1. WHAT IS THIS?

At Seven Search & Selection Limited (referred to as “we”, “us”, “our”) we take privacy seriously and we are committed to protecting it.
This policy explains when and why we collect personal information about individuals, how this information is used, the conditions under which it may be disclosed to others and how it is kept secure.
This policy may change from time to time so please check this page occasionally to ensure that you’re happy with any changes.
This policy was last updated on 24th May 2018.

2. WHO WE ARE

Seven Search & Selection Limited (company registration number 06966795) is the data controller in relation to the processing activities described below. This means that we decide why and how your personal information is processed.

3. HOW WE COLLECT YOUR PERSONAL INFORMATION

When you use this website and our services, the categories of information that we may collect about you are as follows:
Personal data:

• Name;
• Age;
• Contact information, including phone number, email and home address;
• Education and employment history; and
• Salary information.

Sensitive personal data:

• Health (to assess and/or to comply with our obligations under the Equality Act 2010).
• Diversity information (for equal opportunity monitoring purposes; and
• Criminal convictions (where permitted by law).

Personal information you give to us:

This is information about you that you freely volunteer to give to us by: (i) entering information via the Company’s website, or (ii) sending a CV to the Company based on a historical working relationship.

This is information about you that you give to us by entering information via:

• our site www.workwithseven.com
• social media platforms;
• corresponding with us by phone, email or otherwise,

and is provided entirely voluntarily.

Personal information we collect about you:

This is information about you that you give to us by phone, email or via our website. It includes information that you give us by corresponding with us by phone, e-mail or otherwise and filling in forms sent to you by e-mail or Docusign or handed to you in person. It includes information you provide when you register to use our site, subscribe to our services, participate in discussion boards or other social media functions on our site.
The information we collect including your name, home address, telephone number and private and corporate email address (where applicable), financial information, compliance documentation and references verifying your qualifications and experience and your right to work in the United Kingdom, and your curriculum vitae.

Information we collect about you when you visit our website.

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

Personal information we may receive from other sources.

The Company may obtain personal information about you from publicly accessible sources outside of our business which may include a third party job board, a professional networking site such as LinkedIn, or it could be you have applied to an advertisement through one of these channels too. The personal information we receive from third party sources is personal data, such as you name, contact information, education and employment history. Where we receive such information from these third parties, we will only use it in accordance with this notice.

• The following third parties may send the Company personal information about you:

Source of data	Categories of data	Privacy policy
Reed.co.uk	Personal data	https://www.reed.co.uk/policies#privacyPolicy
Monster.co.uk	Personal data	http://inside.monster.co.uk/fullpolicy/inside2.aspx
Linkedin.com	Personal data	https://www.linkedin.com/legal/privacy-policy
Grocer Jobs	Personal data	https://www.william-reed.com/William-Reed-Privacy-Cookies-Policy
RecruitNI	Personal data	https://www.recruitni.com/legal.php#privacy-policy
Food Man Jobs	Personal data	https://www.william-reed.com/William-Reed-Privacy-Cookies-Policy
Retail Choice	Personal data	http://recruiters.retailchoice.com/page/privacy
Only Marketing Jobs	Personal data	https://recruiter.onlymarketingjobs.com/privacy-policy/
Jobsite	Personal data	https://www.jobsite.co.uk/privacy
CV Library	Personal data	https://www.cv-library.co.uk/privacy

4. HOW WE USE YOUR PERSONAL INFORMATION

The purposes for which we use your information and the legal basis under data protection laws on which we rely to do this are explained below.

Where there is a LEGITIMATE INTEREST

We may use and process your personal information where it is necessary for us to pursue our legitimate interests as a business, or that of a third party, for the following purposes:

• For prospective candidates, interim managers, referees and clients, our processing is necessary for our legitimate interests in that we need the information in order to be able to assess suitability for potential roles, to find potential candidates and to contact clients and referees.
• 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.
• If you are shortlisted as a candidate, then this may involve the processing of more detailed personal data including sensitive data such as health information that you or others provide about you. In that case we always ask for your consent before undertaking such processing.
• For clients, we may also rely on our processing being necessary to perform a contract for you, for example in contacting you

Where you have provided CONSENT
We may use and process your personal information where you have consented for us to do so for the following purposes:

• From time to time, we may contact you via email, text, telephone with marketing information about our other services, or those services/products of the other entities within our group or with details of reports, promotions, offers, networking and client events and general information about the industry sectors which we think might be of interest to you, or if you are applying for a particular job which requires us to process your sensitive personal information. You may withdraw your consent for us to use your information in any of these ways at any time. Please see “Withdrawing your consent” for further details

You may withdraw your consent for us to use your information in any of these ways at any time. Please see Withdraw your consent for further details.

5. DATA ANONYMISATION AND USE OF AGGREGATED INFORMATION

Your information may be converted into statistical or aggregated data in such a way as to ensure that you are not identified or identifiable from it. Aggregated data cannot be linked back to you as a natural person. We may use this data for analytical and research purposes.
For more information on how we use cookies and how to switch them off on your device, please see our section of Cookies below.

6. OTHERS WHO MAY RECEIVE OR HAVE ACCESS TO YOUR PERSONAL INFORMATION

• Prospective employers in order to apply for jobs or to assess your eligibility for jobs;
• Third parties where we have retained them to provide services that we, you or our client have requested;
• Third parties, regulatory or law enforcement agencies; and
• Third parties service providers, agents, subcontractors and other organisations who perform functions on our behalf.

Other ways we may share your personal information

We may transfer your personal information to a third party as part of a sale of some or all of our business and assets to any third party or as part of any business restructuring or reorganisation. We may also transfer your personal information if we’re under a duty to disclose or share it in order to comply with any legal obligation, to detect or report a crime, to enforce or apply the terms of our contracts or to protect the rights, property or safety of our visitors and customers. We will always take steps with the aim of ensuring that your privacy rights continue to be protected.

7. WHERE WE STORE YOUR PERSONAL INFORMATION

All information you provide to us is stored on our secure servers which are located within the European Economic Area (EEA).
If at any time we transfer your personal information to, or store it in, countries located outside of the EEA (for example, if our hosting services provider changes) we will ensure that appropriate safeguards are in place for that transfer and storage as required by applicable law. This is because some countries outside of the EEA do not have adequate data protection laws equivalent to those in the EEA

8. HOW LONG WE KEEP YOUR PERSONAL INFORMATION FOR

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 a data retention policy and disposal policy, where we routinely remove data that we no longer have a legitimate business interest in maintaining.

We keep your information in accordance as follows:

• Candidate data: up to a maximum of 8 years from last contact
• Interim Manager data: up to a maximum of 8 years from last contact
• Client contact details: up to a maximum of 5 years from last contact

9. SECURITY AND LINKS TO OTHER SITES

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 your information transmitted to our website and any transmission is at your own risk. Once we have received your personal information, we put in place reasonable and appropriate controls to ensure that it remains secure against accidental or unlawful destruction, loss, alteration, or unauthorised access.

Our website may contain links to other websites run by other organisations. This policy does not apply to those other websites‚ so we encourage you to read their privacy statements. We cannot be responsible for the privacy policies and practices of other websites even if you access them using links that we provide. In addition, if you linked to our website from a third party website, we cannot be responsible for the privacy policies and practices of the owners and operators of that third party website and recommend that you check the policy of that third party website.

10. COOKIES

A cookie is a small data file, which is sent from a web server to a web browser when the browser visits the server’s site. We use cookies for login purposes. If you wish to reject our cookie, you may configure your browser to do so. For further information please refer to your Internet browser software instructions or help screen. To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit www.aboutcookies.org or www.allaboutcookies.org.

11. OUR MARKETING

We may periodically send you information that we think you may find interesting, or to ask for your help with connecting other Candidates with jobs. In particular, we may wish to use your data for the purposes listed below, where appropriate and in accordance with any local laws and requirements. Please note that this list is not exhaustive. To:

• enable us to develop and market other products and services;
• market our full range of recruitment services to you;
• send you details of reports, networking and Client events, and general information about the industry sectors which we think might be of interest to you;
• display promotional excerpts from your details on our websites as a success story (only where we have obtained your express consent to do so).

From time to time, we may ask you to refresh your marketing preferences by asking you to confirm that you consent to continue receiving marketing information from us.

12. YOUR RIGHTS

You have a number of rights in relation to your personal information under data protection law. In relation to certain rights, we may ask you for information to confirm your identity and, where applicable, to help us to search for your personal information. Except in rare cases, we will respond to you within one month from either (i) the date that we have confirmed your identity or (ii) where we do not need to do this because we already have this information, from the date we received your request.

• The right to be informed. You have the right to be provided with clear, transparent and easily understandable information about how we use your information and your rights. This is why we’re providing you with the information in this Policy.
• The right of access. You have the right to obtain access to your information (if we’re processing it), and certain other information (similar to that provided in this Privacy Policy). This is so you’re aware and can check that we’re using your information in accordance with data protection law.
• The right to rectification. You are entitled to have your information corrected if it’s inaccurate or incomplete.
• The right to erasure. This is also known as ‘the right to be forgotten’ and, in simple terms, enables you to request the deletion or removal of your information where there’s no compelling reason for us to keep using it. This is not a general right to erasure; there are exceptions.
• The right to restrict processing. You have rights to ‘block’ or suppress further use of your information. When processing is restricted, we can still store your information, but may not use it further. We keep lists of people who have asked for further use of their information to be ‘blocked’ to make sure the restriction is respected in future
• The right to data portability. You have rights to obtain and reuse your personal data for your own purposes across different services. For example, if you decide to switch to a new provider, this enables you to move, copy or transfer your information easily between our IT systems and theirs safely and securely, without affecting its usability.
• The right to object to processing. You have the right to object to certain types of processing, including processing for direct marketing (ie if you no longer want to be contacted with potential opportunities).
• The right to withdraw your consent. Where we rely on your consent as the legal basis for processing your personal information, as set out under How we use your personal information, you may withdraw your consent at any time by contacting us using the details at the end of this policy. If you would like to withdraw your consent to receiving any direct marketing to which you previously opted-in, you can do so using our unsubscribe tool. If you withdraw your consent, our use of your personal information before you withdraw is still lawful.
• The right to lodge a complaint. You have the right to lodge a complaint about the way we handle or process your personal data with your UK data protection regulator. You have the right to complain to the Information Commissioner’s Office (ICO) if you are concerned about the way we have processed your personal information. Please visit the ICO’s website for further details.

13. CHANGES TO THIS POLICY

We may review this policy from time to time and any changes will be notified to you by posting an updated version on our website and/or by contacting you by email. Any changes will take effect 7 days after the date of our email or the date on which we post the modified terms on our website, whichever is the earlier. We recommend you regularly check for changes and review this policy whenever you visit our website. If you do not agree with any aspect of the updated policy you must immediately notify us and cease using our services.

14. CONTACT US

If you have any concerns, queries or requests as to your data or how we may use it or feel that the company is not abiding by its privacy policy please don’t hesitate to get in contact. Our Data Protection Lead, Stewart Wilson and Data Protection Representative, Caroline Thorp can be contacted as follows::
If you wish to write to us, please write to the address given at the start of this policy.
Our email address for data protection queries is privacyinfo@workwithseven.com
If you would prefer to speak to us by phone, please call 0845 437 9770.