COYNE RECRUITMENT LIMITED (“We”) are committed to protecting and respecting your privacy and will ensure that the data you supply to us will be processed with skill and care and in accordance with applicable legislation and codes.
For the purpose of the General Data Protection Regulation (GDPR) (Regulation (EU) 2016/679), the data controller is COYNE RECRUITMENT LIMITED of Space Solutions Business Centre, Sefton Lane Industrial Estate, Liverpool, L31 8BX
Information we may collect from you
We may collect, process, store and use your personal and/or professional contact details for the purpose of contacting and corresponding with you with regards to our services, as well as the contact details for any organisation that you represent. We deem these uses of your data to be necessary for our legitimate interests as an organisation providing various recruitment and career consultancy services to you:
Personal details including your name, address, contact details (mobile phone number, telephone number, email address, social media addresses);
Relevant information from your Curriculum Vitae (or CV) including sensitive information such as criminal convictions, as well as financial information;
Relevant and reasonably expected information such as emergency contact details, reference contact details, National Insurance details;
Information that you provide by registering on our web site to access the complete interactive features of, or by filling in forms on the COYNE RECRUITMENT LIMITED site (our site). This includes information you may be asked to provide when subscribing to our service, registering as a candidate, posting material or requesting further
services. We also receive information when you interact with our site, such as by adding contacts, updating your profile, uploading your CV or joining groups. We may also ask you for information when you enter a competition or promotion sponsored by us, and if you report a problem with our site.
How we process your information
Your information is processed by COYNE RECRUITMENT LIMITED as follows:
To enable you to submit your CV and details to specific job applications as well as general applications and job alerts
To enable COYNE RECRUITMENT LIMITED to identify and match your details and experience with suitable vacancies and share your CV and personal details and sensitive data with clients as part of the job application process
If you contact us, we may keep a record of that correspondence
We may also ask you to complete surveys that we use for research purposes, although you do not have to respond to them.
Details of job applications you may have made; remuneration and other benefits details and interview information, including the outcome.
Details of your visits to our site including, but not limited to, traffic data, location data, weblogs and other communication data, whether this is required for our own purposes or otherwise and the resources that you access.
To enable COYNE RECRUITMENT LIMITED to assist with your career management and job search we may need to disclose your information (personal and sensitive) to trusted third parties.
Information could include that which enclosed on your CV and Sensitive Personal Data where your financial and criminal background may form an essential party
of the recruitment process i.e. apply for a position in a financial services business regulated by a third party regulatory such as the Prudential Regulatory Authority.
Where permitted and requested to do so by the Law we may disclose your personal information to regulatory or law enforcement agencies. We could seek further consent to hold, process and release your personal information for any other purpose not stated above.
We may collect information about your computer, including where available your IP address, operating system and browser type, for system administration and as a consequence of the communications standards on the internet. This is statistical data about our users’ browsing actions and patterns and does not identify any individual.
Where we store your personal data
servers. We are committed to protecting the security of your personal information and we use a variety of security technologies and procedures to help protect your personal information from unauthorised access, use or disclosure. Unfortunately, the transmission of information via the internet is never 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. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
Uses made of the information
We use information held about you in the following ways:
To ensure that content from our site is presented in the most effective manner for you and for your computer and to enable us continually to improve the on-line experience;
To provide you with information, job vacancies, information about recommended jobs (job alerts), recruitment services, other products or services that you request from us or which we feel may interest you, and in continuing to use our site you give consent to be contacted for such purposes;
To allow you to participate in interactive features of our site, such as sending messages to your contacts or joining and communicating within groups, when you choose to do so;
To notify you about recommended groups, blogs or content;
To notify you about any changes to our service or these terms.
If you are an existing registered user, we will only contact you with information about services or promotional material similar to those for which you have already subscribed. If you are a new registered user, and where we permit selected third parties to use your data, we (or they) will contact you only if you have consented to this. You can change your level of consent at any time by visiting your consent settings on our website.
If you do not want us to use your data in this way, or to pass your details on to third parties for marketing or employment purposes, please let us know directly at firstname.lastname@example.org
We may store and use your data, for recruitment activities, to record conversations and meetings and/or to marketing our services to you. If we have engaged with you and provided assignments and/or any scope of works we will keep your file and details of such services executed for six years to comply with statutory obligations such as The Conduct of Employment Agencies and Employment Business Regulations 2003. We are required by law to hold your personal data and your sensitive data for as long as is reasonable and necessary to comply with our statutory duties. We will use reasonable endeavours to ensure your data is maintained and up to date. You must inform us of any changes to your data to enable us to ensure that it is up to date.
Disclosure of your information
We may disclose your personal information to any member of our group, which means our subsidiaries, our ultimate holding company, and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006. We may disclose your personal information to third parties:
In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets.
If COYNE RECRUITMENT LIMITED or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
If required by law, by any governmental or regulatory body (including, without limitation, HMRC or other tax authority) or by a Court or other authority of competent jurisdiction.
In the course of matching you with recommended job opportunities or third party associated service providers.
Your rights and our lawful basis for processing your information
Under the GDPR you have increased rights and we, COYNE RECRUITMENT LIMITED must establish a lawful basis for processing your information. Article 6(1) says we can process your data where it “is necessary for the purposes of the legitimate interests pursued by [us] or by a third party, except where such interests are overridden by the interests or fundamental rights of freedoms of [you] which require protection of personal data”. We believe that our recruitment activities and collection, storage
and use of your personal data does not prejudice you in any way and allows us to offer an enhanced, more tailored and relevant service for your ultimate benefit (our clients and ours). We have a legitimate interest in processing your information to enable us to provide recruitment services and marketing activities and on balance believe the impact to you, the data subject, is minimal and in fact reasonable and expected as part of our service provision.
Given the nature of our work, as a candidate, we believe it is reasonable for us to collect, store and use your data for the provision of recruitment services if you have previously registered with us, attended an interview, been telephone interviewed by us, been placed in a new job, or agreed we can keep your details on file. We also feel that if you are looking for employment and posted your CV on professional networking sites or job boards, you are happy for us to collect and use your personal data to offer and / or provide recruitment services to you, share that information with prospective employers and assess your CV against our portfolio of opportunities. It is also reasonable to expect a future employer, once you have accepted an offer, to want to check information you've provided to us including references, qualifications, criminal records, your financial health to the extent this is appropriate and in accordance with local laws. We must do these things so we can function as a profit-making business and to help you find work. It is reasonable for us to wish to provide you with tailored job recommendations and relevant employment/recruitment/industry articles to aid your job search. We think it is reasonable to process and store your data to make sure we only supply relevant content. We may also use your data for internal administrative duties such as payroll and invoicing when and where appropriate.
We are required by law to hold your information for as long as is reasonable and necessary to comply to statutory and contractual obligations and in accordance with our legitimate interests as a data controller. You have rights under the GDPR including:
Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it;
Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected;
Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below);
Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct
Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it;
Request the transfer of your personal information to another party.
If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact the DPO.
We keep a record of when and how we received your consent, recording exactly what you have consented to. We look to regularly review our consents to check that the processing and purposes have not changed.
In addition to these rights, you, the individual (the data subject), also has the right to know:
The identity and contact details of the data controller (COYNE RECRUITMENT LIMITED) and, where applicable, the data controller’s representative, as well as the identity and contact details of the Data Protection Officer.
The Data Protection Officer may be employed by the recruitment company, or may be an external consultant
The purpose of the processing and the lawful basis for the processing
The legitimate interests of the controller or third party, where applicable
The categories of personal data
Any recipient or categories of recipients of the personal data
Transfers to third country and safeguards
Retention period or criteria used to determine the retention period
The right to lodge a complaint with a supervisory authority
The source the personal data originates from and whether it came from publicly accessible sources, such as LinkedIn
Whether the provision of personal data is part of a statutory or contractual requirement or obligation and possible consequences of failing to provide the personal data
The existence of automated decision making, including profiling and information about how decisions are made, the significance and the consequence.
You have the right to review and make any desired changes to the personal data you provide to us. You also 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. You can exercise your right to prevent such processing by ticking certain boxes on the forms we use to collect your data.
You can also exercise the right at any time by contacting us at email@example.com. 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.
If you are an employee
If we employ you, we collect information about you and your work from time to time throughout the period of your employment. This information will be used only for purposes directly relevant to your employment. After your employment has ended, we will keep your file for six years to comply with statutory obligations.
If you are a supplier
We may collect, store and use your personal and/or professional contact details for the purpose of contacting and corresponding with you, as well as the contact details for any organisation that you represent. We may also hold confidential details about any services that you may supply to us, as well as your bank account and/or other payment details in order to pay your fees and comply with statutory obligations.
Right to withdraw consent
When you register with Coyne Recruitment Limited, you provided consent to us to process your personal information for the purposes of the recruitment. You have the right to withdraw your consent for processing for that purpose at any time. To withdraw your consent, please contact the DPO. Once we have received notification that you have withdrawn your consent, we will no longer process your data and, subject to our retention policy, we will dispose of your personal data securely.
You can withdraw your consent at any time by contacting the Data Protection Officer at firstname.lastname@example.org
Data Retention - how long will you use my information for?
We retain your personal information for that period so that we can show, in the event of a legal claim, that we have not discriminated against candidates on prohibited grounds and that we have conducted the recruitment exercise in a fair and transparent way. We retain your personal information on file for this period of time, on the basis that a further opportunity may arise in future and we may wish to consider you for that opportunity. After this period, we will request consent to continue representing you or securely destroy your personal information.
Where we refere to “meaningful contact”, we mean, for example, communication between us (either verbal or written), or where you are actively engaging with our services - online, by email, by telephone, by SMS or over social media sites. Specifically, if you are a candidate we consider the receipt of your CV as meaningful contact. 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 only occurs
where you click-through or reply.
You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making.
Access to information and Subject Access Requests (SARs)
The GDPR gives you the right to access information held about you. Your right of access can be exercised in accordance with the GDPR. We will comply with all requests within 30 days from access to information being requested. If the request for information is excessive or manifestly unfounded we retain the right to refuse the request or levy a charge for providing the information. If we refuse you the right to access information you have the right to complain to the supervisory authority and to a judicial remedy.
The right to complain
Under the GDPR you have the right to complain to the Information Commissioner's Office (ICO) if you think there is a problem with the way we handle your data.