VMA Global Resourcing Group Ltd and its subsidiaries (”we”,”us”,”our”) are committed to protecting and respecting your privacy.
Our GROUP means our subsidiaries, our ultimate holding company and its subsidiaries, our associated companies as defined in section 1159 of the UK Companies Act 2006.
This notice sets out the basis on which any personal data we collect from you or retain about you will be used by us.
The General Data Protection Regulation (“GDPR”) (Regulation (EU) 2016/679) is a new regulation which replaces the Data Protection Regulation (Directive 95/46/EC). GDPR aims to harmonise data protection legislation across EU member states, enhancing privacy rights for individuals and providing a strict framework within which commercial organisations can legally collect, retain and use personal information. GDPR will be enforceable in the UK from 25 May 2018. We are committed to upholding the principles of GDPR prior to its introduction.
For the purposes of GDPR, the data controller is VMA Global Resourcing Group Ltd of 23 Bedford Square, London WC1B 3HH.
We collect information about you to carry out activities relating to our core business and ancillary services as a recruitment business. You might be:
• A candidate seeking new work opportunities (permanent or temporary)
• A client we engage with to find new recruits
• A referee
• A supplier or sub-contractor to support our services
• An employee (permanent, temporary or on a consultant basis
The information we collect and retain about you may be different depending on who you are, but will typically include name, address, private and corporate e-mail address and phone number, position and company details, compliance documentation and references verifying qualifications and experience and right to work in the United Kingdom, or in the jurisdiction in which you are seeking employment, curriculum vitae, salary details, links to professional profiles available in the public domain e.g. LinkedIn, Twitter, business Facebook or corporate website, marketing and event interests.
As a recruitment business we are dedicated to supporting our candidates’ career aspirations and our clients’ resourcing needs and as such require a database of candidate and client personal information containing historical information as well as current resourcing requirements.
A fundamental and essential process of our business is to introduce candidates to clients for permanent employment, temporary work placements or independent professional contracts. Using your information in this way is called our Legitimate Business Interest.
We also use your information to:
• Provide you with information and services that you request from us or we think will be of interest to you because it is relevant to your career or to your organisation.
• Provide you with information about other goods and services we offer that are similar to those that you have already been provided with or enquired about.
• Notify you about changes to our service.
• Ensure that content from our website is presented in the most effective manner for you and for your computer.
In addition to using your information for our Legitimate Business Interest, we may also rely on contract, legal obligation and consent for specific uses of information:
• We will rely on contract if we are negotiating or have entered into a placement agreement with you or your organisation or any other contract to provide services to you or receive services from you or your organisation.
• We will rely on legal obligation if we are legally required to hold information about you to fulfil our legal obligations.
• We will in some circumstances rely on consent for particular uses of your information and you will be asked for your express consent, if legally required.
Should we want or need to rely on consent to lawfully process your information we will request your consent orally, by email or by an online process for the specific activity we require consent for and record your response on our systems. Where consent is the lawful basis for processing your information, you have the right to withdraw your consent to this particular processing at any time.
We collect personal information from a range of sources, including directly from the information you provide to VMA Global Resourcing Group Ltd or through third parties we may work with such as sub-contractors in technical and professional services and reference agencies, as well as via our website when you complete an online form, and through a range of other publicly available sources such as directories, job boards, online CV libraries, social media sites, corporate websites, and LinkedIn.
In the case of information we collect via publicly available sources, we will inform you – within 30 days, but no later than 60 days of collecting the information – that we hold the information, where the information originates from, and for what purpose we intend to retain and process the information. As part of this communication we will ask for your consent to add your information to our database.
We use this technical information to:
• Administer our website and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes.
• Improve our website to ensure that content is presented in the most effective manner for you and for your computer.
• Allow you to participate in interactive features on our website, when you choose to do so.
• Keep our website safe and secure.
• Make suggestions and recommendations to you and other users of our website about services that may interest you or them.
We do not undertake automated decision-making or profiling. We do use our computer systems to search and identify personal data in accordance with parameters set by a person. A person will always be involved in the decision making process.
In the course of running our business, we may need to share your personal information with selected third parties either within or outside of the European Economic Area (EEA). Depending on who you are, these third parties may include:
• Any member of our GROUP both in the EEA and outside of the EEA.
• Clients for the purpose of introducing candidates to them.
• Candidates for the purpose of arranging interviews and work placements.
• Credit reference agencies, our insurance broker, compliance partners or other sub-contractors for the purpose of assessing your suitability for a role where this is a condition of us entering into a contract with you.
• Suppliers or sub-contractors for the performance and compliance obligations of any contract we enter into with them or you.
• Suppliers or subcontractors to support our services.
• Analytics and search engine providers that assist us in the improvement and optimisation of our website.
We may also disclose your personal information to third parties in the following circumstances:
• In the event that we sell or buy any business or assets, in which case we will disclose your personal information to the prospective buyer or seller of such business or assets.
• If the GROUP or substantially all of its assets are acquired by a third party, in which case personal information held by the GROUP about its candidates and clients will be one of the transferred assets.
The lawful basis for third parties to process your personal information include:
• Their own legitimate business interests.
• Satisfaction of their contractual obligations to us as our data processor.
• For the purpose of a contract in place or in contemplation.
• To fulfil their legal obligations.
The information that we collect from you may be transferred to, and stored at, a destination outside of the EEA, but within the GROUP. It may also be transferred to third parties outside of the EEA for the purpose of providing our recruitment services. It may be processed by staff operating outside of the EEA who work for us or for one of our suppliers. This includes staff engaged in, among other things, our recruitment services and the provision of support services. By submitting your personal information, you agree to this transfer, storing or processing. The GROUP will take all reasonable steps to ensure that your information is treated securely and in accordance with this privacy notice.
All information you provide to us is stored on our secure servers. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our website, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal information, we cannot guarantee the security of information transmitted to us through our website and any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
All of the data we capture is stored on a secure server and encrypted. It is only accessible by authorised users and we deploy many security systems to ensure unauthorised access it not permitted and access is only granted to approved and authorised users. Data transmitted between the internal user and the server is encrypted to ensure it is protected in transit.
We understand our legal duty to retain accurate information and only retain personal information for as long as we need it for our legitimate business interests and that you are happy for us to do so. Accordingly, we have a data retention notice and routinely run reports to identify and remove data that we no longer have a legitimate business interest in maintaining.
We try to ensure the information we hold about you is accurate by:
• Enabling you to manage your information by contacting our Data Protection Officer at DPO@vmagroup.com and to review whether the details we hold about you are accurate.
• Enabling you to keep in touch with us so you can let us know of changes to your personal information.
The criteria we use to determine whether we should retain your personal information includes:
• The nature of the personal information.
• The perceived accuracy of the information
• Our legal obligations.
• Whether an interview or placement has been arranged.
• Our recruitment expertise and knowledge of the industry by country, sector and job role.
• Whether you have told us you want to be contacted about future job opportunities.
Due to legal obligations, we may archive part or all of your personal information or retain it on our financial systems only, deleting all or part of it from our main Customer Relationship Manager (CRM) system. We may anonymise parts of your information, particularly following a request for suppression or deletion of your information. If your information is deleted we will have no records remaining, so may re-engage with you if your information is available in a public location.
Our current retention notice is available upon request.
You have the right to ask us not to process your personal information for marketing purposes. We will usually inform you (before holding your information) if we intend to use your information for such purposes or if we intend to disclose your information to any third party for such purposes, and we will collect express consent from you if legally required prior to using your personal information for marketing purposes.
You can exercise your right to accept or prevent such processing by emailing DPO@vmagroup.com and requesting this.
Our website may, from time to time, contain links to and from the websites of our partner networks and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
The GDPR provides you with the right to:
• Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
• Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
• Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.
• Request the restriction of processing your personal information. This enables you to ask us to suspend the processing of your personal information, for example if you want us to establish its accuracy or the reason for processing it.
• Request the transfer of your personal information to another party in certain formats, if practicable.
• Make a complaint. In the first instance we would ask to you to contact us at email@example.com and register the issues, allowing us to respond within 14 days. If you are not satisfied with the response, we suggest you contact a supervisory body, which in the United Kingdom is the Information Commissioner’s Office. The ICO can be contacted through this link: https://ico.org.uk/concerns/.
You are also able to find out more from the Data Protection Authority in your country:
Germany – Die Bundesbeauftragte für den Datenschutz und die Informationsfreiheit – http://www.bfdi.bund.de/
Netherlands – Autoriteit Persoonsgegevens – https://autoriteitpersoonsgegevens.nl/nl
Belgium – Commission de la protection de la vie privée – http://www.privacycommission.be/
France – Commission Nationale de l’Informatique et des Libertés (CNIL) – http://www.cnil.fr/
Switzerland – Federal Data Protection and Information Commissioner (FDPIC) – https://www.edoeb.admin.ch
Access to information
GDPR gives you the right to access information held about you. We encourage you to contact us to ensure the information we hold about you is accurate and complete.
Your right of access can be exercised in accordance with the Data Protection Act 1998 (and the GDPR once it is in force from 25 May 2018). Prior to 25 May 2018, any access request under the Data Protection Act will be subject to a fee of £10 to meet our costs in providing you with details of the information we hold about you. No fee will apply after 25th May 2018.
A subject access request should be submitted to DPO@vmagroup.com.
Any changes we make to our privacy notice in the future will be posted on this webpage (www.vmagroup.com/privacy) and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our privacy notice.
Questions, comments and requests regarding this privacy notice should be addressed to our Data Protection Officer at DPO@vmagroup.com.