Trinnovo Group (”We”) are committed to protecting and respecting your privacy. Any mention of “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 notice and any other documents set out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Data Protection Legislation Even though the UK left the EU, the GDPR is still applicable in the UK. The Government intends for the GDPR to continue in UK law post Brexit and has therefore enforced the Data Protection Act 2018 and UK GDPR. (a) Data Protection Act 2018 and UK GDPR; (b) the General Data Protection Regulation (EU) 2016/679; (c) the Privacy and Electronic Communications (EC Directive) Regulations 2003 (as may be amended by the proposed Regulation on Privacy and Electronic Communications); and (d) any legislation that replaces or converts into United Kingdom law, UK GDPR, the General Data Protection Regulation (EU) 2016/679, the proposed Regulation on Privacy and Electronic Communications or any other law relating to data protection, and the processing of personal data and privacy resulting from the United Kingdom leaving the European Union. 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. 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 Trinnovo Group Ltd / Broadgate Search Ltd / Trust in Soda Ltd / BioTalent Ltd / Ex-Military Careers of 52 Bedford Row, London, WC1R 4LR.
Our nominated UK Data Protection Officer is Hayley Harkins of Trinnovo Group. Email – firstname.lastname@example.org Our nominated EU Representative is Adam Brogden of Instant EU GDPR Representative Ltd. Email - email@example.com 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 business). We collect the personal data of the following types of people to allow us to undertake our business; • Prospective and placed candidates for permanent or temporary roles; • Prospective and live client contacts; • Supplier contacts to support our services; and • Employees, consultants, temporary workers We collect information about you to carry out our core business and ancillary activities. Information you give to us or we collect about you Personal Information is obtained in many ways including interviews, correspondence, by telephone and facsimile, by email, via one of our websites, from media and publications, from other publicly available sources and third parties. We don’t guarantee website links or policy of authorised third parties. It includes information you provide when you register to use our site, to enter our database, subscribe to our services, attend our events, participate in discussion boards or other social media functions. 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 and personal recommendations. Purposes of the processing and the legal basis for the processing We use information held about you in the following ways: To carry out our obligations arising from any contracts we intend to enter into or have entered into between you and us and to provide you with the information, products and services that you request from us or we think will be of interest to you because it is relevant to your career or to your organisation. To provide you with information about other goods and services we offer that are similar to those that you have already been provided with or enquired about. The core service we offer to our candidates and clients is the introduction of candidates to our clients for the purpose of temporary or permanent engagement. However, our service expands to supporting individuals throughout their career and to supporting businesses’ resourcing needs and strategies. Our legal basis for the processing of personal data is our legitimate interests, described in more detail below, although we will also rely on contractual obligations to which you are subject, legal obligations and consent for specific uses of data. We will rely on contractual obligations 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.
Our Legitimate Interests
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 marketing purposes or if we intend to disclose your information to any third party for marketing purposes. We will collect express consent from you, if legally required, prior to using your personal data for marketing purposes. 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 right to: • 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 marketing purposes. • 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 in certain formats, if practicable. Access to information The Data Protection Act 2018 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. A subject access request should be submitted to the relevant Data Protection Officer (as listed above). No fee will apply unless the requests from a data subject are manifestly unfounded or excessive, in particular because of their repetitive character. In such circumstances, we may charge a fee or refuse to act on the request. Changes to our privacy notice Any changes we make to our privacy notice in the future will be posted on our website and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our privacy notice. Contact Questions, comments and requests regarding this privacy notice are welcomed and should be addressed to Hayley Harkins on firstname.lastname@example.org Complaints If you are unhappy with the way in which your personal data has been collected, stored or processed please contact the Data Controller using the contact details above. If you remain dissatisfied, then you have the right to apply directly to the Information Commissioner for a decision.
The Information Commissioner can be contacted by telephone on 0303 123 1113 or via their online notification system at www.ico.org.uk/concerns. Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF.
Version History Version Date Description Amended by Approved by 1.0 25/10/18 Notice Created Ellen Chamberlain John Miller 1.1 01/08/20 Notice updated Hayley Harkins DJ Marker 1.2 11/02/21 Notice updated Hayley Harkins DJ Marker 1.3 26/02/21 Notice updated Hayley Harkins DJ Marke