Privacy notice
Introduction
BNF Consultants Ltd. take the privacy of our clients and candidates seriously. All organisations that process personal data are required to comply with data protection legislation. This includes in particular the Data Protection Act 1998 (or its successor) and the EU General Data Protection Regulation (together the ‘Data Protection Laws’). The Data Protection Laws give individuals (known as ‘data subjects’) certain rights over their personal data whilst imposing certain obligations on the organisations that process their data.
As a recruitment business the Company collects and processes both personal data and sensitive personal data. It is required to do so to comply with other legislation. It is also required to keep this data for different periods depending on the nature of the data.
This policy sets out how the Company implements the Data Protection Laws. It should be read in conjunction with the Data Protection Procedure.
Who we are?
BNF Consultants ltd is boutique recruitment organisation and the nature of business activities means BNF is considered as “data controller” for the purpose of this policy. See below for information related to Data handling activities at our organisations:
Data Processor: Faria Humayra
Contact : faria@bnfconsultants.co.uk
Phone: 02084 323 454
What information do we collect?
BNF collects, stores, and uses personal data to provide our recruiting, employment, and consulting services. We collect personal data about individuals who apply for employment or engagement with us, or placement by us through our recruitment services, and those who are representatives of our customers (including prospective customers).
Most of this data is provided by you directly when you contact us, submit an application, attend an in-person recruiting event, through phone conversations, and contact us about our services or employment relationship. We may collect data via third part job sites and or social media public profiles (i.e. LinkedIn, Facebook) etc.
We have set out further details below (not an exhaustive list) on the types of personal data we collect, and store;
Name; Date of birth; Gender; Job history; Educational qualifications; qualification certificates; Profession; Contact information such as home address, email addresses and telephone numbers; Demographic information such as postcode, preferences and interests; financial information such as bank account details; We may be requested to conduct historical, criminal, legal and financial searches as requested.
* For the purposes of this policy we use the term ‘personal data’ to include ‘sensitive personal data’ except where we specifically need to refer to sensitive personal data.
How do we use personal information?
- All personal data is processed and stored securely, for no longer than is necessary in light of the reason(s) for which it was first collected. We will comply with our obligations and safeguard your rights under the GDPR at all times. For more details on security see section 7, below.
- Our use of your personal data will always have a lawful basis, either because it is necessary for Our performance of a contract/employment services with you, because you have consented to Our use of your personal data (e.g. by registering with us, subscribing to job alerts, engaging in employment services with us), or because it is in Our legitimate interests. Specifically, We may use your data for the following purposes:
- Supplying Our services to you (please note that We require your personal data in order to enter into a contract/employment service with you);
- Personalising and tailoring Our services for you;
- Replying to emails, telephone calls and texts from you;
- Supplying you with emails and job alerts that you have opted into (you may unsubscribe or opt-out at any time;
- Market research;
- With your permission and/or where permitted by law, We may also use your data for marketing purposes which may include contacting you by email and telephone and text message and post with information, news and offers on Our services. We will not, however, send you any unsolicited marketing or spam and will take all reasonable steps to ensure that we fully protect your rights and comply with our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations.
What legal basis do we have for processing your personal data?
The Company will only process personal data where it has a legal basis for doing so (see Annex A). Where the Company does not have a legal reason for processing personal data any processing will be a breach of the Data Protection Laws.
The Company will review the personal data it holds on a regular basis to ensure it is being lawfully processed and it is accurate, relevant and up to date and those people listed in the Appendix shall be responsible for doing this.
Before transferring personal data to any third party (such as past, current or prospective employers, suppliers, customers and clients, intermediaries such as umbrella companies, persons making an enquiry or complaint and any other third party (such as software solutions providers and back office support)), the Company will establish that it has a legal reason for making the transfer.
When do we share personal data?
We will never share our candidates’ personal details or Curriculum Vitae with a third party without the candidate’s explicit consent, and then we will only share the personal information with that one company or individual.
BNF Consultants Ltd holds its employees, agents, and suppliers accountable for maintaining the trust that you place in us with your personal information.
For individuals, BNF shares the data that is necessary to perform its staffing and outsourcing services with customers, suppliers, or with service providers that may be engaged to assist in managing the processes required to provide these services.
Where do we store and process personal data?
Your data will only be stored in the UK.
Data security is very important to us, and to protect your data we have taken suitable measures to safeguard and secure data collected through Our Site or through other mediums.
How do we secure personal data?
The Company has implemented measures and procedures that adequately protect the privacy of individuals and ensures that data protection is integral to all processing activities. This includes implementing measures such as:
- Data minimisation (i.e. not keeping data for longer than is necessary);
- Pseudonymisation;
- Anonymisation
- Cyber security
How long do we keep your personal data for?
We will retain your personal information for as long as is necessary in connection with our agreement with you, to provide you with the services requested, or for other necessary purposes such as compliance with a law, regulation, or other legal authority, or as is otherwise permitted to be maintained for other legal purposes, such as audit, security, fraud prevention, or preserving and defending BNF Consultants Ltd.’s legal rights.
Your rights in relation to personal data
BNF Consultants Ltd. respects the right of data subjects to access and control their personal data. As a data subject, you have the following rights under the GDPR, which this Policy and Our use of personal data have been designed to uphold:
- The right to be informed about our collection and use of personal data
- The right of access to the personal data we hold about you
- The right to rectification if any personal data we hold about you is inaccurate or incomplete (please contact us using the details in section “How to contact us?”)
- The right to be forgotten – i.e. the right to ask us to delete any personal data we hold about you (if you would like Us to delete it, please contact us using the details in section “How to contact us?”)
- The right to restrict (i.e. prevent) the processing of your personal data
- The right to data portability (obtaining a copy of your personal data to re-use with another service or organisation)
- The right to object to us using your personal data for particular purposes
Use of automated decision-making and profiling
The Company will not subject individuals to decisions based on automated processing that produce a legal effect or a similarly significant effect on the individual, except where the automated decision:
- Is necessary for the entering into or performance of a contract between the data controller and the individual;
- Is authorised by law; or
- The individual has given their explicit consent.
The Company will not carry out any automated decision-making or profiling using the personal data of a child
Reporting personal data breaches
All data breaches should be referred to the persons whose details are listed in the section “How to contact us?”.
- Personal data breaches where the Company is the data controller:
Where the Company establishes that a personal data breach has taken place, the Company will take steps to contain and recover the breach. Where a personal data breach is likely to result in a risk to the rights and freedoms of any individual the Company will notify the ICO.
- Personal data breaches where the Company is the data processor:
The Company will alert the relevant data controller as to the personal data breach as soon as they are aware of the breach.
- Communicating personal data breaches to individuals
Where the Company has identified a personal data breach resulting in a high risk to the rights and freedoms of any individual, the Company shall tell all affected individuals without undue delay.
The Company will not be required to tell individuals about the personal data breach where:
- The Company has implemented appropriate technical and organisational protection measures to the personal data affected by the breach, in particular to make the personal data unintelligible to any person who is not authorised to access it, such as encryption.
- The Company has taken subsequent measures which ensure that the high risk to the rights and freedoms of the individual is no longer likely to materialise.
How to contact us?
All Company staff & consultants are permitted to add and amend personal data from the Company’s database(s) (‘database’ includes paper records or records stored electronically).
Contact Details For all matters concerning data protection and the associated laws please contact;
Name: Faria Humayra
Title: Founder & Director
Email: faria@bnfconsultants.co.uk
Phone: +44 208 4323 454
Linking to other websites / third party content
If you have a complaint or suggestion about the Company’s handling of personal data then please contact the person whose details are listed above.
Alternatively you can contact the ICO directly on 0303 123 1113 or at https://ico.org.uk/global/contact-us/email/
Annex A:
The lawfulness of processing conditions for personal data are:
- Consent of the individual for one or more specific purposes.
- Processing is necessary for the performance of a contract with the individual or in order to take steps at the request of the individual to enter into a contract.
- Processing is necessary for compliance with a legal obligation that the controller is subject to.
- Processing is necessary to protect the vital interests of the individual or another person.
- Processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the data controller.
- Processing is necessary for the purposes of legitimate interests pursued by the controller or a third party, except where such interests are overridden by the interests or fundamental rights or freedoms of the individual which require protection of personal data, in particular where the individual is a child.
Annex B
- b) The lawfulness of processing conditions for sensitive personal data are:
- Explicit consent of the individual for one or more specified purposes, unless reliance on consent is prohibited by EU or Member State law.
- Processing is necessary for carrying out data controller’s obligations under employment, social security or social protection law, or a collective agreement, providing for appropriate safeguards for the fundamental rights and interests of the individual.
- Processing is necessary to protect the vital interests of the individual or another individual where the individual is physically or legally incapable of giving consent.
- In the course of its legitimate activities, processing is carried out with appropriate safeguards by a foundation, association or any other not-for-profit body, with a political, philosophical, religious or trade union aim and on condition that the processing relates only to members or former members (or those who have regular contact with it in connection with those purposes) and provided there is no disclosure to a third party without the consent of the individual.
- Processing relates to personal data which are manifestly made public by the individual.
- Processing is necessary for the establishment, exercise or defence of legal claims or whenever courts are acting in their judicial capacity.
- Processing is necessary for reasons of substantial public interest on the basis of EU or Member State law which shall be proportionate to the aim pursued, respects the essence of the right to data protection and provide for suitable and specific measures to safeguard the fundamental rights and interests of the individual.
- Processing is necessary for the purposes of preventative or occupational medicine, for assessing the working capacity of the employee, medical diagnosis, the provision of health or social care or treatment or the management of health or social care systems and services on the basis of EU or Member State law or a contract with a health professional and subject to the necessary conditions and safeguards.
- Processing is necessary for reasons of public interest in the area of public health, such as protecting against serious cross-border threats to health or ensuring high standards of quality and safety of healthcare and of medicinal products or medical devices, on the basis of EU or Member State law which provides for suitable and specific measures to safeguard the rights and freedoms of the individual, in particular professional secrecy.
- Processing is necessary for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes, which shall be proportionate to the aim pursued, respect the essence of the right to data protection and provide for suitable and specific measures to safeguard fundamental rights and interests of the individual.