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PRIVACY NOTICE – REFEREE 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 for the purposes of obtaining a reference for our applicant; or worker; or employee. 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. We may also use your information during the course of audits to demonstrate our compliance with certain industry standards. In any case the Company must have a legal basis for processing your personal data. We will only use your personal data in accordance with the terms of our privacy notice. 1.1 COLLECTION OF DATA Your personal details have been provided to us by another person (e.g. our applicant; or worker; or employee) who has indicated you as a referee. 1.2 PURPOSE OF PROCESSING AND LEGAL BASES The legal bases we rely upon when processing your personal data are: Legal base Legal obligation Contractual obligation Legitimate interest Consent
Public interest Vital interest of data subject
Example of purpose Does not apply Does not apply To fulfil our recruitment requirements which referencing is a vital part of the recruitment process to ensure the suitability of an individual Where we have explicitly obtained your consent to share your data with the data subject and our client that data is introduced/supplied to e.g. to provide a testimonial and/or reference about our service provision. We also rely upon your consent to use your data for purpose of direct marketing. You have the right to withdraw that consent at any time by clicking unsubscribe on our marketing email or by emailing Data Protection Officer dpo@gap-personnel.com Does not apply To support the applicant; or worker; or employee to fulfil our recruitment requirements which referencing is a vital part of the recruitment process to ensure the suitability of an individual
1.3 RECIPIENTS/S OF DATA Where we need to share your personal and/or sensitive data, we have contracts and data sharing agreements in place with the recipients that require them to treat your information as confidential and ensure the continued protection of your data whilst in their possession. The Company will process your personal data and/or sensitive date, with the following recipients: a) Our parent company and any of our group companies; b) Governing bodies, law enforcement, regulators and any other authorities as required by law; c) Any organisations including trade bodies, associations, business partners of which we are registered members or licence holders, such as REC, GLAA, ALP, Sedex and Stronger Together; d) Master/Neutral vendor and/or other recruitment agencies and/or Employment Business within the supply chain, where you agreed for supplied references to be shared when necessary; e) Our clients as part of an audit process, where you agreed for supplied references to be shared when necessary; f) Our software providers, including IT, CRM, Website, Marketing technology platforms and suppliers; g) Third party suppliers, e.g. business associates and professional advisers, such as external consultants, technical and IT support functions, payroll companies, pension provider, insurers, legal advisors, independent auditors and intermediaries; h) We may transfer your personal information to a third party as part of a TUPE transfer under The Transfer of Undertakings (Protection of Employment) Regulations 2006; i) 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
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