Middleton Jones Ltd provide recruitment and headhunting services to clients looking to recruit personnel into their business. We also work with candidates by confidentially networking through the market to identify suitable hiring companies.
This privacy notice describes what personal data we collect, why we collect it, how we collect it, and how we use it to help clients fill vacancies and candidates to find new roles. It also describes how we comply with our legal obligations.
Personal data and privacy are important. We are committed to best practice in all areas of our business including helping protect your data and you as an individual.
The privacy notice applies to the personal data of our website users, candidates, clients, suppliers, and other people we may contact for reference taking or emergency contacts.
Depending on the circumstances you may have legal rights and where possible we have described these.
This privacy notice will be updated as needed. To stay up to date, please visit this page on a regular basis.
At Middleton Jones Ltd we make every effort to comply with our responsibilities under the General Data Protection Regulation (GDPR).
How is personal data collected?
Information is provided to us in a variety of forms, such as in person, over the phone, via email and on our website.
Personal data is usually provided to us by one of two methods: 1) directly by you, and 2) from third parties.
At times, legal and contractual obligations mean we are required to see original documents and retain copies for our own purposes e.g., passports and work visas.
All phone calls are recorded, both inbound and outbound, and ensuring a full audit trail is available.
Where possible, all information is stored electronically using state of the art systems, including our Customer Relationship Management (CRM) system and accounting system. In addition, all emails and phone calls involving candidates and clients are automatically stored in our Customer Relationship Management (CRM) software with all other details of the relevant person.
Obviously, our main area of business is recruitment, including headhunting, which means connecting the right people with the right jobs. This means we may need to collect information from third parties including other people and data sources such as job boards, LinkedIn and other websites.
What information is being collected?
To ensure we are able to fulfil our duties as a professional recruitment consultancy we are required to collect personal data where relevant. Whilst not an exhaustive list, the information we typically require is described below.
Candidate data – We will only ask for personal data such as your name, address, contact details, education details, employment history, professional qualifications, immigration status, Curriculum Vitae (CV), reasons for gaps on your CV, current and expected remuneration, your current notice period or availability, job applications, conversations, interviews, meetings and placements. Where we are required to carry out additional background checks e.g. DBS checks, further information may be required.
Client data – We need to collect information about you or others in your organisation to ensure we can provide you with: 1) finding candidates who are the right fit for your organisation, and 2) providing you with information we think may be useful to you e.g. updated salary and market data. Information we collect may include contact details such as phone numbers, email addresses, postal addresses, and job titles. We will also record recruitment activity e.g. vacancies registered, conversations, meetings, interviews, and placements. We may also record other information that people choose to tell us.
Supplier data – We need a small amount of data to ensure we can maintain a smooth service. This includes contact details of relevant people in your organisation such as phone number, email address, postal address and job title. We may also record other pieces of information that people inform to tell us.
Other peoples data we receive from candidates, clients and staff e.g. referrals, referees, and emergency contacts – As part of our service, we may need to perform background checks to validate information or for use in an emergency. For these purposes, we usually only require very basic contact details such as a phone number and email address.
Website users – To continually improve our online user experience we need to track usage to identify trends. This may include how you use our website, the pages viewed, and the frequency, time, and duration of website visits. Other users may choose to log in to our website for a better user experience and submit additional information.
How will personal data be used?
We use personal data to establish, exercise and defend legal claims and to comply with contractual obligations. We also use it for:
Recruitment activities – to include helping the right individuals connect with the right organisations for the right job. This includes everything from identifying candidates, notifying candidates of relevant jobs, screening candidates, notifying clients of relevant candidates, introducing candidates to companies, providing interview feedback, negotiating remuneration packages, providing support during resignation, and helping with the on-boarding process.
Marketing activities – to include profiling of jobs and candidates; informing clients and candidates of possible matches; automatic job alerts; informing clients and candidates of relevant market research or information; and advertising jobs on third-party media channels.
Information we obtain from other sources
This is information we obtain about you from sources such as Job Boards, Social Media sites, Corporate Websites or Direct Referrals. In this case we will inform you and tell you where we got your personal data from. We will also provide a link to this privacy notice which explains our use of your personal data.
We work closely with third parties including sub-contractors in technical, professional, payment and other services, advertising networks, analytics providers, search information providers, credit reference and background check agencies, and professional advisors. We may receive information about you from them for the purposes of our recruitment services and ancillary support services.
All our recruitment and marketing activities are based on what we think will serve our clients and candidates best. However, we may need your consent for some aspects of our activities which are not covered by our legitimate interests (in particular, delivery of direct marketing to you through digital channels) and, depending on the situation, we’ll ask for this via an opt-in or soft-opt-in (which we explain further below).
Soft opt-in consent is a specific type of consent which applies where you have previously engaged with us (for example by submitting a job application or CV or registering a vacancy to be filled if you are an individual), and we are marketing other recruitment-related services. Under ‘soft opt-in’ consent, we will take your consent as given unless or until you opt out. For most people, this is beneficial as it allows us to suggest other jobs to you alongside the specific one you may have applied for, significantly increasing the likelihood of us finding you a new position.
In soft opt-in cases if we have had no contact with you for a period of 1 year, we will automatically email you inviting you to opt-out if you wish. If we do not receive a response, we will continue to process your personal data in the usual manner for another 1 year thereafter. We will then email you again inviting you to opt-out and so on.
For other types of e-marketing, we are required to obtain your consent. Where we have that consent but have not heard from you for a year then we will email you asking you if you wish to consent to receive marketing information. If you do not respond within a month of the email we will remove you from our non – recruitment marketing database.
At any time, you can opt out of all marketing communications including emails, SMS and automatic job alerts, by clicking unsubscribe or contacting us directly. Alternatively, if you are not happy with the accuracy of our matching, you can provide us with more accurate information.
Even if you have opted out from our marketing communications, it is possible that your details may be recaptured through public sources in an unconnected marketing campaign. If this happens, please inform us so we can advise and/or act accordingly.
For all clients, subject to any applicable laws and requirements, we will not, as a matter of course, seek your consent when sending marketing materials to a corporate postal or email address. However, if the corporate email or postal address contains personal data i.e., someone’s name then you will have the right to opt out of all future marketing communication.
Article 6(1)(f) of the GDPR says we are able to process your data where it “is necessary for the purposes of the legitimate interests pursued by [us] or by a third party, except where such interests are overridden by the interests or fundamental rights or freedoms of [you] which require protection of personal data.”
We think the following activities benefit the people we work with and do not prejudice individuals in any way.
- We think it is reasonable that if you are looking for a new job, have posted your CV to a job board, connect with our staff on LinkedIn or other social media platforms, or indicated you are open to new career opportunities on professional networking site, then you are happy for us to collect and process your data with the view of providing a recruitment service to you, share your details with employers, and assess your skills against our database of vacancies.
- A prospective employer may want to double check the information provided to us. We need to do these things to ensure we can operate as a profitable business whilst ensuring a high level of service to you and other candidates.
- We think it is reasonable that we may ask you to participate in a customer satisfaction survey as this will help us to refine and improve over time
- We want to provide you with tailored job recommendations and relevant articles to assist in your job search and/or ongoing career development. We, therefore, think it is reasonable for us to process your data in this way.
- To ensure our business runs smoothly, we may need to process your information for internal activities such as payroll and invoicing.
We have legal obligations that mean we have a legitimate interest in processing and sharing your data in relation to a crime, tax, and litigation.
- We store personal data of individual contacts in organisations, as well as keeping records of conversations, meetings, registered vacancies, interviews and placements. We think this is reasonable otherwise we are unable to provide a service to your business or to candidates seeking new jobs.
- We think it is reasonable that we may ask you to participate in a customer satisfaction survey as this will help us to refine and improve over time.
- We think it is reasonable for us to use your data to make contact with you if we believe we have a registered candidate who may benefit your organisation based on our own knowledge and experience.
- We think it is reasonable for us to share personal data and information about your organisation with a candidate interested in applying for a vacancy in your company.
- We think it is reasonable for us to assess your vacancies against our database of candidates.
We use and store personal data of individuals within your organisation to facilitate the receipt of services from you as one of our suppliers. We also hold financial details, so that we can pay you for your services. We deem all such activities to be necessary within the range of our legitimate interests as a recipient of your services.
Other peoples data we receive from candidates, clients and staff e.g. referrals, referees, and emergency contacts:
If you have been put down by a Candidate or a prospective member of Staff as one of their referees, we use your personal data in order to contact you for a reference. This is a part of our quality assurance procedure, so we deem it necessary for our legitimate interests as an organisation offering recruitment services and employing people ourselves.
If we have been given your details via a referral, it is because someone who knows you thinks we might be able to assist you. Therefore, we think this is in our legitimate interest for us to use your store and process your data to ensure we follow up with this information by contacting you.
If a Candidate or Staff member has given us your details as an emergency contact, we will use these details to contact you in the case of an accident or emergency. We are sure you will agree that this is a vital element of our people-orientated organisation, and so is necessary for our legitimate interests.
Who will personal data be shared with?
In accordance with law and requirements, we may share your personal data in various ways and for various reasons. For example:
- Our clients who may have a suitable vacancy, either at present or in the near future.
- Candidates who may be suitable or interested in working for your organisations.
- Individuals or organisations who hold information on you, or your business, that is required for the recruitment process.
- Government and authorities where we believe the law, or other regulations, requires us to share data.
- Third-party service providers who perform functions on our behalf e.g. lawyers, accountants, auditors, and technical support.
- Third-party outsourced IT, telecoms, document storage providers, and marketing platforms, who collectively enable us to provide our service.
Data Protection Rights
Where we hold personal data on you, you may have various rights. Please contact us and we will deal with your request without undue delay and in accordance with any applicable laws.
Your rights include:
- The right to object – if we are using your data because we deem it necessary for our legitimate interest, and you do not agree, you have the right to object. Generally, we will only disagree with you if certain limited conditions apply.
- The right to withdraw consent – Where we have obtained your consent in the past to process personal data, you are entitled to change your mind and withdraw your consent at any time.
- Data Subject Access Request (DSAR) – you have the right to ask us what personal information we hold on you at any time and a right to certain supplementary information.
- The right to rectification – you can ask us to correct any factually incorrect information we hold about you.
- The right to erasure – in certain situations you have the right to request that we erase your data.
- The right of data portability – you have the right to request that your data is moved from us to another data controller.
Please let us know if you wish to exercise one of your rights. Generally, we will deal with your request within a month (although the law does sometime allow us up to three months) and without charge (again sometimes the law does allow us to make a charge and if we propose to do so we will tell you why and what it will be).
We need to be satisfied that the person making the request is entitled to make it. We may ask you to prove who you are by supplying a copy of a passport or photocard driving licence or something similar.
Sometimes we may refuse your request completely or in part. If we do, we will tell you why.
We may be unable to erase your data where a request conflicts with our legal obligations or legitimate interests.
Instead of full erasure, we may opt to restrict all future processing of your data to ensure we maintain a copy of your request to be erased and prevent the accidental re-addition of your details back in to our system from a third-party.
Where we do erase your data live from our system, records maybe held in a recycle bin for 60 days from the date of deletion, after which they are permanently deleted and we are unable to restore any data.
Is the intended use likely to cause individuals to object or complain?
In the vast majority of cases, we do not believe individuals will object or complain, unless their data is being used for non-relevant activities, without their knowledge, or without their permission.
We aim to undertake best practice in all areas of our business. And if you feel we have not, then we welcome contact from you and will aim to immediately correct any errors on our part. If, after we have been given the opportunity to resolve your complaint you are still dissatisfied you have the right to lodge a complaint with the Information Commissioner’s Office; we recommend visiting their website https://ico.org.uk for up-to-date contact details.
Telephone – +44 (0)20 7947 9266
Email – [email protected]
Letter – 4 Old Park Lane Mayfair London W1K 1QW
Note: Middleton Jones Ltd has the right to make changes to this policy without any prior notice.