Data Protection / Privacy Policy

Originally adopted: October 2020

Sirius Search Limited is a recruitment business which provides work-finding services to its clients and work-seekers. Sirius Search Limited must process personal data (including sensitive personal data) so that it can provide these services – in doing so, Sirius Search Limited acts as a data controller.

You may give your personal details to Sirius Search Limited directly, such as on an application or registration form or via our website, or we may collect them from another source such as a jobs board. Sirius Search Limited must have a legal basis for processing your personal data. For the purposes of providing you with work-finding services and/or information relating to roles relevant to you, we will only use your personal data in accordance with this privacy statement. At all times we will comply with current data protection laws and Employment Agency Standards.

1. Collection and use of personal data

a. Purpose of processing and legal basis

Sirius Search Limited will collect your personal data (which may include sensitive personal data) and will process your personal data for the purposes of providing you with work-finding services. This includes, for example, contacting you about job opportunities, assessing your suitability for those opportunities, updating our databases, putting you forward for job opportunities, arranging payments to you, and developing and managing our services and relationships with you and our clients.

In some cases, we may be required to use your data for the purpose of investigating, reporting, and detecting crime, and to comply with laws that apply to us. We may also use your information during the course of internal audits to demonstrate our compliance with certain industry standards.

We must have a legal basis to process your personal data. The legal bases we rely upon to offer our work-finding services to you are:

• Your consent
• Where we have a legitimate interest
• To comply with a legal obligation that we have
• To fulfil a contractual obligation that we have with you

b. Legitimate interest

This is where Sirius Search Limited has a legitimate reason to process your data, provided it is reasonable and does not go against what you would reasonably expect from us. Our legitimate interests include:

• Providing work-finding services to individuals, including sending your information to our clients where you have expressed an interest in that particular type of work but have not expressly consented to your CV being passed on;
• Managing our database and keeping work-seeker records up to date;
• Contacting individuals to seek your consent to hold and process your data.

c. Statutory/contractual requirement

Recruitment businesses must collect certain personal data to meet statutory obligations, such as the Conduct of Employment Agencies and Employment Businesses Regulations 2003 – for example identity, right to work, suitability for the role, qualifications, and experience. You will be obligated to provide this information as a minimum should you want Sirius Search Limited to assist your job search.

d. Recipient/s of data

Sirius Search Limited will process your personal data with the following recipients:

• Client contacts at companies whom we feel may be interested in seeing your details;
• Former or prospective employers for providing references;
• Payroll service providers who manage payroll on our behalf or other payment intermediaries whom we may introduce you to;
• Our IT and CRM providers;
• Government, law enforcement agencies, regulators, and the Employment Agency Standards Inspectorate, if required.

Note: We will not sell or rent your personal data to third parties. We will only share your data with clients or third parties for recruitment purposes, and only with your prior consent where required.

2. Overseas Transfers

Sirius Search Limited will not transfer the information you provide to us to countries outside the European Economic Area (‘EEA’) for the purposes of providing you with work-finding services. The EEA comprises the EU member states plus Norway, Iceland, and Liechtenstein.

3. Data retention

Sirius Search Limited will retain your personal data only for as long as is necessary for the purpose we collect it. Different laws may also require us to keep different data for different periods of time.

The Conduct of Employment Agencies and Employment Businesses Regulations 2003 require us to keep work-seeker records for at least one year from (a) the date of their creation or (b) after the date on which we last provide you with work-finding services.

We must also keep your payroll records, holiday pay, sick pay, and pensions auto-enrolment records for as long as legally required by HMRC and associated national minimum wage, social security, and tax legislation (currently 3 to 6 years).

Where Sirius Search Limited has obtained your consent to process your personal and sensitive personal data, we will hold/process your data for a period of 5 years. Upon expiry of that period, we will seek further consent from you. Where consent is not granted, Sirius Search Limited will cease to process your personal data.

4. Your rights

You have the following data protection rights:

• The right to be informed about the personal data Sirius Search Limited processes on you;
• The right of access to the personal data Sirius Search Limited processes on you;
• The right to rectification of your personal data;
• The right to erasure of your personal data in certain circumstances;
• The right to restrict processing of your personal data;
• The right to data portability in certain circumstances;
• The right to object to the processing of your personal data that was based on a public or legitimate interest;
• The right not to be subjected to automated decision making and profiling;
• The right to withdraw consent at any time.

Where you have consented to Sirius Search Limited processing your personal and sensitive personal data, you can withdraw that consent at any time by contacting Cressida Courtney at cressida@sirius-search.co.uk.

There may be circumstances where Sirius Search Limited will still need to process your data for legal or official reasons. We will inform you if this is the case and restrict the data to only what is necessary.

If you believe that any of your data that Sirius Search Limited processes is incorrect or incomplete, please contact us using the details above and we will take reasonable steps to check its accuracy and correct it where necessary.

You can also contact us using the above details if you want us to restrict the type or amount of data we process for you, access your personal data, or exercise any of the other rights listed above.

5. Cookies

We may obtain data about you from cookies. These are small text files that are placed on your computer by websites you visit. Cookies enable us to deliver more personalised content and analyse website usage.

Most web browsers allow some control of cookies through the browser settings. Please note that in a few cases some of our website features may not function if you remove cookies from your browser.

6. Log Files

We use IP addresses to analyse trends, administer the site, track users’ movements, and gather broad demographic information. IP addresses are not linked to personally identifiable information.

7. Links to external websites

Our website may contain links to other external websites. We are not responsible for the privacy practices of such other sites. When leaving our site, we encourage you to read the privacy statements of each website that collects personally identifiable information.

8. Sale of business

If the Company’s business is sold or integrated with another business, your details may be disclosed to our advisers and prospective purchasers and passed on to the new owners.

9. Data Security

Sirius Search Limited takes every precaution to protect our users’ information. Only employees who need the information to perform a specific job (for example, consultants, accounts clerks, or marketing assistants) are granted access to your information.

Personal data is stored within our secure, encrypted CRM system hosted on UK or EEA servers. We use all reasonable efforts to safeguard your personal information.

However, email/Internet is not entirely secure and we cannot guarantee the security of information transferred via these channels. If you share a device with others, do not select the “remember my details” option.

For security questions, email info@sirius-search.co.uk.

10. Changes to this privacy statement

We will update this privacy statement from time to time and post any changes with revision dates. If we make material changes, we will notify you.

11. Complaints or queries

If you wish to complain about this privacy notice or any procedures set out in it, please contact info@sirius-search.co.uk.

You also have the right to raise concerns with the Information Commissioner’s Office (ICO) at 0303 123 1113 or https://ico.org.uk/concerns/, and/or the Employment Agency Standards Inspectorate if your concern relates to agency compliance.