Who will use my data?
Xtrava Group Limited
What will happen if I contact you?
We will store and process your data in order to allow us to provide our services to you as a recruitment company. We will also send any relevant details to authorities such as HMRC, Inland Revenue and any other organisation that requires them by law.
We may contact you to participate in anonymous research via surveys. The purpose of such research is to provide insight for our clients, as well as to generate statistics relevant to our business and brand.
We want to assure you that your responses to anonymous surveys are completely anonymous, and responses cannot be traced back to the respondent. No personally identifiable information is captured unless you voluntarily offer personal or contact information in any of the comment fields. Additionally, your responses are combined with those of many others and summarized in a report to further protect your anonymity.
What will happen if I contact you?
If you contact us as a candidate looking for work, we will use your information to send you the information that you have requested and updates, job vacancies and other information that we think you will be interested in. If you contact us as a client with possible vacancies to fill or with other related requests, we will use your information to send any requested information as well as updates and other information that we think you will be interested in as well as updates relevant to the positions advertised.
What data will be stored?
As an applicant, client, or employee, we will store your personal details such as application forms, identity documents and bank details in order to provide our services to you. We may also collect personal data about you from third parties, such as references supplied by former employers. As a potential employer, we will store any data required in order to provide our services to you and meet any contractual obligations. This might include potential contact information for example.
What data will be shared?
We will only share any data that is particularly relevant to our process in order to provide the services that we offer. We will only share information with the third parties detailed in this policy.
How long?
Your data will be stored for up to 7 years following the last contact we have with you, after which time your data will be deleted. For more information please ask for our Data Retention policy
Who can access my data?
We will never sell, share or otherwise distribute your data to any other third party other than as described here. We will share your information with any regulator or legal body that requests it as well as any parties relevant to the application process. Whether that be client companies with possible vacancies, or applicants to any roles.
How is my data kept secure?
We will store your data on secure UK based servers which will be processed in the UK. We use industry standard security protocols/technology to secure your data.
We take your privacy seriously and will only use your personal information to provide the services you have requested from us and to send you information about services, vacancies and other information you may be interested in. We will never sell, share or use your personal information other than as described here.
About This Privacy Policy
The General Data Protection Regulation (GDPR) describes how organisations must collect, handle, process and store personal information. These rules apply regardless of whether data is stored electronically, on paper or on other materials. To comply with the law, personal information must be collected and used fairly, stored safely and not disclosed unlawfully. GDPR is underpinned by eight important principles. These say that personal data must:
- Be processed fairly and lawfully
- Be obtained only for specific, lawful purposes
- Be adequate, relevant and not excessive
- Be accurate and kept up to date
- Not be held for any longer than is necessary
- Processed in accordance with the rights of the data subjects
- Be protected in appropriate ways
- Not be transferred outside the United Kingdom, unless that country or territory also ensures an adequate level of protection
We take these responsibilities seriously, this document describes our approach to data protection.
This policy helps to protect us from data security risks, including:
- Breaches of confidentiality. For instance, information being given out inappropriately
- Failing to offer choice. For instance, all individuals should be free to choose how the company uses data relating to them
- Reputational damage. For instance, the company could suffer if hackers successfully gained access to sensitive data
Who We Are And How To Contact Us
Xplor Partners is registered in the United Kingdom and is registered with the Information Commissioner’s Office. The data controller is: Thomas Naylor for external queries and the same for internal queries. You can contact us in any of the following ways:
Name: Thomas Naylor
Company name: Xtrava Group
Address: Xtrava Group, The Courtyard, Oakwood Park Business Centre, Fountains Road, Harrogate, HG3 3BF
E-mail address: [email protected]
Who This Policy Applies To
This policy relates to data subjects of Xtrava Group including clients (potential employers), candidates, workers and employees, and all other individuals. Processing of your data is required in order to offer you our recruitment and selection services. This policy applies to individuals who have shared their data with Xtrava Group as either a customer, candidate, employee, supplier or in any other capacity.
It applies to all data that the company holds relating to identifiable individuals, even if that information technically falls outside of the GDPR. This can include:
- Names of Individuals
- Postal addresses
- Email Addresses
- Telephone numbers
What This Policy Applies To
This section describes the lawful basis for processing your data and applies to the information about yourself that you choose to provide us with or that you allow us to collect. This includes:
- The Information you provide when you contact us
- When you contact us in order to discuss using our services
- Information we collect about how you use the website
- Information relating to products and services we offer to you and other transactions including financial and other personal information required to complete these transactions
- Information that is given and stored as part of our ongoing relationship
- Information we collect from other sources such as the internet, social media, commercial databases, other companies, and other third parties
- Information we derive from information we collect about you – for example where we derive your email address from your name and company name combined
We do not routinely collect or process sensitive data about you however where this is the case we will ensure we keep that data safe as required under Article 9 of GDPR.
Our Lawful Basis – What this policy applies to
This section describes the lawful basis for processing your data and applies to all personal information collected, stored, and processed which relates to any individual.
We will only use your personal data for the purposes for which we collected it and as you would reasonably expect your data to be processed and only where there is a lawful basis for such processing, for example:
As an employee / candidate / recruit / contractor etc….: We may collect and process information about you, including your name, date of birth, address, contact details (including email address and mobile phone number), employment details, and other data collected as part of any application for employment. We may take personal information from:
- Information that you provide to us when registering with our website (including your email address)
- Information that you provide when completing your application (including your name, gender, date of birth and any educational details and employment details you provide)
- Information that you provide to us when signing up to any lists to receive correspondence from
- Information we collect from other sources such as the internet, social media, commercial databases, other companies, and other third parties
- Information we derive from information we collect about you – for example where we derive your email address from your name and company name combined
- Information relating to any vacancies, jobs, or employment you accept
Personal data we receive will be used for the purposes it was provided, including: - To respond to queries from you regarding vacancies and employment
- To manage and administer the relationships between you and us
- To notify you about changes to our services and to otherwise communicate with you; for example, we will use your contact details in order to respond to any queries that you submit to us
- To obtain feedback from you regarding us
- Tell you about any place of work changes e.g. shift patterns, new assignments or any other changes regarding your Job Role.
In accordance with your preferences, we may also use your personal information to provide you with information about products, services, promotions and offers that may be of interest to you. We may use your personal information in order to ascertain the services, opportunities, promotions and offers that are likely to be of particular interest to you. This document explains how you can change whether to receive this information. Please note that, even if you choose not to receive this information, we may still use your personal information to provide you with important services communications, including communications in relation to any purchases you make or services you use.
How to change your preferences
We operate in line with GDPR data protection guidelines. We respect your rights and will respond to any request for access to personal information and requests to delete, rectify, transfer, data and to stop processing. We will also advise you on how to complain to the relevant authorities, namely the Information Commissioner’s Office. Any requests or objections should be made in writing to the Data Controller or you can visit our website, call, or email us to contact us to change your preferences at any time.
Scope of Agreement
By submitting your personal data on this site or as required for us to provide products and services to you, you are affirming your agreement for such information to be used in accordance with this privacy policy. You will be able to change your preferences at any time by the methods described as prescribed in this document.
We may from time to time use your information for marketing, account management or relationship management purposes. The main purpose of this is to provide you with information about services which we think may be of interest to you and/or to maintain any existing relationship we may have with you.
How we store and process your data
Your data will be collected, stored and processed primarily in the UK, where we transfer your data outside the UK, we ensure that appropriate technical and organisational safeguards are in place to protect your data. Your data will be stored for a period of time after our last interaction – this period is defined in our Data Retention policy.
In order to provide our services we may use carefully selected third parties such as:
- CRM providers – storage
- Outlook – data shared by candidates
- One Drive – storage restricted access for specific user
- CV are formatted by a third party located out of EEA
- Contracts are sent through DocuSign
These third parties may operate outside the UK, if this is the case we will ensure precautions are in place to protect your data.
We may also use recognised third parties to take payment, conduct credit reports and other checks, manage our company accounts and provide banking services. We will store transactions, payment and order data for up to 7 years or for as long as required by UK financial and company regulations. These third parties may operate outside the UK, if this is the case we will ensure precautions are in place to protect your data.
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose and/or we are acting as you would reasonably expect. If you wish to find out more about how the processing for the new purpose is compatible with the original purpose, please email us. If we need to use your personal data for a purpose unrelated to the purpose for which we collected the data, we will notify you and we will explain the legal ground of processing.
We may be legally obliged to disclose your personal information without your knowledge.
Our Obligations
We are a Data Controller. In relation to the information that you provide to us, we are legally responsible for how that information is handled. We will comply with the GDPR in the way we use and share your personal data. You can see more about your rights at: https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
Third Parties
We may have to share your personal data with the parties set out below for the purposes described in this document:
For candidates/workers – Prospective employers and companies that may offer you work and other relevant third parties
For clients – Candidates / employees / workers that may be interested in any vacancies and other relevant third parties
For all users of our site:
- Companies where you have applied for a vacancy
- Other companies we believe you would be interested in working for
- Companies that may have vacancies that match your preferences
- Service providers who provide IT and system administration services.
- Other companies as required for us to provide our services to you and/or our clients
- Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, credit scoring, banking, legal, fraud protection, insurance and accounting services etc..
- Third parties who use such data for non-marketing purposes (including credit and risk assessment and management, identification and fraud prevention, debt collection and returning assets to you).
- HM Revenue & Customs, regulators and other authorities based in the United Kingdom and other relevant jurisdictions who require reporting of processing activities in certain circumstances.
- Third parties as required to provide our services to you and our clients
- Social media platforms
- Other IT platforms and services as required to provide our services to you and to operate our company
- Other companies where we have a legitimate interest and where we believe the purpose is consistent with the original purpose and always as you would reasonably expect
We require all third parties to whom we transfer your data to respect the security of your personal data and to treat it in accordance with the law. We only allow such third parties to process your personal data for specified purposes and in accordance with our instructions.
Security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know such data. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We will report any breaches or potential breaches to the appropriate authorities within 24 hours and to anyone affected by a breach within 72 hours. If you have any queries or concerns about your data usage, please contact us.
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
Cookies
A cookie is a small file which asks permission to be placed on your computer’s hard drive. Once you agree, the file is added and the cookie helps analyse web traffic or lets you know when you visit a particular site. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences. We use traffic log cookies to identify which pages are being used. This helps us analyse data about webpage traffic and improve our website in order to tailor it to customer needs. We only use this information for statistical analysis purposes and then the data is removed from the system.
Overall, cookies help us provide you with a better website by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us.
You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of the website.
As well as your ability to accept or reject cookies, we also require your permission to store cookies on your machine, which is why when you visit our site, you are presented with the ability to accept our terms of use, including the storage of cookies on your machine. Should you not accept, then you are free to leave our website, at any time.
Legitimate Interests
We have completed a detailed Legitimate Interest Assessment to ensure that sharing your information and processing your information as described here is reasonable and that we have an appropriate lawful basis.
Contacting us, exercising your information rights and Complaints
If you have any questions or comments about this Privacy Policy, wish to exercise your information rights in connection with the personal data you have shared with us or wish to complain, please contact: Thomas Naylor at Xtrava Group.
We will process SARs within 30 days, SAR responses are usually free but we reserve the right to charge for excessive or unfounded requests. We fully comply with Data Protection legislation and will assist in any investigation or request made by the appropriate authorities.