We collect and process your personal data in order to facilitate the receipt of services from you as one of our Suppliers.
What information do we collect?
- Full Name
- Job Role
- Email Address
- Phone Number
- Company Bank Details
- Business information i.e. Company registration details
- A log of our communications with you by email and telephone
- IP Address, should you sign a contract with us electronically
How do we collect your information?
We collect your data when individuals:
- are designated by their employer as our contacts for the purpose of providing services to Saragossa, for managing the service relationship, processing and paying invoices;
- contract to supply services to Saragossa; or
- otherwise provide Saragossa or a Saragossa employee with their contact details or other personal data.
How do we use your information?
We use your data to:
- enquire about your produces and/or services;
- instruct our suppliers and service providers;
- compensate you for your services;
- comply with any legal and regulatory requirement.
Our basis for processing your data
As a recruitment consultancy we introduce Candidates to Clients for permanent employment or contract opportunities.
As part of conducting our day to day operations we rely on the personal data of our suppliers (and potential suppliers) to assist in delivering these operations.
This is our legitimate interest for processing your data.
We may also rely on the following bases, depending on our relationship status:
Contract – if we have a contractual relationship through your supplying us with goods and/or services then this will change our basis for processing your data.
Legal Obligation – if we use your business for the supply of goods and/or services then we will have certain legal obligations which will impact our basis for processing your data.
Who we share your data with
In order to provide you with our services and meet our compliance obligations, both contractually and legally we will need to share your data with certain third parties who process your data on our behalf.
- Various third party providers including: our candidate management platform, email provider, cloud storage provider, email security provider and client recruitment platforms;
- When you accept a Contract placement with us this list will expand to include our timesheet system, our accountant, financial and banking systems;
- Prospective employers or engagers;
- Other recruitment companies or intermediaries involved in managing the supply of personnel;
- A professional association or registration body or regulatory or law enforcement agencies if Saragossa is required by law to do so.
- For example, upon accepting and performing against a Contractor contract we are obliged to inform HMRC of certain personal data on a quarterly basis via HMRC Intermediary Reporting.
There will be occasions where your personal data is shared with third parties operating outside the EU and EEA.
We require minimum standards of confidentiality and data protection from such third parties. To the extent that any personal information is provided to third parties outside the EEA, or who will access the information from outside the EEA, we will ensure that approved safeguards are in place, such as the approved Model Clauses or the EU/US Privacy Shield.
How long do we keep your information for?
We will only retain your personal data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting or reporting requirements. To determine the appropriate retention period for personal data, we consider the amount nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirement.
We maintain detailed policies and procedures regarding how and for how long we retain your personal data.
What are your rights?
You have certain, specific rights with respect to how we process your data. Saragossa is committed to ensuring that your rights are protected.
The GDPR sets out the following rights applicable to data subjects:
- The Right to be Informed
- The Right of Access
You may request access to a copy of your personal data by contacting us on the details below.
- The Right to Rectification
You may ask us to rectify inaccurate information held about you. We will also get in touch with you periodically to ensure that we hold the correct details and most up to date version of your information i.e. your CV.
- The Right to Erasure
You may ask us to delete your personal data. We may not be able to erase your personal data if there is an overriding contract/legal basis for retaining it, but we will let you know this reason in response to your request. Please note that in the event you wish to exercise these rights, we may be unable to process any applications (including those in-flight).
- The Right to Restrict Processing
You may ask us to restrict the processing of your personal data, and we will comply when one of the following applies
- you are contesting the accuracy of your personal data that we hold, while we verify the accuracy of your personal data;
- the way we are processing the personal data is unlawful and you oppose the erasure of the personal data and request the restriction of their use instead;
- we no longer need the personal data for the purposes of the processing, but you need the personal data to establish, exercise or defend legal claims; or
- you have objected to processing in the public interest or in relation to our legitimate interest, pending the verification whether any legitimate grounds we may have override your right.
While you have restricted its processing, we will only store your personal data in question, and may process it only with your consent or to establish, exercise or defend legal claims or protect the rights of another natural or legal person or for reasons of important public interest. We will notify you before lifting the processing restriction.
- The Right to Data Portability
You may ask us to provide you with the personal information that we hold about you in a structured, commonly used, machine-readable format, or ask us to send such information to another data controller, where:
- the processing is based on consent or on a contract; and
- the processing is carried out by automated means.
Where technically feasible, we will transmit your personal data directly to the other controller.
- The Right to Object
You have the absolute right to object to the processing of your data in relation to direct marketing. You can also object to Saragossa processing your data in connection with our legitimate purpose.
- Rights with respect to Automated Decision-Making and Profiling
You have the right not to be subject to a decision based solely on automated processing, including profiling. At present all of our decisions involve human decision-making.
- Right to lodge a complaint with your data protection supervisory authority
In the event you believe that we are processing your personal data otherwise than in accordance with the provisions of the GDPR, you have the right to lodge a complaint with the data protection supervisory authority located in the EU jurisdiction where you reside. For the UK, the supervisory authority is the UK Information Commissioner’s Office.
Saragossa does not knowingly collect information from children under the age of 16 and Saragossa does not target its Website or any of its services to children under the age of 16.
Security and Data Storage
At Saragossa we are committed to protecting the information you provide to us. To prevent unauthorised access or disclosure, to maintain data accuracy, and to ensure the appropriate use of the information, Saragossa has in place appropriate technological and operational procedures to safeguard the information we collect.
This policy was last amended on 10 May 2019.
How you can contact us
- By email at email@example.com; or
- By post at Saragossa Limited, 11-12 Queen Square, Bristol, BS1 4NT.
- By phone at 0207 871 3666