Privacy Policy

Introduction

Boston Hale have updated their privacy policy in line with recent changes in data protection law to explain how they manage and use personal information. This policy was last updated on 23^rd September 2019.

Boston Hale are committed to protecting the privacy of our candidates, clients and websites users.

This notice sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us.

The General Data Protection Regulation (GDPR) (Regulation (EU) 2016/679) is a new regulation which replaces the Data Protection Regulation (Directive 95/46/EC). The Regulation aims to harmonise data protection legislation across EU member states, enhancing privacy rights for individuals and providing a strict framework within which commercial organisations can legally operate.

Even though the UK expressed its intention to leave the EU in March 2019, the GDPR is applicable in the UK from 25thMay 2018. The Government intends for the GDPR to continue in UK law post Brexit and has therefore enforced the Data Protection Act 2018.

Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

For the purposes of data protection legislation in force from time to time the data controller is Boston Hale of 1-3 Pemberton Row, London, EC4A 3BG.

Our Data Protection Officer Graham Hale.

Who we are and what we do

We are a recruitment agency and recruitment business as defined in the Employment Agencies and Employment Businesses Regulations 2003 (our business).

We collect the personal data of the following types of people to allow us to undertake our business;
• Prospective and placed candidates for permanent or temporary roles;
• Prospective and live client contacts;
• Supplier contacts to support our services;
• Employees, consultants, temporary workers.

We collect information about you to carry out our core business and ancillary activities.

Information you give to us

This is information about you that you give us by filling in forms on our site www.bostonhale.com (our site) or by corresponding with us by phone, e-mail or otherwise. It includes information you provide when you register to use our site, to enter our database, subscribe to our services, attend our events, participate in discussion boards or other social media functions on our site, enter a competition, promotion or survey, and when you report a problem with our site.

Information we collect

The information you give us or we collect about you may include your name, address, private and corporate e-mail address and phone number, financial information, compliance documentation and references verifying your qualifications and experience and your right to work in the United Kingdom, curriculum vitae and photograph, links to your professional profiles available in the public domain e.g. LinkedIn, Twitter, business Facebook or corporate website.

Information we obtain from other sources

This is information we obtain about you from other sources such as LinkedIn, corporate websites, job board websites, online CV libraries, your business card or personal recommendations.

We are working closely with third parties including suppliers of technical, professional, payment and other services, advertising networks, analytics providers, search information providers and professional advisors. We may receive information about you from them for the purposes of our recruitment services and ancillary support services.

How we use your personal information

We will hold, use and disclose your personal information, for our legitimate business purposes including:
1. to provide our services to you;
2. to maintain our business relationship, where you are a user of our website, a client or candidate;
3. to enable you to submit your CV for general applications, to apply for specific jobs or to subscribe to our job alerts.
4. to match your details with job vacancies, to assist us in finding a position that is most suitable for you and to send your personal information (including sensitive personal information) to clients in order to apply for jobs;
5. to retain your details and notify you about future job opportunities other than the specific role for which you have contacted us;
6. to answer your enquiries;
7. to direct-market services, advise you of news and industry updates, events, promotions and competitions, reports and other information. You will be given an option to opt-out of such communications and an option to unsubscribe will also be provided with each communication;
8. to fulfil contractual obligations with our clients;
9.to provide continued/further services to you by sharing your personal information with other companies within our Group of companies, should we decide to form a Group, as well as trusted third parties.
10. to release personal information to regulatory or law enforcement agencies, if we are required or permitted to do so;

We may process, in accordance with local regulations, certain sensitive personal data (known as special category data in GDPR) where you include it in information you send to us e.g. if you include information about your health, religion or ethnic origin in the CV you send to us.

We may also be required to conduct a criminal records check against your details. We have processes in place to limit our use and disclosure of such sensitive data other than where permitted by law.

The legal basis for processing your personal information

Under GDPR, the main grounds that we rely upon to process personal information of clients and candidates are the following:

(a) Necessary for entering into, or performing, a contract – in order to perform obligations that we undertake in providing a service to you, or in order to take steps at your request to enter into a contract with us, it will be necessary for us to process your personal data;

(b) Necessary for compliance with a legal obligation – we are subject to certain legal requirements which may require us to process your personal data. We may also be obliged by law to disclose your personal data to a regulatory body or law enforcement agency;

(c) Necessary for the purposes of legitimate interests - either we, or a third party, will need to process your personal data for the purposes of our (or a third party's) legitimate interests, provided we have established that those interests are not overridden by your rights and freedoms, including your right to have your personal data protected. Our legitimate interests include responding to requests and enquiries from you or a third party, optimising our website and customer experience, informing you about our products and services and ensuring that our operations are conducted in an appropriate and efficient manner;

(d)Consent– Should we want or need to rely on consent to lawfully process your data we will request your consent orally, by email or by an online process for the specific activity we require consent for and record your response on our system.Where consent is the lawful basis for our processing you have the right to withdraw your consent to this particular processing at any time.

Who we share your personal information with

Clients

We may disclose personal information of candidates to clients who have vacancies for jobs in which they would be interested.

Trusted Third Parties

We will share your personal information and, where necessary, your sensitive personal information with trusted third parties where we have retained them to provide services that you or our clients have requested, such as:
• employment reference checking;
• qualification checking;
• criminal reference checking (as required);
• verification of details you have provided from third party sources; and/or
• psychometric evaluations or skills tests.

We will also share your personal information with third parties who perform functions on our behalf and provide services to us such as:
• professional advisors;
• data analytics providers;
• IT consultants carrying out testing and development work on our business technology systems;
• payroll providers

We require minimum standards of confidentiality and data protection from such third parties.

Regulatory and Law Enforcement Agencies

As noted above, if we receive a request from a regulatory body or law enforcement agency, and if permitted under GDPR and other laws, we may disclose certain personal information to such bodies or agencies.

New business owners

If we or our business merges with or is acquired by another business or company, we will share your personal information with the new owners of the business or company and their advisors. If this happens, you will be sent notice of such event.

How long we will hold your information

We understand our legal duty to retain accurate data and only retain personal data for as long as we need it for our legitimate interests and that you are happy for us to do so.Accordingly, we have a data retention notice andconduct regular data-cleansing and updating exercises with our candidates to ensure that (a) the data that we hold is accurate and (b) we are not holding data for too long.

Your rights

You have certain rights in relation to personal information we hold about you. Details of these rights and how to exercise them are set out below. We will require evidence of your identity before we are able to act on your request.

Right of Access

The Data Protection Act 2018 and the GDPR give you the right to access information held about you.We also encourage you to contact us to ensure your data is accurate and complete.

A subject access request should be submitted to enquiries@bostonhale.com. No fee will apply unless the requests from a data subject are manifestly unfounded or excessive, in particular because of their repetitive character. In such circumstances, we may charge a fee or refuse to act on the request.

If we have good reason, and if the GDPR permits, we can refuse your request for a copy of your personal information, or certain elements of the request. If we refuse your request or any element of it, we will provide you with our reasons for doing so.

Right of Correction or Completion

If personal information we hold about you is not accurate, out of date or incomplete, you have a right to have the data rectified, updated or completed. You can let us know by contacting us, see details below.

Right of Erasure

In certain circumstances, you have the right to request that personal information we hold about you is erased e.g. if the information is no longer necessary for the purposes for which it was collected or processed or our processing of the information is based on your consent and there are no other legal grounds on which we may process the information.

Right to object to or restrict processing

In certain circumstances, you have the right to object to our processing of your personal information by contacting us (see details below).For example, if we are processing your information on the basis of our legitimate interests and there are no compelling legitimate grounds for our processing which override your rights and interests. You also have the right to object to use of your personal information for direct marketing purposes.

You may also have the right to restrict our use of your personal information, such as in circumstances where you have challenged the accuracy of the information and during the period where we are verifying its accuracy.

Right of Data Portability

In certain instances, you have a right to receive any personal information that we hold about you in a structured, commonly used and machine-readable format.

You can ask us to transmit that information to you or directly to a third-party organisation.

The above right exists only in respect of personal information that:
• you have provided to us previously; and
• is processed by us using automated means.

While we are happy for such requests to be made, we are not able to guarantee technical compatibility with a third-party organisation's systems. We are also unable to comply with requests that relate to personal information of others without their consent.

You can exercise any of the above rights by contacting us (see details below).

Most of the above rights are subject to limitations and exceptions. We will provide reasons if we are unable to comply with any request for the exercise of your rights.

Consent

To the extent that we are processing your personal information based on your consent, you have the right to withdraw your consent at any time. You can do this by contacting us, see below.

Job Alerts

To subscribe to job alerts emails, you will be required to provide your name and e-mail address, which will be used to keep you informed, by e-mail, of the latest jobs in your nominated industry and to provide you with industry news and other information related to our services.

Should you decide that you no longer wish to receive this information, unsubscribe links are provided in every job alert email that you receive.

Curriculum Vitae (CV)

We give you the option of submitting your CV via our website or by providing your CV to one of our consultants. You can do this either to apply for a specific advertised job or for consideration by our recruitment consultants for positions as they come up.

Your CV will be stored in our database and will be accessible by our recruitment consultants.

Should we become part of a Group of companies, your CV may also be emailed directly to other companies within the Group for review and entry onto their database to enable them to provide their services to you.

You can update your CV at any time, simply by following the same procedure to submit a new CV. Your old CV will automatically be archived providing the submission details remain the same (for example you submit both CVs using the same email address or you advise the relevant contact of your new submission).

Use of Cookies

Like most websites, when you visit our site, we place cookies on your computer or other device. For the most part, these cookies are used to enable the websites' functionality, improve the user experience or help us to optimise our websites, measure traffic and other internal management purposes.

When you visit www.bostonhale.com (our site), we collect standard internet log information and details of visitor behaviour patterns. We do this to find out things such as the number of visitors to the various parts of the website. We will not associate any data gathered from this site with any personally identifying information.

What are cookies

Cookies are small text files that are placed on your computer by websites that you visit. They are widely used to make websites work and improve the usability of those sites.

We use these cookies to:
• Remember things like what type of jobs you are interested in when navigating to different pages in a single web browser session
• Make forms work such as applying for a job, submitting your CV, or completing a survey
• Collect information about how you use our website ie what pages you visit and how you navigate to the pages that you are most interested in. These cookies do not collect any information that could identify you and the information is only used to help us improve our overall website experience.
• Integrate with social networking sites such as Google and LinkedIn to allow you to share content from our site on theirs.
• Allow Google Maps to show on our website

We don’t use these cookies to
• Gather information that could be used to advertise products or services to you
• Remember your preferences or username beyond your current visit
• Gather any personal information that could be used to advertise products or services to you on other websites

In some cases, these cookies are managed by 3rd parties but they do not use them for any other purposes than those listed above.Certain 3rd party cookies such as the ones from Google, may also be used by the 3rd party to target advertising.For more information regarding 3^rd party cookies from google, go towww.google.co.uk/intl/en/policies/privacy/

Accepting these cookies is a condition of using the website. If you disable these cookies we cannot guarantee how the site will perform for you.

Cookies can be removed or disabled altogether. You can control the use of these cookies either by changing the settings in your web browser or by using the 3rd parties’ own tools. Please note that by disabling these cookies you may prevent us from offering you certain services on www.bostonhale.com

Internet-based transfers

Given that the Internet is a global environment, using the Internet to collect and process personal data necessarily involves the transmission of data on an international basis. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site via third party networks; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

Changes to our Privacy Policy

This privacy policy can be changed by Boston Hale at any time.

Equal Opportunities

Boston Hale is an equal opportunities employer and a company committed to diversity. This means that all job applicants and members of staff will receive equal treatment and that we will not discriminate on grounds of gender, marital status, race, ethnic origin, colour, nationality, national origin, disability, sexual orientation, religion or age.

As part of our commitment to equal opportunities we will from time to time use information provided by you for the purposes of diversity monitoring. All such information will be used on an anonymised basis. Pleaseclick herefor more information on diversity.

Contact

If you have any enquires or if you would like to contact us about our processing of your personal information, including to exercise your rights as outlined above, please contact us either by email or letter to the following address:-Data Protection Officer, Boston Hale, 1 – 3 Pemberton Row, London EC4A 3BG enquiries@bostonhale.com

When you contact us, we will ask you to verify your identity.

Our registered office is at 1-3 Pemberton Row, London, EC4A 3BG