in data protection law to explain how we manage and use your information. This policy was last updated on 22 May 2018.
Boston Hale is committed to protecting the privacy of our
candidates, clients and websites users.
We want to provide a safe and secure user experience. We will ensure that the information you
submit to us, or which we collect through various means, including our website,
email, written correspondence, conversations or meetings is only used for the
purposes set out in this policy.
We aim to inform you about the types of personal data we
collect from candidates, the purposes for which we use the data and the ways in
which the data is handled. We also aim
to satisfy the obligation of transparency under the EU General Data Protection
Regulation, GDPR, and national laws implementing GDPR.
The right to object.
You have a legal right to object at any time to the use of your personal
information for direct marketing purposes and the processing of your personal
information which is based on our legitimate interests, unless there are
compelling legitimate grounds for our continued processing.
The information we collect
We will collect your personal details, including your
name and contact details, such as your email address, and other relevant
information from your CV. On occasion,
this will also include sensitive personal information such as details of
criminal convictions and ethnic origin. When we receive your details and
CV electronically, this may be through a direct application on our website or
an application that you have made through a third-party job board.
will likely obtain further personal information about you during the course of
our relationship with you. This information may be obtained from you
directly or from third parties, such as organisations to whom we have provided
your CV and who have engaged with you as part of a job application.
How we use your personal information
We will hold, use and disclose
your personal information, for our legitimate business purposes including:
provide our services to you;
maintain our business relationship, where you are a user of our website, a
client or candidate;
enable you to submit your CV for general applications, to apply for specific
jobs or to subscribe to our job alerts.
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;
retain your details and notify you about future job opportunities other than
the specific role for which you have contacted us;
answer your enquiries;
direct-market products and 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;
fulfil contractual obligations with our clients;
provide 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.
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
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 – in some circumstances, we may ask for your consent to
process your personal data in a particular way.
How we share your personal information
We disclose your personal
information to clients who have vacancies for jobs in which you are 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;
·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:
·data analytics providers;
·IT consultants carrying out testing and
development work on our business technology systems;
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
How long we will hold your
The length of time we will hold or
store your personal information for will depend on the services we perform for
you and for how long you require these. As we often support candidates
with placements over many years, and potentially throughout their careers, the
purpose for which we retain candidate data is often an ongoing purpose.
We conduct 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 on information we hold
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
You have the right at any time to
ask us for a copy of the personal information about you that we hold.
Where 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
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, 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
You can exercise any of the above
rights by contacting us, see 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.
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,
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
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
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).
Like most websites, when you visit
our sites 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 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
·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
·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
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 3rd party cookies from google,
go to www.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
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.
by Boston Hale at any time.
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. Please click here for
more information on diversity.
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
When you contact us, we will ask
you to verify your identity.
Our registered office is at 1-3
Pemberton Row, London, EC4A 3BG