John Ross Associates (”We”) are committed to protecting and respecting your privacy.

We know it can be confusing and sometimes worrying when you are asked for personal details, so we want to reassure you and be clear as to what data we take, why we take it, how we deal with it and most importantly how we protect it.

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)

1. Introduction

This Policy sets out the obligations of John Ross Associates, a company registered in England & Wales as a sole trader, whose registered office is at 11 Oldbury Court Drive, Bristol, BS16 2JW (“the Company”) regarding data protection and the rights of our staff, candidates, clients and business contacts in respect of their personal data under Data Protection Law.

“Data Protection Law” means all legislation and regulations in force from time to time regulating the use of personal data and the privacy of electronic communications including, but not limited to, the retained EU law version of the General Data Protection Regulation ((EU) 2016/679) (the “UK GDPR”), as it forms part of the law of England and Wales, Scotland, and Northern Ireland by virtue of section 3 of the European Union (Withdrawal) Act 2018, the Data Protection Act 2018, the Privacy and Electronic Communications Regulations 2003 as amended, and any successor legislation.

This Policy sets the Company’s obligations regarding the collection, processing, transfer, storage, and disposal of personal data. The procedures and principles set out herein must be always followed by the Company, its employees, agents, contractors, or other parties working on behalf of the Company.

This notice together with our terms of business sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us.

For the purposes of data protection legislation in force from time to time the data controller is John Ross Associates of 11 Oldbury Court Drive, Bristol, BS16 2JW.

Our nominated Data Protection Officer is John Ross – Director.

1. 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
• Employees, consultants, temporary workers

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

1. Information you give us, or we collect about you

 This is information about you that you give us by filling in forms on our website:  www.johnrossassociates.co.uk (our site) or by corresponding with us by social media, direct marketing, phone, email or otherwise.

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 on our site, enter a competition, promotion, or survey, and when you report a problem with our site.

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., social media platforms, event literature or corporate website.

Some of the personal data that we collect is more sensitive and needs higher protection. Under UK GDPR these are known as ‘special categories of personal data’ and includes information about a person’s:

• Race
• Ethnicity
• Political views
• Religion, spiritual or philosophical beliefs
• Biometric data for ID purposes
• Health data
• Sex life data
• Sexual orientation
• Genetic data

It is anticipated that the only Special Categories of Personal Data required from a job seeker will be for the purposes of Health Screening in very specific circumstances, in accordance with our Equality, Diversity and Inclusion Statement (please refer to our company website) where it will be anonymised and were authorised by law or criminal record checks.

Consent will always be sought prior to this data being stored and processed.

1. Information we collect about you when you visit our website

With regards to each of your visits to our site we will automatically collect the following information:

Technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information if applicable, browser type and version.

Information about your visit, including the full Uniform Resource Locators (URL), page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs).

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 allows us to improve our site. Users are advised that if they wish to deny the use and saving of information from our website to their computer’s hard-drive they should take the necessary steps within their web browser’s security settings to block all cookies from this website and external vendors or use the cookie control system available on your first visit.

1. Information we obtain from other sources

This is information we obtain about you from other sources such as social media platforms, corporate websites, job board websites, online CV libraries, your business card, and personal recommendations. In this case we will inform you, by sending you this privacy notice, 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 companies within our Group, business partners, sub-contractors in technical, professional, payment and other services, advertising networks, analytics providers, search information providers, credit reference agencies and professional advisors in some cases. We may receive information about you from them for the purposes of our recruitment services and ancillary support services.

1. 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 or have entered between you and us and to provide you with the information 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 services we offer that are similar to those that you have already purchased, 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 supporting businesses’ resourcing needs, onboarding, benchmarking, trends, analysis, and wider strategic advice.

 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 you to fulfil our legal obligations.

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

1. Our Legitimate Business Interests

Our legitimate interests in collecting and retaining your personal data are 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.

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

1. 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/digital 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 specific processing at any time.

1. Other uses we may use your data for

• Use of our website
• To notify you about changes to our service
• To ensure that content from our site is presented in the most effective manner for you and for your computer

We will use this information:

• To administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes
• To improve our site to ensure that content is presented in the most effective manner for you and for your computer
• To allow you to participate in interactive features of our service, when you choose to do so
• As part of our efforts to keep our site safe and secure
• To measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you
• To make suggestions and recommendations to you and other users of our site about goods or services that may interest you or them

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.

1. Disclosure of your information inside and outside of the EEA (European Economic Area)

We may, from time to time, need to share your personal information with a member of our group both in the EEA and outside of the EEA.

Selected third parties including:

• Clients for the purpose of introducing candidates to them
• Candidates for the purpose of arranging interviews and engagements
• Clients, business partners, suppliers and sub-contractors for the performance and compliance obligations of any contract we enter with them or you
• Subcontractors including email marketing specialists, event organisers, payment and other financial service providers
• Analytics and search engine providers that assist us in the improvement and optimisation of our site
• Credit reference agencies, our insurance broker, compliance partners and other sub-contractors for the purpose of assessing your suitability for a role where this is a condition of us entering into a contract with you

We will disclose your personal information to third parties:

• In the event that we sell or buy any business or assets, in which case we will disclose your personal data to the prospective seller or buyer of such business or assets
• If John Ross Associates or substantially all 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 we are under a duty to disclose or share your personal data to comply with any legal obligation, or to enforce or apply our terms of use or terms and conditions of supply of services and other agreements; or to protect the rights, property, or safety of John Ross Associates, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction

The lawful basis for the third-party processing will include:

• Their own legitimate business interests in processing your personal data, in most cases to fulfil their internal resourcing needs
• Satisfaction of their contractual obligations to us as our data processor
• For the purpose of a contract in place or in contemplation
• To fulfil their legal obligations

1. Where we store and process your personal data

The data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (”EEA”). It may be transferred to third parties outside of the EEA for the purpose of our recruitment services. It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers.

This includes staff engaged in, among other things, our recruitment services, and the provision of support services. By submitting your personal data, you agree to this transfer, storing or processing. John Ross Associates will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy notice. 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.

1. 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 data retention guidelines 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:

• Prior to making an introduction we check that we have accurate information about you
• We keep in touch with you so you can let us know of changes to your personal data

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:

• The nature of the personal data
• Its perceived accuracy
• Our legal obligations
• Whether an interview or placement has been arranged
• Our recruitment expertise and knowledge of the industry by country, sector and job role

 We may pseudonymise parts of your data, particularly following a request for suppression or deletion of your data, to ensure that we do not re-enter your personal data onto our database, unless requested to do so.

Pseudonymised data is created by taking identifying fields within a database and replacing them with artificial identifiers, or pseudonyms.

Due to the nature of operating as a recruitment business, John Ross Associates works with candidates for the entire duration of their working life and John Ross Associates supports businesses through all growth stages, for the duration of a business’s existence. For this reason, the default data retention duration for candidates is the duration of a professional’s working life and for clients/ businesses, the duration of the business’s existence. John Ross Associates retains details until advised otherwise or until advised that the individual has now retired, left a business (as in, is no longer with the business that is John Ross Associates’ client) or the business has ceased to trade.

1. 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 also exercise this right at any time by contacting us at 11 Oldbury Court Drive, Bristol, BS16 2JW or info@johnrossassociates.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 UK GDPR provides you with the following rights 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
• Make a complaint to a supervisory body which in the United Kingdom is the Information Commissioner’s Office. The ICO can be contacted through this link: https://ico.org.uk/concerns/

1. Access to information

We encourage you to contact us to ensure your data is accurate and complete but also the UK GDPR gives you the right to access information held about you.

You may make subject access requests (SARs) at any time to find out more about the personal data which we hold about you, what we are doing with that personal data, and why.

Responses to SARs must normally be made within one month of receipt, however, this may be extended by up to two months if the SAR is complex and/or numerous requests are made. If such additional time is required, the data subject shall be informed.

All SARs received shall be handled by our Data Protection officer.

1. Changes to our privacy notice

Any changes we make to our privacy notice in the future will be posted on this page and, where appropriate, notified to you by email. Please check back frequently to see any changes to our privacy notice.

1. Contact

Questions, comments, and requests regarding this privacy notice are welcomed and should be addressed to 11 Oldbury Court Drive, Bristol, BS16 2JW or info@johnrossassociates.co.uk

John Ross Associates is an ICO Registered Company, complying with the Data Protection Act and GDPR ready.