Effective from 1st March 2018
Platinum Recruitment Group is an Employment and Recruitment Agency which primarily exists to help candidates find new jobs and clients fill vacant job positions. In order to achieve this, we must collect and store data, use this to help us and employers decide on the suitability of a candidate and keep records of candidate’s job search history to fully represent them. We will also use candidate data for marketing purposes, to send newsletters and updates on jobs or content related to their career, where the user has opted in.
If you want to contact us to discuss how we use or manage your data please email us on email@example.com or write to us at
Data Protection Officer
Platinum Recruitment Group
Suite 2A, Portland Buildings
127-129 Portland Street
Candidate Representation & Consent Form
By ticking this box on the Consent Form you authorise us to hold data about you in a secure CRM system along with notes that will allow us to represent you accordingly. This means we know who you are with contact details, what your requirements are and hold information that we can send to your potential employers to help you find a new role. We will also update our records on you depending on the communications we have with you and how you interact with our services. This data will be held whilst you are deemed as employable, whether this is when you are actively seeking a role now or in the future.
What information is being collected?
Only information that will help the process of seeking employment or developing a career for a candidate will be held by Platinum Recruitment Group. The information we collect will be on candidates who give us consent to hold and use their data that will include factual data based on the profile of the candidate (e.g. name, address, email address, telephone number, experience, skillset, salary details etc) and also other information like what interviews they are put forward to, dates, how they performed at these interviews, jobs secured, jobs rejected, salary offered etc. We may also categorise you on our systems into job or experience based segments to help us locate you amongst our data.
As information regarding a candidate relates to their employment and therefore their career, data will be kept on file for the lifetime of the candidate’s employability. You have the right to ask for this to be removed, amended or updated at any time and we can supply you with the data that we hold on you upon request.
Who is collecting it?
The data is being collected by Platinum Recruitment Group and employees of it and stored only on secure and licenced company software or platforms. Data may be shared with employers who will use this to assess the candidate for interviews and suitability for their positions.
How is it collected?
The majority of our data comes from job applications for our advertised roles into the business or the submission of CV’s. This normally comes via email, whether direct from 3rd party websites or to our consultant’s email inboxes from our website. We also collect data from both publically available databases of candidates who have listed their CV for viewing by agencies and employers or from password protected databases which we subscribe to in order to access candidate data. In all instances, candidates will be required to give consent for their data to be held on our systems. Where consent has not been given and we are in receipt of data, this will not be used in any way and be deleted from all platforms that they have been received onto, within 30 days.
Data is collected from a range of sources and uploaded onto our licenced company software or platforms. These sources may include CVs submitted to the business directly either digitally or off-line, CV’s submitted indirectly through referrals, CV data from online job board sites, collected verbally over the phone or face to face, via text messages or online messaging.
We will also store data about individuals from clients and candidates who provide feedback on CVs and meetings by communicating verbally, in written form offline or online through emails, post, online messaging or telephone text messaging.
Why is it being collected?
We collect data and information on candidates that will assist us and potential employers to make a decision whether they may be suitable for an employer’s role.
How will it be used?
It will be used to profile the candidates that we have consent for to introduce to an existing or speculative employer and used to help generate interviews for these candidates. It will be used for communication purposes so that employees of Platinum Recruitment Group can communicate with and provide updates to candidates. This information may also be passed to clients for communication reasons, to conduct interviews, provide offer letters or other direct communications.
It may also be used for marketing purposes by Platinum Recruitment Group to send emails, newsletters about job and career information that will be deemed beneficial to the candidate.
We also work within The Equalities Act 2010 and will use data appropriately to ensure fairness and compliance.
Who will it be shared with?
The data will be shared amongst recruitment consultants and employees internally within Platinum Recruitment Group to help find them a role. They will all have access to all of the data that is stored about a candidate and can use this in accordance with their employment contracts. In addition, our employee’s employment contracts hold confidentiality clauses that operate within Information Commissioners Office requirements.
The data will be shared externally with speculative, new or existing clients by Platinum Recruitment Group. These will include a range of people within the employer’s organisation who are in a position to make a decision on a candidate’s skills and experience for a job interview or employment.
What will be the effect of this on the individuals concerned?
Data will be used to profile a candidate and help employees from Platinum Recruitment Group make a decision on whether they would be suitable for a role based on the data we hold. Relevant pieces of this data will be supplied to employers to help them make a decision on the suitability of the candidate.
Is the intended data use likely to cause individuals to object or complain?
No, consent will have been taken from the candidate for the use of their data.
However if you wish to make a complaint please email us on firstname.lastname@example.org or the address above. You can also make a complaint to the Information Commissioner’s Office at this address:
Information Commissioner’s Office
We take your rights very seriously and will adhere to the following:
- Your right to be informed of use of data
- Your right of access to your data
- Your right of rectification of data
- Your right to erasure of data and be forgotten
- Your right to restrict our processing of your data
- Your right for your data to be portable
- Your right to object at the use of your data
- Your rights relating to automated decision making and profiling
We will hold your details on our file for as long as you are in any employment or deemed to be employable. Upon request, we will provide you with all of the data that we hold on you. Please email the Data Officer listed below for this information.
We will never transfer your data outside of the EU unless you have given us permission to do so.
Upon request, Platinum Recruitment Group will adhere to the rights listed above so if you want us to address or action any of these please do so by contacting the Data Protection Officer at any time on email@example.com or on the address above. Please send us your Date Of Birth, name, registered email address and mobile number to ensure that we correct the right record. You also have a right to see the data that we hold on you, please contact The Data Protection Officer should you require this.
We are committed to ensuring that your information is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial processes to safeguard and secure the information we collect and store.
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We use traffic log cookies to identify which pages are being used. This helps us analyse data about web page traffic and improve our website in order to tailor it to customer needs. We only use this information for statistical analysis purposes and then the data is removed from the system.
Overall, cookies help us provide you with a better website, by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us.
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From time to time we may make changes and updates to this policy in order to ensure your information and data is secure.
GDPR and Recruitment: Platinum Recruitment Group
Data controller: Platinum Recruitment Group
Data Subjects: Candidates, suppliers, staff, clients
PII: Personally Identifiable Information
Platinum Recruitment Group takes data gathering, processing and use very seriously and we have been working to become GDPR complaint for some time and have been following the developments with GDPR closely in order to become compliant since the issue arose.
Our primary objective is to maintain outstanding levels of service for our candidate and client base whilst providing a world-class recruitment service, all within GDPR requirements.
Policy & Procedure Objectives
The data that Platinum Recruitment Group gathers is gathered lawfully and for specific purposes only. To be GDPR compliant, we will always seek consent to store and process data in a clear and affirmative way with a timescale on storing data agreed at point of consent. Platinum Recruitment Group will always have confirmation that we can hold their PII with an audit trail (if verbal, an audit trail will be created.)
We will provide the following information to the Data Subject during the consent process:
- Identity and contact details of persons at Platinum Recruitment Group
- The reasons that we hold the data and the sole purpose
- That there are legitimate reasons for holding the data
- Categories of personal data held
- Who the recipients might be
- If it is to be transferred outside the EU
- Origin of the data
- Period of time for the data to be stored
- The logic of any automated processing
- How to exercise your rights
- The right to withdraw
- The right to complain to the regulator
Platinum Recruitment Group classes all internal notes and correspondence with candidates or to 3rd parties about correspondence as PII. We will make the PII and records and any notes accompanying the data available to those who the record involves. We will supply the source of where we gathered the data and request consent to use data within 30 days of gathering the data. Upon request, we will amend data if requested. We will also remove and permanently delete data from the consented databases as soon as possible at any time should it be requested.
Platinum Recruitment Group shall only work with Data Processors (companies who store the data on our behalf) who guarantee to support the rules of GDPR.
Platinum Recruitment Group is waiting on advice regarding the portability of data, should a data subject request all data and how this might have to be provided to another data controller.
In the event of a data breach, Platinum Recruitment Group will notify the regulator within 72hrs.
Audit of Data
Platinum Recruitment Group is continually developing an audit of all data within the business and this is assisting in our drive to become GDPR compliant.
Storage of data
Data will only be stored on our CRM system or where consent from an affirmative action has been given.
Platinum Recruitment Group acknowledges that the new requirements for consent will not necessarily cover all existing data held. Like most recruitment companies, we are potentially in possession of Data Subject PII with no audit of consent and no evidence that we have engaged with the Data Subject or supplied a service and will therefore be seeking affirmative action in order to gain consent to hold this data moving forward, within a reasonable timescale, in order to be GDPR compliant.
Training of staff on GDPR
Platinum Recruitment Group is holding training with its employees as the picture regarding GDPR becomes clearer for the industry and Platinum Recruitment.
- Platinum Recruitment Groups contracts with its staff cover confidentiality and the use of data and this will be extended to be GDPR compliant
- Platinum Recruitment Group will continue to ensure that every leaver has access to all data revoked
- Platinum Recruitment Group is creating a data retention policy
- Platinum Recruitment Group will continue with its strict password policy
- Platinum Recruitment Group will be conducting a Privacy Impact Assessment
- Platinum Recruitment Group is part of focus groups and forums to understand the latest developments on GDPR and implement them accordingly
- Platinum Recruitment Group continues to take legal advice on the implementation of GDPR
If you have any questions about Platinum Recruitment Group approach to GDPR, then please contact the Data Officer, Duncan Hughes, on firstname.lastname@example.org