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PRIVACY NOTICE - CLIENTS THE COMPANY AND THE COMPANY POLICY This policy is applicable to all businesses, offices and operations within the gap personnel group www.gap-personnel-group.com (referred to as The Company), including: • BeNext UK Holdings Limited – Company Reg – 8044442 – ICO – ZB066799 • gap personnel Holdings Limited (including Hawk 3 Talent) – Company Reg – 3589208 – ICO - Z2057848 - https://www.gap-personnel.com/ • gap technical Limited – Company Reg – 5646432 – ICO – ZA230558 - https://www.gap-technical.com/ • gap personnel (TELFORD) LTD – company Reg – 13377649 – ICO – ZB346100 - https://www.gap-personnel.com/ • Quattro Recruitment Limited t/a gap personnel – Company Reg – 7131120 – ICO – ZA015243 - https://www.gap-personnel.com/ • Quattro Healthcare Ltd t/a gap healthcare – Company Reg - 9389534 – ICO – ZA127351 - https://www.gap-healthcare.com/ • Driving Force Recruitment Limited - company Reg – 06538808 – ICO - Z1709668 - https://www.driving-force.co.uk/ Our parent company is Open Up Group Inc. which is a global human resources and staffing provider; Open Up Group Inc. NBF Comodio Shiodome, 2-14-1 Higashi-shimbashi, Minato-ku, Tokyo 105-0021, Japan. The Company is a recruitment business which provides work-finding, recruitment, training and related services to its clients and work-seekers. The Company must process personal data so that it can provide these services – in doing so, the Company acts as a data controller. We will only use your personal data in accordance with the terms outlined in our contracts and our privacy notice. 1. COLLECTION AND USE OF PERSONAL DATA The Company will collect your personal data and process your personal data, which may include sensitive data, for the purposes of providing you with our 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 relationship 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 also to comply with laws that apply to us. We may also use your information during the course of audits to demonstrate our compliance with certain industry standards. 1.1 COLLECTION OF DATA The Company will collect your personal data via a number of routes, including but not limited to the methods detailed below: a) You may give your personal details to the company directly, such as by seeking services from us. b) We may collect personal data on your visits to our website including, but not limited to, your IP address, browser, timestamp, content from surveys and contact forms and other communication data and the resources that you access. c) Your details may have been identified via publicly available sources in relation to your professional history e.g. LinkedIn or your company website. d) We may collect data from interactions you conduct with our social media platforms, including but not limited to posts, likes, comments, shares, tags and direct messages. This data may be utilised within the social media platforms themselves and may at times be required to be transferred to our internal databases and CRM systems, for the purposes of demographics, trackers for targeted advertising and recording and reporting systems e.g where you have entered and won a competition. e) In some circumstances, your personal details may have been provided to us by another person in your company in order for us to offer and / or perform a contractual obligation between our company and your company. f) In some circumstances, your personal details may have been provided to us by another person for us to offer our services to you, e.g. a referral from one of our clients. In any case the Company must have a legal basis for processing your personal data, which may include sensitive data. We will only use your personal data in accordance with the terms of a contract and our privacy notice. 1.2 PURPOSE OF PROCESSING AND LEGAL BASES The legal bases we rely upon when providing and/or offering to provide these services to you are: Legal base Legal obligation Contractual obligation
Example of purpose To comply with law, e.g. HMRC, Tax legislation, HSE, The Conduct of Employment Agencies and Employment Businesses Regulations 2003, Fraud Prevention. To provide our services including work-finding, recruitment, training and related services. To assist us/you to establish/exercise or defend legal claims.
Legitimate interest
For marketing and public relations in relation to our services; To improve the services we offer and provide including work-finding, recruitment, training and related services.
Consent
Where we have explicitly obtained your consent to share your data with other potential client e.g. to provide a testimonial and/or reference about our service provision.
Public interest
This may apply in limited circumstances where the client itself operates within the public sector and certain reporting to HMRC or similar governing body is required. Third party, where necessary to protect your vital interest and/or where it is believed that you are in immediate danger, e.g. emergency services.
Vital interest of data subject
gap personnel Holdings Limited – CR - 03589208 – GLAA – CAST0004 gap technical Limited – CR - 5646432 Quattro Recruitment Limited – CR - 7131120 – GLAA – QUAT0001 Talent Invest Limited – CR – 05104902
BeNext UK Holdings Limited – CR – 8044442 Quattro Group Holdings Limited – CR 9508069 Quattro Healthcare Limited – CR – 09389534 gap personnel (Telford) Limited – 13377649 – GLAA – GAPP0008