We (Invoke Recruitment Ltd) are committed to protecting and respecting your privacy and the data you provide. Personal information submitted to us via this website is collected, handled and stored securely.
This notice sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed 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) The Regulation 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 operate.
Even though the UK has expressed its intention to leave the EU in March 2019, the GDPR will be applicable in the UK from 25th May 2018. The Government intends for the GDPR to continue in UK law post Brexit and has also introduced a Data Protection Bill to replace the current Data Protection Act in due course.
Your new rights under the GDPR are set out in this notice but will only apply once the GDPR becomes law on 25th May 2018.
Please read the following to understand our views and practices regarding your personal data and how we will treat it.
For the purposes of data protection legislation in force from time to time the data controller is Invoke Recruitment, 11 Bedford Street, Woburn, Milton Keynes, MK17 9QB. Our nominated representative is Jo Wassell, Managing Director of Invoke Recruitment.
Who we are and what we do
We are a recruitment agency and recruitment business as defined in the Employment Agencies and Employment Businesses Regulations 2003 (our business). We collect the personal data of the following types of people to allow us to undertake our business;
- Prospective and placed candidates for permanent or temporary roles;
- Prospective and live client contacts;
- Supplier contacts to support our services;
- Employees, consultants, temporary workers;
We collect information about you to carry out our core business and ancillary activities.
Information you give to us or we collect about you
This is information about you that you give us by filling in forms on our site www.invokerecruitment.com (our site) or by corresponding with us by phone, e-mail or otherwise. It includes information you provide when you register to use our site, apply via our website, subscribe to our services, participate in discussion boards or other social media activities, enter a competition, promotion or survey and when you report a problem with our site.
The information you give us or we collect about you may include your name, address, private and corporate e-mail address and phone number, financial information, compliance documentation and references verifying your qualifications and experience and your right to work in the United Kingdom, curriculum vitae and photograph, links to your professional profiles available in the public domain e.g. LinkedIn, Twitter, business Facebook or corporate website.
Invoke Recruitment Website Cookies
We use the following Cookies on our website:
Analytics - This is a small cookie that allows the site owner to check which pages are the most popular on the site and so provide more site content that is popular to users. It contains no personal or private data at all and is used on millions of websites worldwide.
Remember Me - This is used when you ask the system to remember your login and stores the email address you use to login only.
Shortlist - This is used to be able to remember jobs you place in your shortlist, and is classed as essential to the site functionality and thus can be stored regardless of your selection to ensure the site works. However we wanted to bring this to your attention as we are keen not to hide anything from you.
Information we obtain from other sources
This is information we obtain about you from other sources such as LinkedIn, corporate websites, job board websites, online CV libraries, web forums or discussion boards, your business card, verbal conversations at events, personal recommendations and social media. In this case we will inform you, within one month (max 30 days) or at time of first engaging with you by making this privacy notice available. We inform you about the fact that we hold personal data about you, the source the personal data originates from and whether it came from publicly accessible sources, and for what purpose we intend to retain and process your personal data.
We are working closely with third parties, business partners, clients and may work with parties such as sub-contractors in technical, professional, payment and other services, advertising networks, analytics providers, search information providers, credit reference agencies and professional advisors in some cases. We may receive information about you from them for the purposes of our recruitment services and ancillary support services.
Purposes of the processing and the legal basis for the processing
We use information held about you in the following ways:
To carry out our obligations arising from any contracts we intend to enter into or have entered into between you and us and to provide you with the information, products 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.
To provide you with information about other goods and services we offer that are similar to those that you have already purchased, been provided with or enquired about.
The core service we offer to our candidates and clients is the introduction of candidates to our clients for the purpose of temporary or permanent engagement. However, our service expands to supporting individuals throughout their career and to supporting businesses’ resourcing needs and strategies.
Our legal basis for the processing of personal data is our legitimate business interests, described in more detail below, although we will also rely on contract, legal obligation and consent for specific uses of data.
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 on to information to fulfil our legal obligations.
We will in some circumstances rely on consent for particular uses of your data and you will be asked for your express consent, if legally required. Examples of when consent may be the lawful basis for processing include permission to introduce you to clients (if you are a candidate).
Our Legitimate Business Interests
Our legitimate interests in collecting and retaining your personal data is described below:
As a recruitment business and recruitment agency we introduce candidates to clients for permanent employment, temporary worker placements or independent professional contracts. The exchange of personal data of our candidates and our client contacts is a fundamental, essential part of this process.
In order to support our candidates’ career aspirations and our clients’ resourcing needs we require a database of candidate and client personal data containing historical information as well as current resourcing requirements.
To maintain, expand and develop our business we need to record the personal data of prospective candidates and client contacts.
Should we want or need to rely on consent to lawfully process your data 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 system. Where consent is the lawful basis for our processing you have the right to withdraw your consent to this particular processing at any time.
Other Uses we will make of your data:
- Use of our website;
- To notify you about changes to our service;
- To ensure that content from our site is presented in the most effective manner for you and for your computer.
We will use this information:
- To administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
- To improve our site to ensure that content is presented in the most effective manner for you and for your computer;
- To allow you to participate in interactive features of our service, when you choose to do so;
- As part of our efforts to keep our site safe and secure;
- To measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you;
- To make suggestions and recommendations to you and other users of our site about goods or 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.
Disclosure of your information inside and outside of the EEA
We will share your personal information with:
Any member of our group only if applicable, currently only within the EEA.
Selected third parties including:
- Clients for the purpose of introducing candidates to them;
- Candidates for the purpose of arranging interviews and engagements;
- Clients, business partners, suppliers and sub-contractors for the performance and compliance obligations of any contract we enter into with them or you;
- Subcontractors including email marketing specialists, event organisers, payment and other financial service providers.
- Analytics and search engine providers that assist us in the improvement and optimisation of our site;
- Credit reference agencies, our insurance broker, compliance partners and 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.
We will disclose your personal information to third parties:
- In the event that we sell or buy any business or assets, in which case we will disclose your personal data to the prospective seller or buyer of such business or assets.
- If Invoke Recruitment or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
- If we are under a duty to disclose or share your personal data in order to comply with any legal obligation and to protect the rights, property, or safety of Invoke Recruitment, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
The lawful basis for the third party processing will include:
- Their own legitimate business interests in processing your personal data, in most cases to fulfil their internal resourcing needs;
- 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.
Where we store and process your personal data
All information you provide to us is stored on our secure servers. Any payment transactions will be encrypted [using SSL technology]. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, 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 data, we cannot guarantee the security of your data transmitted to our site; 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.
Retention of your data
We understand our legal duty to retain accurate data and only retain personal data 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 data retention guidelines and run data routines to remove data that we no longer have a legitimate business interest in maintaining.
We do the following to try to ensure our data is accurate:
- Our website enables you to manage your data and to review whether the details we hold about you are accurate.
- Prior to making an introduction we check that we have accurate information about you.
- We keep in touch with you so you can let us know of changes to your personal data.
We segregate our data so that we keep different types of data for different time periods. The criteria we use to determine whether we should retain your personal data includes:
- The nature of the personal data;
- Its perceived accuracy;
- Our legal obligations;
- Whether an interview or placement has been arranged; and
- Our recruitment expertise and knowledge of the industry by country, sector and job role.
We may pseudonymise parts of your data, particularly following a request for suppression or deletion of your data, to ensure that we do not re-enter your personal data on to our database, unless requested to do so.
For your information, Pseudonymised Data is created by taking identifying fields within a database and replacing them with artificial identifiers, or pseudonyms.
Due to the nature of operating as a Recruitment Business, Invoke Recruitment works with candidates for the entire duration of their working life and Invoke Recruitment supports businesses through all growth stages, for the duration of a business's existence. For this reason, the default data retention duration for candidates is the duration of a professional's working life and for clients/ businesses, the duration of the business's existence. Invoke Recruitment retains details until advised otherwise or until advised that the individual has now retired, left a business (as in, is no longer with the business that is Invoke Recruitment’s client) or the business has ceased to trade.
You have the right to ask us not to process your personal data for marketing purposes. We will usually inform you (before collecting your data) if we intend to use your data 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 data for marketing purposes.
You can exercise your right to accept or prevent such processing by checking certain boxes on the forms we use to collect your data. You can also exercise the right at any time by contacting us via firstname.lastname@example.org.
Our site 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 following rights. 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 of your personal information. This enables you to ask us to suspend the processing of personal information about you, 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 to 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/
The Data Protection Act 1998 and the GDPR give you the right to access information held about you. We also encourage you to contact us to ensure your data is accurate and complete.
Your right of access can be exercised in accordance with the Act (and the GDPR once it is in force).
Here are our guidelines to respond to individual requests
“Your right to be informed”
The purpose of this policy is transparency of use of data as part of trading as Invoke Recruitment. This consideration is baked into all of Invoke Recruitment’s practices and part of general staff guidelines.
“Your right of access”
We can extract data from the database in a machine readable format, free of charge, without delay and at the latest within one month of receipt. We will always verify the identity of anyone making a subject access request before handing over any information. Requests can be sent to jo.wassell@invokerecruitment.
“Your right to rectification / correction”
Candidates can self-manage their profiles via the Invoke Recruitment website. Invoke Recruitment receives notifications about all updates to ensure all changes have been noted. All other requests for data updates can be emailed to email@example.com to be actioned with no delay. Third parties (such as umbrella companies) are informed about any data corrections.
“Your right to erasure”
Candidates can self-manage their profiles via the Invoke Recruitment website, this includes the option to delete an account. Invoke Recruitment receives notifications about all updates to ensure all changes have been noted. All other requests for erasure can be emailed to firstname.lastname@example.org to be actioned with no delay if there is no compelling reason to process it. In some cases the “The right to restrict processing” is used as an alternative based on legitimate business interest as well as the individual’s interest, to be able to suppress any further approaches. A note that “erased” as requested is added, so the individual is not approached repeatedly as “new contact”. Only minimum data required is held onto in this case and we may pseudonymise parts of the data.
“Your right to data portability”
Invoke Recruitment can extract data from the database in a machine readable format, free of charge, without delay and at the latest within one month of receipt. We will always verify the identity of anyone making a subject access request before handing over any information.
“Your right to object”
Individuals can block or suppress the processing of their data. Preferences can be self-managed via candidate profiles. All other ‘objections’ can be emailed to email@example.com.
“Your rights in relation to automated decision making and profiling”
We don’t use any automated decision making and profiling.
For those signing up to Invoke Recruitment newsletters by email submission only, Invoke Recruitment only stores the data set submitted for the purpose of sending news to the individual as requested. All of the above rights can be exercised by emailing firstname.lastname@example.org. Consent can be withdrawn at any time via this email address also.
Newsletters are sent via a software, importing an up to date data set each time, including currently opted in candidates only. The software notes everyone that has previously unsubscribed and each newsletter includes the option to unsubscribe.
Invoke Recruitment job alerts are an opt-in, sign up to them requires the affirmative action of ticking a tick box. Invoke Recruitment only stores the data set submitted for the purpose of sending job alerts to individuals as requested and specifically tailored to their preferences. Preferences as well as this profile are self-managed via a created login. All of the above rights can be exercised via their login or by emailing email@example.com. Consent can be withdrawn at any time via this email address also. The system notes unsubscribes and an easy unsubscribe option is included in all alerts.
Changes to our privacy notice
Any changes we make to our privacy notice in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our privacy notice.
What we do if there was a Data breach?
We have established a “Breach Management Process”. As part of the data breach response plan, Invoke Recruitment reports breaches that are likely to have a significant detrimental effect on individuals to the ICO without delay and within 72 hours, and affected individuals are notified if the breach is high risk. This happening is very unlikely.
The internet and use of e-mail are not secure and by using these methods to communicate with us you accept that there are risks associated with sending information via this method.
Questions, comments and requests regarding this privacy notice are welcomed and should be addressed to Jo Wassell, Managing Director, Invoke Recruitment, 11 Bedford Street, Woburn, Bedfordshire, MK17 9QB.