Privacy Policy

At Finlay James we take the privacy of our clients, candidates and visitors seriously.

Finlay James Associates is committed to protecting and respecting your privacy.

Our Group means our subsidiaries, our ultimate holding company and its subsidiaries, our associated companies as defined in section 1159 of the UK Companies Act 2006 (our Group).

This policy 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 has expressed its intention to leave the EU in March 2019, the GDPR will be applicable in the UK from 25th May 2018. The Government intends for the GDPR to continue in UK law post Brexit and has also introduced a Data Protection Bill to replace the current Data Protection Act in due course.

Your new rights under the GDPR are set out in this policy but will only apply once the GDPR becomes law on 25th May 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 Finlay James Associates of Ground Floor, Kingston House, Towers Business Park, and Didsbury, M20 2LD.

Our Data Protection Officer is Linda Latimer, Human Resources Manager, at the above address.

 

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 core business). We collect the personal data of the following types of people to allow us to undertake our business;

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

 

Information you give to us or we collect about you.

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

It also includes any information we gather from you at interview or other meetings with you, whether that occurs face to face or, for example, by telephone or video.

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, personal recommendations, and others. In this case we will inform you within a maximum of 30 days of collecting the data of the fact we hold personal data about you, the source the personal data originates from and whether it came from publicly accessible sources, and for what purpose we intend to retain and process your personal data.

We are working closely with third parties including business partners, sub-contractors in technical, professional, payment and other services, analytics providers, search information providers, credit reference agencies, professional advisors AND OTHERS. We may receive information about you from them for the purposes of our recruitment services and ancillary support services.

 

Purposes of the processing and the legal basis for the processing

We use information held about you in the following ways:

Our legal basis for the processing of personal data is our legitimate business interests, described in more detail below, although we will also rely on contract, legal obligation and consent for specific uses of data.

We will rely on contract if we are negotiating or have entered into a placement agreement with you or your organisation or any other contract to provide services to you or receive services from you or your organisation.

We will rely on legal obligation if we are legally required to hold information on to you to fulfil our legal obligations, for example for the purpose of placing candidates for permanent and temporary roles.

We will in some circumstances rely on consent for particular uses of your data and you will be asked for your express consent.  Examples of when consent may be the lawful basis for processing include permission to introduce you to a client (if you are a candidate).

 

Our Legitimate Business Interests

Our legitimate interests in collecting, retaining and processing your personal data is described below:

As a recruitment business and recruitment agency we introduce candidates to clients for permanent employment, temporary worker placements or independent professional contracts.  The exchange of personal data of our candidates and our client contacts is a fundamental, essential part of this process.

In order to support our candidates’ career aspirations and our clients’ resourcing needs we require a database of candidate and client personal data containing historical information as well as current resourcing requirements and candidate information.

To maintain, expand and develop our business we need to record the personal data of prospective candidates and client contacts.

 

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.

Other Uses we will make of your data:

We will use this information:

We do not undertake automated decision making or profiling. We do use our computer systems to search and identify personal data in accordance with parameters set by a person. A person will always be involved in the decision making process.

 

Cookies  

Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site. Finlay James does not permit third party organisations to set or access Finlay James cookies on your browser. From time to time other companies may set and access their own cookies on your browser through your usage of the Finlay James website. Finlay James cannot access these cookies and you should consult the relevant third-party’s privacy policy if you require further information.

The cookies track data linked to your email address and include data such as how you arrived at the site, how often you’ve visited, and which pages you looked at. To opt out of this, you can disable cookies or unsubscribe from Finlay James emails using the link on the bottom of any marketing email.

Email Marketing: Finlay James may send job or operational announcements by email to users who have registered their details on the Finlay James website, applying for a job or dropping off their CV. Users may unsubscribe from operational and marketing emails at any time by clicking the unsubscribe link at the bottom of any marketing email or emailing hello@finlayjames.co.uk. 

 

Disclosure of your information inside and outside of the EEA

We will share your personal information with:

Any member of our group both in the EEA and outside of the EEA.

Selected third parties including:

We will disclose your personal information to third parties:

The lawful basis for the third party processing will include:

 

Where we store and process your personal data  

All information you provide to us is stored on our secure servers.

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; 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.

 

Retention of your data

We understand our legal duty to retain accurate data and only retain personal data for as long as we need it for our legitimate business interests and that you are happy for us to do so.  Accordingly, we have a data retention notice and run data routines to remove data that we no longer have a legitimate business interest in maintaining.

We do the following to try to ensure our data is accurate:

We segregate our data so that we keep different types of data for different time periods.  The criteria we use to determine whether we should retain your personal data includes:

 

Your rights  

You have the right to ask us not to process your personal data for marketing purposes. We will usually inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes and we will collect express consent from you if legally required prior to using your personal data for marketing purposes.

You can exercise your right to accept or prevent such processing by checking certain boxes on the forms we use to collect your data. You can also exercise the right at any time by contacting us at Finlay James Associates, Ground Floor, Kingston House, Towers Business Park, Didsbury, M20 2LD or email linda.latimer@finlayjames.co.uk.

Our site may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.

The GDPR provides you with the following rights. To:

If you wish to exercise any of these rights you should, in the first instance email our appointed Data Protection Officer at linda.latimer@finlayjames.co.uk

Access to information  

The Data Protection Act 1998 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.

Your right of access can be exercised in accordance with the Act (and the GDPR once it is in force). Prior to 25th May 2018 any access request under the Data Protection Act will be subject to a fee of £10 to meet our costs in providing you with details of the information we hold about you. No fee will apply once the GDPR comes into force.

If a subject access request is manifestly unfounded or excessive, Finlay James is not obliged to comply with it. Alternatively, Finlay James can agree to respond but may charge a fee, which will be based on the administrative cost of responding to the request.

A subject access request should be submitted to linda.latimer@finlayjames.co.uk

 

Changes to our privacy policy  

Any changes we make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our privacy policy.

 

Contact  

Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to Linda Latimer, Human Resources Manager, Finlay James Associates, Ground Floor, Kingston House, Towers Business Park, Didsbury, M20 2LD, or email at linda.latimer@finlayjames.co.uk.