Conquisitor Ltd | Privacy Policy
Conquisitor Ltd (referred to as “we”, “us”, “our”) is a headhunting business and our legitimate interests encompass the activities necessary to carry on the commercial activity of providing recruitment services. We work on behalf of businesses (referred to as ‘Clients’) to conduct research, identify, engage and source individuals (referred to as ‘Candidates’) for employment opportunities.
We will only process personal information as detailed in this notice, unless we inform you otherwise. Should you wish to query, update, edit or remove the personal data we hold about you then the person responsible for data protection is Christopher Jacques who can be contacted on: Tel: +44 (0) 20 8090 7498 Email: christopher.jacques@theconquisitor.com
If you do not wish us to process personal data in accordance with this policy, then please do not provide it to us. Refer to Section 4 ’Your Rights‘, in respect of data that we already hold, or which we receive from third parties.
Section 1 | Clients & Commercial Partners or Suppliers
How we obtain data
We may collect your personal data in the course of our dealings (e.g. name, company you represent, telephone and email) and information relevant to our legitimate interests in the supply of recruitment services (e.g. interview feedback, opinions on candidates, commercial discussions). This information may be obtained directly from you, other representatives in your organisation, 3rd party referrals, social media, business information databases or the public domain.
How we process data
We will process your personal data only within the context of our business dealings with the Company for whom you work. This may include storing, using data to communicate with you, retaining records of our dealings and transactions, and to provide 3rd parties with information when relevant to us carrying out our legitimate interests as a provider of recruitment services (e.g. briefing a Candidate in respect to an employment opportunity).
Why we process data
In order to carry out our legitimate interests as recruitment services provider it is necessary to process some personal data to (a) comply with statutory provisions including the Conduct of Employment Agencies and Employment Businesses Regulations 2003 which requires us to assess suitability of Candidates and obtain information from Clients; (b) comply with obligations relating to business generally such as Tax, fraud/crime prevention and co-operating with authorities such as HMRC; (c) contact Clients regarding our recruitment services and execute our contractual obligations.
Consent
We may process your personal data on the basis that you have consented to us doing so either verbally or in writing for a specific purpose (e.g. by engaging with us commercially on behalf of the organisation you represent). For our commercial viability and to pursue our legitimate interests, we may continue to process your personal information for as long as we consider reasonably appropriate. However, you may object to our processing your personal data at any stage (please refer to Section 4 ‘Your Rights’). Please note that we may retain or otherwise use your personal information thereafter where we have a legitimate legal, commercial or contractual obligation to do so.
When data is obtained from a 3rd party
Part of our business activity involves researching information for the purposes of finding and filling job roles which may come from a range of sources. Where information from 3rd parties is of no use we will discard it but where we have a strong reason to believe that you can benefit from the provision of our recruitment services then we may process the data required to enable us to make this representation to you.
Section 2 | Candidates
How we obtain data
We may collect your personal data in the course of carrying out our legitimate interests as a provider of recruitment services and the data we require you to provide will depend on the stage reached in the process of finding a suitable opportunity for you.
To make an initial registration we require the following personal information which may be sent by email, via some other messaging system (e.g. LinkedIn), or sometimes uploaded directly via our website (Name, Telephone, Email Address, and a CV providing skills, job history and education history). If you do not wish us to process personal data in accordance with this policy, then please do not provide it to us. We will only have a copy of your CV if you have provided it directly to us for recruitment services purposes.
Should the recruitment process advance to a stage where we intend to introduce your details to a client then we will ask you to provide additional information (e.g. address, proof of identity, proof of eligibility to legally accept employment) and other information relating to your career advancement (e.g. aspirations, motivations, goals, travel availability, expected compensation etc.) If necessary we may also ask for details of referees, criminal record, health conditions relevant your ability to work, or other information that it is reasonable for a Client to request before employing you.
As a head hunting business part of our activity involves researching information for the purposes of finding and filling job roles which may come from a range of sources including social media, referrals and recommendations, publications and other areas of the public domain.
How we process data
We will process your personal data only within the context of providing advice, searching for a suitable employment opportunity for you, executing the selection process, and to facilitate aftersales care. This may include storing, using data to communicate with you, assessing your suitability for job roles, notifying you of job roles, retaining records of our dealings, introducing information to actual or potential clients, and to provide 3rd parties with information when relevant to us carrying out our legitimate interests as a provider of recruitment services.
Why we process data
In order to carry out our legitimate interests as recruitment services provider we may enter into a contract with you which requires us to process some personal data (e.g. information provided at initial registration). We shall process your data as necessary to fulfil our obligations to you and to our Clients in the course of providing recruitment services. We must comply with statutory provisions including (a) the Conduct of Employment Agencies and Employment Businesses Regulations 2003 which requires us to verify your identity, assess your suitability for job roles, and maintain records of our dealings; (b) comply with obligations relating to your legal eligibility to take up employment (e.g. UKBA); (c) business generally such as Tax, fraud/crime prevention and co-operating with authorities such as HMRC.
Consent
We may process your personal data on the basis that you have consented to us doing so either verbally or in writing for a specific purpose (e.g. to find you a suitable job opportunity or progress your application for a role or gain advice about CV writing, advancement or changes in career direction etc.)
For our commercial viability and to pursue our legitimate interests, we may continue to process your personal information for as long as we consider reasonably appropriate. However, you may object to our processing your personal data at any stage (please refer to Section 4 ‘Your Rights’). Please note that we may retain or otherwise use your personal information thereafter where we have a legitimate legal, commercial or contractual obligation to do so.
When data is obtained from a 3rd party
Part of our activity involves researching information for the purposes of finding and filling job roles which may come from a range of sources (e.g. LinkedIn, referrals from colleagues or ex-employers). Where information from 3rd parties is of no use we will discard it but where we have a strong reason to believe that you can benefit from the provision of our recruitment services then we may process the data required to enable us to make this representation to you. Where personal data is obtained from a 3rd party our policy is to advise you of the source when we first communicate with you.
Section 3 | Applicable to all Personal Data
Data storage & security
All the personal data we process is processed by our staff in the UK however for the purposes of IT hosting and maintenance this information is located on servers within the European Union. We do not sell, rent, share, trade, give away or allow 3rd party access to any of your personal information other than (a) Clients or Candidates of Conquisitor Ltd within the context of providing recruitment services; (b) authorised parties appointed by our Clients to facilitate the recruitment process (e.g. pre-employment screening); (c) companies providing services to enable our business to operate (e.g. IT services) who will not process your data but may act as data controllers. We have a Data Protection regime in place to oversee the effective and secure processing of your personal data.
Transfer to other jurisdictions
In the course of the provision of our Recruitment Services we may on occasion transfer data to countries or organisations outside of the EEA. For example, within the context of finding or filling job opportunities or dealing with international businesses that are located outside the EEA. If this is to a country without an adequacy decision from the EU Commission, then we will endeavour in so far as is reasonable practical to take steps and put safeguards in place.
What if you don’t want to provide necessary data
In a situation where we have requested you to provide data which is necessary for legal, statutory or contractual purposes or to execute our recruitment services and you do not wish to provide that information then please notify us. However, we may be unable to provide you or the party who you represent with recruitment services as a result, and in some cases, this may cause a breach of the contract we have with you or the organisation you represent.
Retaining data
Normally personal data will not be retained for more than 6 years from the last point at which we engaged with you and it is our policy to store personal data only for as long as is reasonably necessary for us to comply with our legal obligations and for our legitimate business interests. Where there is a legal or contractual requirement to do so we may retain data for longer, or where we assess that your personal information identifies specialist skill sets which may remain in demand. However, you may object to us storing your personal data and if you believe that we should delete this at an earlier date please notify us (refer to Section 4 ‘Your Rights’).
Section 4| Your Rights
If at any point you believe the information we process on you is incorrect you can ask to see a copy of the personal data we hold on file and request that it be corrected. You may object to our processing of your data where based upon legitimate interest and there are no compelling grounds for continuing. You may withdraw your consent to our processing of your personal data for a specific purpose at any stage (note that we may thereafter continue to retain, or otherwise use some personal information in a limited fashion where we have a legal or contractual obligation to do so.) You may request that data is erased where the continued use of that data cannot be justified.
If you wish to raise a complaint on how we have handled your personal data, you can contact Christopher Jacques to have the matter investigated. If you are not satisfied with our response or believe we are processing your personal data not in accordance with the law you can complain to the Information Commissioner’s Office https://ico.org.uk
**should you ask that we erase data or cease any processing activity, we may retain a record of this request and the action taken both evidence our compliance, and minimise the potential for any processing in the future should data be received again from a 3rd party source.