Privacy Policy & Terms & Conditions

Company Name:	Park Street People Ltd
Policy Name:	Privacy & Cookie Policy - Candidate & Client
Date:	5th May 2018
Version:	V007PSP

Park Street People Ltd is committed to protecting and respecting your privacy. We have created this policy to inform you and make sure we are transparent about our processes.

If you are a resident of the European Union, looking for a job (perm, FTC or temporary) and using Park Street People’s services as an Employment Agency / Business, this policy applies to you and we would like to share with you the details of how we process your data.

When you use Park Street People’s services, you trust us with your information and we want you to understand what data we collect, why we collect it and what we do with it. This is important, and we hope you will take time to read it carefully. Your new rights under GDPR will only apply once the GDPR comes into effect on 25 May 2018.

General Data Protection Regulation

In accordance with the General Data Protection Regulation (EU) 2016/679 (‘GDPR’) that comes into effect on 25 May 2018, Park Street People is obliged to issue a Data Processing Notice if we store your personal data in our database.

The GDPR is a new regulation which replaces the Data Protection Directive 95/46. The GDPR aims to harmonise data protection legislation across EU member states, enhancing privacy rights for individuals and providing a strict framework within which commercial organizations can legally operate.

This privacy & cookie policy will outline:

Park Street People as a data controller
What personal data does Park Street People collect
How Park Street People collects personal data
Legal basis for holding your personal data
Optional Marketing communication
Cross-border transfers
How long will we store your data?
What are your rights under GDPR
Automated decision making, including profiling
Lodging a complaint
Changes to this Data Processing Notice
Contact details for GDPR and data queries
Cookies
Client data processing

1. Park Street People as a data controller

Park Street People is registered as a data controller (ICO registration no. Z9591187) in the United Kingdom for the purposes of managing your personal data. We ensure that the data you supply to us is processed fairly and lawfully, and with skill and care and used only for the purposes set out in this policy.

Park Street People Ltd is headquartered in Windsor, UK but also has staff based in France. To ensure we are able to work optimally across multiple locations, all our teams are connected via the same internal CRM system and software. Our current CRM software provider is Altido Ltd (www.altido.com)

All Park Street People employees, are thus obliged to comply with GDPR when processing your personal data, provided you reside in the European Union.

How may we use this data?

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

Your personal data will be stored, processed, used and disclosed by us in the following ways:

To provide our recruitment services to you and to manage the recruitment process
To send your information to clients in order to apply for jobs or to assess your eligibility for jobs
To assess data about you against vacancies which we judge may be suitable for you
To enable you to submit your CV, apply online for jobs or to subscribe to alerts about jobs we think may be of interest to you
To enable us to market other products and services (where you have consented to being contacted for such purposes)
To send you 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 (where you have consented to being contacted for such purposes)
To answer your questions and enquiries
To third parties where we have retained them to provide services that we, you or our client have requested including references, qualifications and criminal reference checking services, verification of the details you have provided from third party source, psychometric evaluation or skill test (where you have consented to being contacted for such purposes)
To third parties, regulatory or law enforcement agencies if we believe in good faith that we are required by law to disclose it in connection with the detection of crime, the collection of taxes or duties, in order to comply with any applicable law or order of a court of competent jurisdiction, or in connection with legal proceedings
To use your information on an anonymised basis to monitor compliance with our equal opportunities policy
To carry out our obligations arising from any contracts entered into between you and us (including the payment of wages)

2. What personal data does Park Street People collect

Park Street People only collects personal data to help us match you with the right career opportunity.

Park Street People would typically collect the following personal data:

Your full name
Your registered address
Your date of birth
Your email addresses
Your (mobile) telephone number
Your website (if applicable)
Professional profiles available in the public domain, e.g. LinkedIn, Twitter or Facebook
Your CV
Skillset (if not already covered in a CV)
Job preferences (if not already covered in a CV)
Current employer/client
Your passport/visa (when required to assess your right to work in a certain country)
Current salary/employment conditions
Desired salary/ employment conditions
Other documentation, if requested by our clients (e.g. references)

Please be aware this is not an exhaustive list and additional information may be obtained to ensure we can represent you to the highest professional standards. Where necessary, sensitive personal data may be collected and held, with your consent.

3. How Park Street People collects personal data

Park Street People collects your personal data in the following ways:

You apply for a job in response to a job ad on www.parkstreetpeople.com
You upload your CV on www.parkstreetpeople.com
You complete a ‘Contact us’ form on www.parkstreetpeople.com
A Park Street People Recruitment Consultant gets in contact with you because they found your profile on a database / job board / social media platform you have subscribed to or registered your CV with and Park Street People uses these platforms to access details of candidates
We have received your details about you from another third party, for instance; a business contact, a client or professional advisors
You applied for a job ad by Park Street People published on an external job board, e.g. Reed, Jobsite, LinkedIn, etc.
You have previously met or spoken with a Park Street People Recruitment Consultant and have shared personal information or sent your CV/application by email to Park Street People

When Park Street People receives your details in one of the above ways, we save your application and information provided by you on our CRM system. Your information and application will be reviewed by our consultants who will potentially share that information with our clients to advance your application, provided you have given your express consent to this upfront.

When we receive these details, our Consultant’s will inform you as soon as possible of collecting the data of the source where your personal data originates from. If this information is not provided, please let us know straight away and we will confirm how we located your data.

4. Legal basis for holding your personal data

The following legal bases apply for processing your data if we have had contact with you inside the last 24 months (or up to 6 years for legal reasons). The legal bases Park Street People rely upon to offer these services to you are:

Your consent
- Where a Recruitment Consultant has fully interviewed and registered you to assist your career search, Park Street People will request for both your verbal and written consent to hold your personal data (and any necessary sensitive personal data)
Where we have a legitimate interest
- Where we have yet to engage with you, Park Street People processes your data as we believe we have a legitimate interest in holding this data to assist you with work finding services
To comply with a legal obligation that we have
- Where Park Street People successfully place someone in either a temporary or permanent role, we have a legal obligation to keep your data on file for six years. This legal requirement is in place so that Park Street People is able to evidence any transactions with our clients for tax purposes and to be able to produce proof of the placement should any legal claims arise against Park Street People by any parties involved during the recruitment and/or hiring process.
To fulfil a contractual obligation that we have with you

5. Optional Marketing communication

Park Street People will hold your personal data for marketing purposes which are optional. The legal basis for collecting and processing personal data for marketing purposes is ‘consent’ which means Park Street People will only send you marketing communication if you have opted into receiving this.

If you opted into receiving updates from Park Street People, we will use your data, preferences, user behaviour and information you have provided to personalize your experience, provide you with relevant service announcements and updates, and to better understand your needs and interests in relation to your job search.

Park Street People uses the personal data and information you have provided with your CV or portfolio to match your profile with relevant job opportunities. Our marketing team analyses your profile to provide you with additional information which helps you to better position yourself in the job market, i.e. with invitations to networking events in your city, news and updates relevant for your area of expertise, or job alerts tailored to your preferences, if you have opted in to receiving marketing communication.

You are entitled to withdraw consent or restrict the use of your personal information for whatever purpose at any time, without affecting the lawfulness of processing based on consent before its withdrawal. To opt out of any data processing and/ or marketing communications from Park Street People. please click the ‘unsubscribe’ link in the footer of the respective email or if you registered on the Park Street People website, please use the self-service platform to update your personal settings.

6. Cross-border transfers

In order to provide you with the best service and to carry out the purposes described in this Privacy Policy, your data may be transferred with your consent:

Within Park Street People Ltd (via the Altido CRM);
To third parties (such as advisers or other suppliers to the Park Street People business);
To overseas Clients (outside of the EEA);
To Clients within your country who may, in turn, transfer your data internationally;
To a cloud-based storage provider.

Park Street People want to make sure that your data is stored and transferred in a way which is secure. We will therefore only transfer data outside of the European Economic Area or EEA (i.e. the Member States of the European Union, together with Norway, Iceland and Liechtenstein) where it is compliant with data protection legislation and the means of transfer provides adequate safeguards in relation to your data, for example:

By way of data transfer agreement, incorporating the current standard contractual clauses adopted by the European Commission for the transfer of personal data by data controllers in the EEA to data controllers and processors in jurisdictions without adequate data protection laws; or
By signing up to the EU-U.S. Privacy Shield Framework for the transfer of personal data from entities in the EU to entities in the United States of America or any equivalent agreement in respect of other jurisdictions; or
Transferring your data to a country where there has been a finding of adequacy by the European Commission in respect of that country's levels of data protection via its legislation; or
Where it is necessary for the conclusion or performance of a contract between ourselves and a third party and the transfer are in your interests for the purposes of that contract (for example, if we need to transfer data outside the EEA in order to meet our obligations under that contract if you are a candidate of ours); or
Where you have consented to the data transfer.

If you have any further queries about data transfer outside the EEA, please contact james@parkstreetpeople.com

7. How long will we store your data?

Park Street People will retain your personal data only for as long as is necessary for the purpose we collect it. Different legal bases require us to keep different data for different periods of time:

Your consent
- Verbal consent = 18 months
- Written consent (including via email or online processes) = 24 months
Legitimate interest
- Before obtaining consent = 3 months
Legal reasons = 6 years
Contractual reasons = up to 12 months’ after the successful conclusion of any contractual obligations (unless legal reasons require the data to be held for longer)

8. What are your rights under GDPR

Under GDPR you are entitled to various rights:

The right to rectification of your personal data;
- This enables you to have any incomplete or inaccurate information we hold about you corrected. This means when working with our Recruitment consultants, make sure you notify us of any changes or update your information like email, phone number etc. when they change.
The right to erasure of your personal data in certain circumstances;
- 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). This means should you wish to be removed from Park Street People’s database, please email james@parkstreetpeople.com or if you registered on the Park Street People website, please use the self-service platform to request the right to be forgotten. We will review and process your request within 30 days.
The right to restrict processing of your personal data;
- 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.
The right to data portability in certain circumstances;
- This enables you to ask us to transfer your personal informational to another party in certain formats (where practical to achieve). If you registered on the Park Street People website, please use the self-service platform to submit a request for data portability.
The right to object to the processing of your personal data that was based on a public or legitimate interest;
- You can object to the 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. This means we will only send you marketing communication if you have opted in. You can opt out at any time by clicking the ‘unsubscribe’ link in the footer of the email in question and will be removed from the Park Street People marketing mailing list.
The right to withdraw consent at any time;

All such requests need to be addressed to james@parkstreetpeople.com or if you registered on the Park Street People website, please use the self-service platform to submit requests as stated above. The fact that you can lodge a request does not necessarily mean we will grant your request, at all times, especially if Park Street People has a legitimate interest that outweighs your interests as an individual.

Park Street People will, however, provide information without undue delay and in any event within one month (this can be extended to 2 months in exceptional circumstances) of the receipt of the request, however where requests are manifestly unfounded or excessive, in particular, because of its repetitive character, Salt may refuse to act upon your request. In that case, we will inform you within one month of the request of the possibility of lodging a complaint with a supervisory authority (in the UK this will be the ICO) or seeking a judicial remedy.

9. Automated decision making, including profiling

Park Street People will not conduct any forms of automated processing of your personal data consisting of the use of personal data to evaluate certain personal aspects relating to you, in particular, to analyse or predict aspects concerning your personal preferences, job roles interests, reliability, behaviour, location or movements. We will not make decisions that are based solely on automated processing which produces legal effects, or similarly significantly affects you as a data subject.

10. Lodging a complaint

If you feel that your rights as a data subject have been breached, you are entitled to lodge a complaint with the national supervisory authority (in the UK this will be the Information Commissioner’s Office via https://ico.org.uk/concerns/) or seek a legal remedy. However, we strongly encourage you to initially contact us via james@parkstreetpeople.com.

11. Changes to this Data Processing Notice

Any changes we make to our Data Processing Notice in the future will be posted on this website and where appropriate (if we make any significant changes that may affect your rights as a data subject), notified to you by email. Please check back frequently to see any updates or changes to this Data Processing Notice.

12. Contact details for GDPR and data queries

If you have any questions, comments, and requests regarding your personal data or this policy, please address them to:

James Bessant

Managing Director

Kings Road House, 2 Kings Road
Windsor, Berkshire
SL4 2AG

james@parkstreetpeople.com
Phone +44 (0)1753 830706

13. Cookies

What are cookies?

Cookies are small pieces of information, stored by your web browser on your computer. They enable things like keeping you logged in as you move around a website, or carrying address and delivery details from page to page as you make an online purchase.

They're very commonly used, right across the web. In fact, without them websites would struggle to deliver the kind of experience that we've all come to expect when online.

Park Street People uses information from cookies for purposes which may include:

Identifying returning users, registrants and subcribers
Eliminating the need for returning users to re-enter their login details
Enabling you to move more easily around our sites and applications
Tracking your use of our sites to better develop our sites and applications in accordance with your requirements
Building up an anonymous profile based on your browsing patterns across our sites, applications and third party websites, which enables us to make advertisements and content available to you that is more relevant to your interests
Google Analytics uses cookies to help the website analyse how users use the site. The information generated by the cookie about your use of the website (including your IP address) will be transmitted to and stored by Google on servers in the United States. Google will use this information for the purpose of evaluating your use of the website, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google's behalf. Google will not associate your IP address with any other data held by Google. Google uses the __utma cookie. This is a persistent cookie that expires in two years. With each new visit, the expiration date is refreshed. By using this website, you consent to the processing of data about you by Google in the manner and for the purposes set out above.

What’s all the fuss about?

The EU is worried that some people may be misusing them and has created a directive that aims to prevent that.

The UK is one of the first EU member states to implement the directive as law although there still exists a lot of confusion about what's actually required of website owners.

We don't believe that cookies are bad - they're useful. Of course they can be used for incorrect purposes by unscrupulous websites but the same is true of many things available on the high street.

We want to play it safe and make sure our users are fully informed.

What cookies do we use?

We automatically set the cookies listed below, so if you're using our site you accept that we're doing so. We use two types of cookies:

Session cookies which only exist while you're on the site. When you close the window and leave the site, your browser will delete them. These are used for things like logging you in to the site.
Persistent cookies which are stored by your computer for your next visit to the site. These are used to maintain useful information such as what you added to your job cart
volcanic_saved_jobs_id - this is used to store some jobs for users before they register on the website. These jobs can then be logged on the users account when they do register
volcanic_rumble_uid - this cookie name is associated with Volcanic's CMS platform tracking. It is used to track and record the unique actions of each user on the website. By default, it has no expiry date. The main purpose of this cookie is performance
_user_logged_in - this cookie name is associated with Volcanic's CMS platform tracking. It is used to keep the user logged in if they leave the website and return. By default, it expires after the user's session ends. The main purpose of this cookie is performance
_oliver_session - this cookie name is associated with Volcanic's CMS platform tracking. It is used to track the user's session on the website for Analytics. By default, it expires after the user's session ends. The main purpose of this cookie is performance
__utma, __utmb, __utmc, __utmz - we use Google Analytics (lots of websites do) to see how well our site is doing. These cookies are set by Google Analytics and allow us to view some anonymous information about the number of visits we get, the most popular pages and so on. They don't provide us with any personally identifiable information. __utmc is destroyed when you leave the site and close your browser but the others will hang around and may be there next time you visit.

Above all, we will never knowingly share any of your personal details with unscrupulous third parties. We don't use cookies to store personal or sensitive information. We don't use them to follow you around the web or send you spam emails. Be reassured, we take this stuff seriously!

But I don’t want to accept cookies…

We hope that you're reassured by this explanation of what cookies we use and why we do so. If you do wish to block cookies from any sites, you can do so by changing your browser settings. Below are links to the appropriate pages for the most popular browsers.

Internet Explorer 7 and 8
http://windows.microsoft.com/en-us/windows-vista/block-or-allow-cookies

Internet Explorer 9
http://windows.microsoft.com/en-GB/windows7/How-to-manage-cookies-in-Internet-Explorer-9

Firefox
http://support.mozilla.org/en-US/kb/Blocking%20cookies

Chrome
https://support.google.com/chrome/bin/answer.py?hl=en&answer=95647&p=cpn_cookies

Safari
http://docs.info.apple.com/article.html?path=Safari/5.0/en/ibr1074.html

More about cookies

A quick search for "EU cookie directive" will return a huge number of results. Below are a few sites we've found useful in our research. We're not experts and we're certainly not lawyers but we care about this stuff. After all, we use the internet too.

The Cookie Collective website is packed with useful information:
http://www.cookielaw.org/

All About Cookies
http://www.allaboutcookies.org/

Wikipedia article on cookies:
http://en.wikipedia.org/wiki/HTTP_cookie

14. Client data processing

What kind of personal data would we collect?

If you are a Park Street People client, we need to collect and use information about you, or individuals at your organisation, in the course of providing you services such as: (i) finding candidates who are the right fit for you or your organisation; (ii) notifying you of content published by Park Street People which is likely to be relevant and useful to you (for example annual salary surveys); (iii) developing relationships with you as a future prospective client

The personal data we would collect would include:

Your name
Your work email address
Your work telephone number / mobile number
Social media URL (LinkedIn)
Your job title

How do we collect your personal data?

We collect Client personal data in three ways:

1. Personal data that we receive directly from you;

2. Personal data that we receive from other sources; and

3. Personal data that we collect automatically.

Personal data that we receive directly from you

We both share the same goal – to make sure that you have the best staff for your organisation. We will receive data directly from you in two ways:

- Where you contact us proactively, usually by phone or email; and/or

- Where we contact you, either by phone or email, or through our consultants' business development activities more generally.

Personal data we receive from other sources

Where appropriate and in accordance with any local laws and requirements, we may seek more information about you or your colleagues from other sources generally by way of due diligence or other market intelligence including:

- From third party market research and by analysing online and offline media (which we may do ourselves, or employ other organisations to do for us);

- From delegate lists at relevant events; and

- From other limited sources and third parties (for example from our Candidates to the extent that they provide us with your details to act as a referee for them).

Personal data we collect via our website

To the extent that you access our website or read or click on an email from us, where appropriate and in accordance with any local laws and requirements, we may also collect your data you provide to us.

How do we use your personal data?

We use Client information for:

- Recruitment activities

- Marketing activities and

- To help us establish, exercise or defend legal claims

Recruitment Activities

Obviously, our main area of work is recruitment, through: (i) providing you with Candidates; (ii) RPO services; and (iii) MSP programmes. We've listed below the various ways in which we use your data in order to facilitate this.

- Storing your details (and updating them when necessary) on our database, so that we can contact you in relation to recruitment activities;

- Keeping records of our conversations and meetings, so that we can provide effective services for you;

- Undertaking customer satisfaction surveys; and

- Processing your data for the purpose of targeting appropriate marketing campaigns.

We may use your personal data for these purposes if we deem this to be necessary for our legitimate interests. For a recruitment business to run profitably, it is essential that we have the ability to contact existing and prospective clients for the purposes stated above

You are entitled to request to be forgotten or restrict the use of your personal information for whatever purpose at any time, without affecting the lawfulness of processing based on legitimate interest before its withdrawal. To opt out of any data processing and/ or marketing communications from Park Street People. please click the ‘unsubscribe’ link in the footer of the respective email or contact us via james@parkstreetpeople.com

Marketing Activities

To help us to establish, exercise or defend legal claim

In more unusual circumstances, we may use your personal data to help us to establish, exercise or defend legal claims.

How do we safeguard your personal data?

We are committed to taking all reasonable and appropriate steps to protect the personal information that we hold from misuse, loss, or unauthorised access. We do this by having in place a range of appropriate technical and organisational measures. These include measures to deal with any suspected data breach.

If you suspect any misuse or loss of or unauthorised access to your personal information, please let us know immediately via james@parkstreetpeople.com or by calling us on +44 (0)1753 830706.