Candidates include applicants for any roles advertised or promoted by Impellam, or individuals who Impellam reasonably considers would be interested in being considered for any roles, including permanent, part-time and temporary positions and freelance roles with Impellam clients (including those individuals who want to, or who Impellam reasonably considers may want to, become Temporary Workers); as well as people who have supplied a speculative CV to Impellam not in relation to a specific job. Individual contractors, freelance workers and employees of suppliers or other third parties put forward for roles with Impellam clients as part of an MSP offering or otherwise will be treated as Candidates for the purposes of this Privacy Notice.
What kind of personal data do we collect?
Depending on the relevant circumstances and our applicable legal obligations and regulatory requirements, we will collect some or all of the information listed below to enable us to offer you employment opportunities which are tailored to your circumstances and your interests:
- Age/date of birth;
- Birth number;
- Marital status;
- Contact details;
- Education details;
- Employment history;
- Emergency contacts and details of any dependants;
- Referee details;
- Immigration status (whether you need a work permit);
- Nationality/citizenship/place of birth;
- Start date or availability date:
- A copy of your driving licence and/or passport/identity card;
- Bank details;
- Financial information (where we need to carry out financial background checks);
- Social security number (or equivalent in your country) and any other tax-related information;
- Diversity information (racial or ethnic origin, religious or other similar beliefs, and physical or mental health, including disability-related information);
- Details of any criminal convictions if this is required for a role that you are interested in applying for;
- Details about your previous and current remuneration, pensions and benefits arrangements;
- Child care or carer arrangements (for example, when you authorise a deduction from pay for childcare vouchers or when you volunteer this information);
- Sexual orientation (for example where you disclose this through providing next-of-kin details);
- Information on your interests and needs regarding future employment, both collected directly and inferred, for example from jobs viewed or articles read on our website or from links clicked on in emails from us;
- Extra information that you choose to tell us;
- Extra information that your referees choose to tell us about you;
- Extra information that our Clients may tell us about you, or that we find from other third party sources such as job sites;
- IP address;
- The dates, times and frequency with which you access our services; and
- CCTV footage if you attend our premises;
- Photos or videos uploaded by you to recruitment platforms;
- Telephone call recordings – if you speak with Impellam IT department (retained for 2 weeks from date of recording)
- Telephone call recordings – if you speak with Comensura (retained for 2 years from date of recording)
- Telephone call recordings – if you speak with Blue Arrow National Response Centre (retained for 2 years from date of recording)
Please note that the above list of categories of personal data we collect is not exhaustive.
To the extent that you access our website or click through any links in an email from us, we will also collect certain data from you.
How do we collect your data?
- Personal data that you give to us;
- Personal data that we receive from other sources; and
- Personal data that we collect automatically.
- Personal data you give to us
Impellam needs to know certain information about you in order to provide a tailored service. This will enable us to provide you with the best opportunities and should save you time in not having to trawl through information about jobs and services that are not relevant to you.
There are numerous ways you can share your information with us. These may include:
- Entering your details on an Impellam brand website or via an application form, as part of the registration process;
- Leaving a hard copy CV at an Impellam brand recruitment event, job fair or office;
- Emailing your CV or other information to an Impellam brand consultant or being interviewed by them;
- Applying for jobs through a job aggregator, which then redirects you to an Impellam brand website;
- Entering your personal details into an Impellam microsite; or
- Entering a competition through a social media channel such as Facebook or Twitter (or similar).
- Personal data we receive from other sources
We also receive personal data about Candidates from other sources. Depending on the relevant circumstances and applicable legal obligations and regulatory requirements, this will involve personal data received in the following situations:
- Your referees may disclose personal information about you;
- Our Clients, Suppliers and other Candidates may share personal information about you with us;
- If you 'like' our page on Facebook or 'follow' us on Twitter we will receive your personal information from these sites; and
- If you were referred to us by a third party or a Managed Service Provider (MSP) supplier, they may share personal information about you with us.
- Personal data we collect automatically
To the extent that you access our website or read or click on an email from us, where appropriate and in accordance with any legal obligations and regulatory requirements, we will also collect your data automatically or through you providing it to us.
How do we use your personal data?
Having obtained data about you, we generally use Candidate data in five ways:
- Recruitment Activities;
- Marketing Activities;
- Equal Opportunities Monitoring; and
- To help us to establish, exercise or defend legal claims.
Here are some more details about each:
Our main area of work is recruitment – connecting the right Candidates with the right jobs. We've listed below various ways in which we will use and process your personal data for this purpose, where appropriate and in accordance with any local laws and regulatory requirements. Please note this list is not exhaustive.
- Collecting your data from you and other sources, such as LinkedIn;
- Storing your details (and updating them when necessary) on our database, so that we can contact you in relation to recruitment;
- Providing you with our recruitment services and to facilitate the recruitment process;
- Assessing data about you against vacancies which we think may be suitable for you;
- Sending your information to Clients, in order to apply for jobs or to assess your eligibility for jobs;
- Enabling you to submit your CV, apply online for jobs or to subscribe to alerts about jobs we think may be of interest to you;
- Allowing you to participate in specialist online training;
- Allowing you to participate in the interactive features of our services, when you choose to do so;
- Carrying out our obligations arising from any contracts entered into between us;
- Carrying out our obligations arising from any contracts entered into between Impellam and third parties in relation to your recruitment;
- Facilitating our payroll and invoicing processes;
- Carrying out customer satisfaction surveys;
- Verifying details you have provided or to request information (such as references, qualifications and potentially any criminal convictions, to the extent that this is appropriate and in accordance with local laws);
- Complying with our legal obligations in connection with the detection of crime or the collection of taxes or duties;
- Processing your data to enable us to send you targeted, relevant marketing materials or other communications which we think are likely to be of interest to you; and
- Carrying out assessment and development activities (such as psychometric evaluations or skills tests) in certain jurisdictions in which we operate.
We will use your personal data for the above purposes if we deem it necessary to do so for our legitimate interests. If you are not happy about this, in certain circumstances you have the right to object.
We will periodically send you information that we think you may find interesting, or to ask for your help with connecting other Candidates with jobs. In particular we will to use your data for the purposes listed below, where appropriate and in accordance with our legal obligations and regulatory requirements. Please note this list is not exhaustive. To:
- enable us to develop and market other products and services;
- send you details of reports, promotions, offers, networking and client events, and general information about the industry sectors which we think might be of interest to you;
- display promotional excerpts from your details on the Impellam website such as a success story (only where we have obtained your express consent to do so); and
- provide you with information about certain discounts and offers that you are eligible for by virtue of your relationship with Impellam.
We need your consent for some aspects of these activities which are not covered by our legitimate interests (in particular, the collection of data via cookies, and (in some cases) the delivery of direct marketing of our services to you through digital channels) and, depending on the situation, we'll ask for this via an opt-in or soft-opt-in (which we explain further below).
As provided for under PECR, Soft opt-in consent is a specific type of consent which applies where we have obtained your contact details from an occasion when you previously engaged with us (for example by submitting a job application or CV, or registering for a vacancy to be filled), and we are e-marketing other recruitment-related services of our own.
Under ‘soft opt-in’ consent, we will take your consent as given unless or until you object or opt out (and we will remind you of your right to do this in each e-marketing message that we send to you). For most people, this is beneficial as it allows us to provide you with information that we think will be of interest to you and suggest other jobs to you alongside the specific one you applied for, significantly increasing the likelihood of us finding you a new position.
For other types of e-marketing, we are required to obtain your explicit consent. If you are not happy about our approach to marketing, you have the right to opt out or withdraw your consent at any time. We want to let you know that even if you have opted out from our marketing communications, it is possible that your details may be recaptured through public sources in an unconnected marketing campaign. We will try to make sure this doesn't happen, but if it does, we're sorry. We'd just ask that in those circumstances you email us at email@example.com to opt out again.
All our marketing is based on what we think will serve our Clients and Candidates best, but we know we won’t always get it right for everyone. We will use your data to show you Impellam, and Impellam brand adverts and other content on other websites, for example Facebook. If you do not want us to use your data in this way, please turn off the “Advertising Cookies” option (please refer to our Cookies Policy). Even where you have turned off advertising cookies, it is still possible that you may see an Impellam advert, but in this case it won’t have been targeted at you personally, but rather at an anonymous audience.
Equal opportunities monitoring and other sensitive personal data
We are committed to ensuring that our recruitment processes are aligned with our approach to equal opportunities. Some of the data we will (in appropriate circumstances and in accordance with our legal obligations and regulatory requirements) collect about you comes under the umbrella of "diversity information". This could be information about your ethnic background, gender, disability, age, sexual orientation, religion or other similar beliefs, and/or social-economic background. This diversity information is what is called ‘sensitive’ or ‘special category’ personal information and slightly stricter data protection rules apply to it.
Where appropriate and in accordance with legal obligations and regulatory requirements, we'll use this information on an anonymised basis to monitor our compliance with our equal opportunities policy. We will also disclose this (suitably anonymised where relevant) data to Clients (including to their internal or external auditors) where this is contractually required or the Client specifically requests such information to enable them to comply with their own employment processes.
We will collect other sensitive/special category personal data about you such as health-related information or religious affiliation if this is appropriate in accordance with our legal obligations. In such circumstances we'll use this information to comply with employment rights and obligations, such as to calculate entitlement to annual leave or in order to make reasonable adjustments for Candidates or Temporary Workers.
We may also collect details of any criminal convictions if appropriate in accordance with our legal obligations and regulatory requirements.
To help us to establish, exercise or defend legal claims
In more unusual circumstances, we will use your personal data to help us to establish, exercise or defend legal claims.
Who do we share your personal data with?
Where appropriate and in accordance with our legal obligations and regulatory requirements, we may share your personal data, in various ways and for various reasons, with the following categories of people:
- Any of our group companies (see Annex 1 on this page for a complete list);
- Appropriate colleagues within Impellam (this may include colleagues in overseas offices);
- Individuals and organisations who hold information related to your reference or application to work with us, such as current, past or prospective employers, educators and examining bodies and employment and recruitment agencies;
- Tax, audit, or other authorities, when we believe in good faith that the law or other regulation requires us to share this data (for example, because of a request by a tax authority or in connection with any anticipated litigation);
- Third party service providers who perform functions on our behalf (external suppliers and consultants, business associates and professional advisers such as lawyers, auditors and accountants, technical support functions and IT consultants carrying out testing and development work on our business technology systems);
- Third party outsourced IT and document storage providers where we have an appropriate processing agreement (or similar protections) in place;
- Marketing technology platforms and suppliers;
- Potential employers and other recruitment agencies/organisations to increase your chances of finding employment;
- Third party partners, job boards, job platforms, job aggregators, software providers and cloud based databases where we consider this will improve the chances of finding you the right job or improving recruitment processes more generally;
- Managed Service Provider (MSP) suppliers as part of our Clients' MSP programmes;
- Third parties who we have retained to provide services such as reference, qualification and criminal convictions checks, to the extent that these checks are appropriate and in accordance with our legal obligations;
- Internal and external auditors of our Clients when we are required to share this data with them upon request in order to comply with our contractual or regulatory obligations;
- Third parties helping us by developing services and processes to optimise the Candidate selection process in order to improve the quality and efficiency of recruitment services;
- If Impellam merges with or is acquired by another business or company in the future, (or is in meaningful discussions about such a possibility) we may share your personal data with the (prospective) new owners of the business or company.
What legal bases do we rely on to process Candidate data?
We think it's reasonable to expect that, as a Candidate you are happy for us to collect and otherwise use your personal data to offer or provide our recruitment services to you, share that information with prospective employers and assess your skills against our current job opportunities.
Once you are at the point of securing a job role, your prospective employer may also want to double check any information you have given to us (such as the results from psychometric evaluations or skills tests) or to confirm your references, qualifications and criminal record, to the extent that this is appropriate and in accordance with our legal obligations and regulatory requirements. We need to do these things so that we can function as a profit-making business, and to help you and other Candidates get the jobs you deserve.
We want to provide you with tailored job recommendations and relevant articles to read to help you on your job hunt. We therefore think it is reasonable for us to process your data to make sure that we send you the most appropriate content and identify the most suitable opportunities for you.
We have to make sure our business runs smoothly, so that we can carry on providing services to Candidates. We therefore also need to use your data for our internal administrative activities, like payroll and invoicing where relevant.
We have our own obligations under the law, which it is a legitimate interest of ours to insist on meeting! If we believe in good faith that it is necessary, we will therefore share your data in connection with crime detection, tax collection or actual or anticipated litigation.
Where processing your personal data is necessary for us to carry out our obligations under our Contract with you, to ensure that you are properly fulfilling your obligations to us, and to ensure that we are fulfilling our obligations to others:
We think it is reasonable to assume that, as a Candidate, you are hoping to enter into an employment contract, and that by using our services you are asking us to take the necessary steps for this purpose.
To Exercise our Rights or Carry out our Employment and Social Security Legal Obligations:
It will sometimes be necessary for us to process your sensitive/special category personal data.
Article 9(2)(b) of the GDPR allows us to do this where the processing is "necessary for the purposes of carrying out the obligations and exercising [our or your] specific rights… in the field of employment and social security and social protection law", as long as this is allowed by law.
We process Candidates’ sensitive/special category personal data for the purpose of ensuring our compliance with our equal opportunities obligations where appropriate and in accordance with our legal obligations, (for example, for some Candidates during the course of the recruitment process).
We will also process the sensitive/special category personal data of individuals connected with Candidates or Staff for other reasons, for example to allow the relevant Staff member to access certain benefits or employment rights.
How long do we keep your personal data for?
We will delete your personal data from our systems if we have not had any meaningful contact with you (or, where appropriate, the company you are working for or with) in accordance with our retention periods at Annex 2 on this page (or for such longer period as we believe in good faith that the law or relevant regulators require us to preserve your data). After this period, it is likely your data will no longer be relevant for the purposes for which it was collected.
If you have expressly indicated that you would rather we didn't retain your personal data, then we will delete it from our systems unless we believe in good faith that the law or other regulation requires us to preserve it (for example, because of our obligations to tax authorities or in connection with any anticipated litigation).
For those Candidates whose services are provided via a third party company or other entity, "meaningful contact" with you means meaningful contact with the company or entity which supplies your services. Where we are notified by such company or entity that it no longer has that relationship with you, we will retain your data in accordance with our retention periods at Annex 2 on this page, if later, from the point we subsequently have meaningful contact directly with you.
When we refer to "meaningful contact", we mean, for example, communication between us (either verbal or written), or where you are actively engaging with our online services. We will consider there to be meaningful contact with you if you submit your updated CV onto our website or take part in any of our online training. We will also consider it meaningful contact if you communicate with us about potential roles, either by verbal or written communication or click through from any of our marketing communications. Your receipt, opening or reading of an email or other digital message from us will not count as meaningful contact – this will only occur in cases where you click-through or reply directly.In determining the appropriate retention period for different types of personal data, we always consider the amount, nature, and sensitivity of the personal data in question, the potential risk of harm from unauthorised use or disclosure of that personal data, the purposes for which we need to process it and whether we can achieve those purposes by other means (in addition of course to ensuring that we comply with our legal, regulatory and risk-management obligations, as described above).