PRIVACY POLICY
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IT'S ABOUT YOU
We use and process your data to help you get the most out of your relationship with us – and always in compliance with the law.

SAFETY
We keep your data under lock and key – in secure and highly restricted environments.

OPENNESS
We aim to be 100% transparent with you about what data we collect and why we collect it.

CONTROL
You are in charge.  You can ask to see the data we hold for you or ask for it to be deleted. This Privacy Policy (together with our Terms of Use and any other documents referred to in it) sets out the basis on which all data that we collect from you, or that you provide to us via this Site, will be processed by us. Please read the following carefully to understand our views and practices regarding your data and how we will treat it.

‍Who is the controller of the data that you provide to us?
‍Maxwell Stephens Limited, based at Golden Cross House, 8 Duncannon Street, London WC2N 4JF is registered as a data controller in the United Kingdom for the purposes of GDPR legislation. We ensure that the data you supply to us is processed fairly and lawfully, and with skill and care and used only for the purposes set out in this policy. We provide permanent and temporary recruitment services to clients looking to recruit personnel for their businesses. We also provide payroll services for contractors.

‍What information will we collect?
‍Where the data that we collect from you or that you provide to us via this Site consists of or contains personal information, that personal information is, for the purposes of the GDPR legislation, categorised as either Personal Data or Sensitive Personal Data.

Personal Data means data which relates to a living individual who can be identified from that data, or who can be identified from that data and from any other information which is in our possession or is likely to come into our possession.

Sensitive Personal Data means personal data consisting of information as to:
the racial or ethnic origin of the data subject;
·       his/her political opinions;
·       his/her religious beliefs or other beliefs of a similar nature;
·       whether he/she is a member of a trade union (within the meaning of the Trade Union and Labour Relations (Consolidation) Act 1992);
·       his/her physical or mental health or condition;
·       the commission or alleged commission by him/her of any offence; or
·       any proceedings for any offence committed or alleged to have been committed by him/her, the disposal of such proceedings or the sentence of any court in such proceedings.

We collect and process Sensitive Personal Data only so far as is necessary and in compliance with all applicable legislation. By using the Site and by registering your details with us, you consent to us collecting and processing Sensitive Personal Data provided by you or received by us and disclosing this information to our clients in connection with the recruitment process.  

‍What use will be made of the information that we collect?
‍Your information will be stored, processed, used and disclosed by us in the following ways:
·       To provide our recruitment services to you and to facilitate the recruitment process;
·       To assess data about you against vacancies which we judge may be suitable for you;
·       To send your information to clients in order to apply for jobs or to assess your eligibility for jobs;
·       To enable you to submit your CV, apply online for jobs or to subscribe to alerts about jobs we think may be of interest to you;
·       To allow you to participate in interactive features of our service when you choose to do so;
·       To market our full range of recruitment services to you;
·       To enable us to develop and market other products and services and where you have consented to being contacted for such purposes;
·       To improve our customer service and to make our services more valuable to you (including tailoring our Site when you log on to enrich your personal online experience);
·       To send you details of reports, promotions, offers and general information about the industry sectors which we think might be of interest to you where you have consented to being contacted for such purposes;
·       To answer your questions and enquiries;
·       To third parties where we have retained them to provide services that we, you or our client have requested including references, qualifications and criminal reference checking services, verification of the details you have provided from third party sources, psychometric evaluations or skill tests;
·       To third parties, regulatory or law enforcement agencies if we believe in good faith that we are required by law to disclose it in connection with the detection of crime, the collection of taxes or duties, in order to comply with any applicable law or order of a court of competent jurisdiction, or in connection with legal proceedings;
·       To use your information on an anonymised basis to monitor compliance with our equal opportunities policy;
·       To carry out our obligations arising from any contracts entered into between you and us.

From time to time we may seek your consent to process, use or disclose your information for any other purpose not listed above.

We reserve the right to transfer your information to a third party in the event of a sale, merger, liquidation, receivership or transfer of all or substantially all of the assets of our company provided that the third party agrees to adhere to the terms of this Privacy Policy and provided that the third party only uses your data for the purposes that you provided it to us. You will be notified in the event of any such transfer and you will be afforded an opportunity to opt-out.  

‍Our legal bases for processing your data
‍Legitimate Interests
‍Article 6(1)(f) of the GDPR says that 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 or freedoms of [you] which require protection of personal data.”  

‍Candidate Data:
‍We think it’s reasonable to expect that if you are contacted us looking for employment or have posted your professional CV information on a job board or professional networking site, you are happy for us to collect and otherwise use your personal data to offer or provide our recruitment services to you, share that information with prospective employers and assess your skills against our bank of vacancies. Once it’s looking like you may get the job, your prospective employer may also want to double check any information you’ve given us or to confirm your references, qualifications and criminal record, to the extent that this is appropriate and in accordance with local laws. We need to do these things so that we can function as a profit-making business, and to help you and other candidates get the jobs you deserve.

We want to provide you with tailored job recommendations and relevant articles to read to help you on your job hunt. We therefore think it’s reasonable for us to process your data to make sure that we send you the most appropriate content.

We have to make sure our business runs smoothly, so that we can carry on providing services to candidates like you. We therefore also need to use your data for our internal administrative activities, like payroll and invoicing where relevant.

We have our own obligations under the law. If we believe in good faith that it is necessary, we may therefore share your data in connection with crime detection, tax collection or actual or anticipated litigation.  

‍Client Data:
‍To ensure that we provide you with the best service possible, we store your personal data and/or the personal data of individual contacts at your organisation as well as keeping records of our conversations, meetings, registered jobs and placements. From time to time, we may also ask you to undertake a customer satisfaction survey. We think this is reasonable – we deem these uses of your data to be necessary for our legitimate interests as an organisation providing various recruitment services to you.  

‍Supplier Data:
‍We use and store the personal data of individuals within your organisation in order to facilitate the receipt of services from you as one of our suppliers. We also hold your financial details, so that we can pay you for your services. We deem all such activities to be necessary within the range of our legitimate interests as a recipient of your services. People whose data we receive from candidates and staff, such as referees and emergency contacts:

If you have been put down by a candidate or a prospective member of staff as one of their referees, we use your personal data in order to contact you for a reference. This is a part of our quality assurance procedure and so we deem this to be necessary for our legitimate interests as an organisation offering recruitment services and employing people ourselves.
If a candidate or staff member has given us your details as an emergency contact, we will use these details to contact you in the case of an accident or emergency. We are sure you will agree that this is a vital element of our people-orientated organisation, and so is necessary for our legitimate interests.  

‍Consent
‍In certain circumstances, we are required to obtain your consent to the processing of your personal data in relation to certain activities. Depending on exactly what we are doing with your information, this consent will be opt-in consent.
Article 4(11) of the GDPR states that (opt-in) consent is “any freely given, specific, informed and unambiguous indication of the data subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.” In plain language, this means that:
–          you have to give us your consent freely, without us putting you under any type of pressure;
–          you have to know what you are consenting to – so we’ll make sure we give you enough information;
–          you should have control over which processing activities you consent to and which you don’t.
–          you need to take positive and affirmative action in giving us your consent – we’re likely to provide a tick box for you to check so that this requirement is met in a clear and unambiguous fashion.

We will keep records of the consents that you have given in this way.

We have already mentioned that, in some cases, we will be able to rely on soft opt-in consent. We are allowed to market products or services to you which are related to the recruitment services we provide as long as you do not actively opt-out from these communications.

As we have mentioned, you have the right to withdraw your consent to these activities which you can do so at any time.  

‍Establishing, Exercising or Defending Legal Claims
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‍Sometimes it may be necessary for us to process personal data and, where appropriate and in accordance with local laws and requirements, sensitive personal data in connection with exercising or defending legal claims. Article 9(2)(f) of the GDPR allows this where the processing “is necessary for the establishment, exercise or defence of legal claims or whenever courts are acting in their judicial capacity”.
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This may arise for example where we need to take legal advice in relation to legal proceedings or are required by law to preserve or disclose certain information as part of the legal process.

‍Where will my information be held? Where will it be accessible from?
‍The personal information that you provide to us may be accessible by clients and the third parties specified above. Some of these clients and third parties may be located outside of the European Economic Area. Accordingly your personal information may be sent to or be capable of being accessed from outside the European Economic Area. When we transfer your personal information outside the European Economic Area we will take steps with the aim of ensuring that your privacy rights continue to be protected as outlined in this Privacy Policy.  

How do I find out what information you hold? Can I amend, modify or require my information to be deleted? Can I unsubscribe to your services?
‍You may request us to confirm what information we hold about you at any time and may request us to modify, update or delete such information. We may ask you to verify your identity and for more information about your request. We also have the right to charge an administrative fee for this service. Where we are legally permitted to do so, we may refuse your request and will give you reasons for doing so. We will seek to act on your request in the timescale required by applicable GDPR laws. You may request to unsubscribe from job alerts and marketing material at any time. If you wish to contact us with respect to the above matters please email us at info@maxwellstephens.com.  

‍How long will you hold my information for?
‍We are required by law to hold your information for as long as is necessary to comply with our statutory and contractual obligations and in accordance with our legitimate interests as a data controller. We will use reasonable endeavours to ensure that your personal information is maintained and up to date. However, you are under a duty to inform us of any and all changes to your personal information to ensure that it is up to date and we will update or delete your personal information accordingly.

‍Sending us information over the internet Your information is held on servers hosted by us or our Internet Service Provider. The transmission of information via the internet is not completely secure. Although we will do our best to protect your data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk.  

‍How we collect and aggregate information about visitors to our Site
‍We also collect information about the way job seekers and visitors use this Site in order to improve our services. We do not use information gained in this manner in a way that any individual can be identified, and will use it to understand our users better, and to determine aggregate trends, most popular pages etc. for all the Site’s users. We may share this kind of aggregate data with selected third parties to assist with these purposes where you have consented to this. We may also undertake marketing profiling to help us identify services or jobs which may be of interest to you.  

Cookies

‍What are cookies?
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A “cookie” is a piece of information that is stored on your computer’s hard drive and which records your navigation of a website so that, when you revisit that website, it can present tailored options to you based upon the stored information about your last visit. You can normally alter the settings of your browser to prevent acceptance of cookies.
Cookies are used by nearly all websites and do not harm your system.  

‍How do we use cookies?
We use “cookies” to:
(1) monitor site user traffic patterns and site usage. This helps us to understand how our users use our Site so that we can develop and improve the design, layout and functionality of the Site; and
(2) to help us to advertise to you jobs we think you will be interested in.There are different kinds of cookies with different functions:Session cookies: these are only stored on your computer during your web session. They are automatically deleted when the browser is closed. They usually store an anonymous session ID allowing you to browse a website without having to log in to each page.

They do not collect any information from your computer.Persistent cookies: a persistent cookie is one stored as a file on your computer, and it remains there when you close your web browser.

The cookie can be read by the website that created it when you visit that website again. We use persistent cookies for Google Analytics (see section 6 on Google Analytics) and for personalisation cookies (see section 7 on Personalisation Cookies).The only third party cookies we use on our site are Google Analytics (please see section 6 on Google Analytics).The cookies we use are explained below:  

‍Strictly necessary cookies
These cookies are essential to enable you to use the Site effectively (such as in applying for a job) and therefore cannot be turned off. Without these cookies, the services available to you on our Site cannot be provided. These cookies do not gather information about you that could be used for marketing or remembering where you have been on the internet.  Performance cookiesThese cookies enable us to monitor and improve the performance of our Site. For example, they allow us to count visits, identify traffic sources and see which parts of the Site are most popular. We use Google Analytics for this purpose (see section 6) and all information these cookies collect is aggregated and therefore remains anonymous. These cookies do not collect information that identifies a visitor, as all information these cookies collect is anonymous and is only used to improve how our Site works.

Functionality cookies
These cookies allow our Site to remember choices you make (such as your user name, language or the region you are in) and provide enhanced features. For instance, a website may be able to provide you with news or updates relevant to the products you buy. These cookies can also be used to remember changes you have made to text size, font and other parts of web pages that you can customise. They may also be used to provide services you have requested such as viewing a video or commenting on a blog. The information these cookies collect is usually anonymised.

‍Google Analytics
This Site uses Google Analytics, a web analytics service provided by Google, Inc. (“Google”). Google Analytics uses cookies to help the website analyse how users use the Site. The information generated by the cookie about your use of the Site (including your IP address) will be transmitted to and stored by Google on servers in the United States. Google will use this information for the purpose of evaluating your use of the Site, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf. Google will not associate your IP address with any other data held by Google. By using this Site, you consent to the processing of data about you by Google in the manner and for the purposes set out above.  

‍Personalisation cookies
This Site uses personalisation cookies which help us to advertise to you jobs that we think may be of interest. These cookies are persistent (see section 2 above) and this means that when you log in or return to the Site you may see advertising for jobs that are similar to jobs that you have previously browsed.For information on how to reject these personalisation cookies, see section 8 below.  

‍How to reject cookies
Note that most web browsers will accept cookies, but if you would rather that we did not collect data in this way you can choose to accept all or some or reject cookies in your browser’s privacy settings. Rejecting all cookies means that certain features cannot then be provided to you and accordingly you may not be able to take full advantage of all of our Site’s features. Each browser is different, so check the “Help” menu of your browser to learn how to change your cookie preferences. For more information generally on cookies, including how to disable them, please refer to aboutcookies.org (http://www.allaboutcookies.org/).  

‍How To Contact Us
‍Country in which you use Maxwell Stephens’ services or supply Maxwell Stephens with services: UK
How you can get in touch with us:to access, amend or take back the personal data that you have given to us;if you suspect any misuse or loss of or unauthorised access to your personal information;to withdraw your consent to the processing of your personal data (where consent is the legal basis on which we process your personal data);with any comments or suggestions concerning this Privacy Policy You can write to us at the following address: Maxwell Stephens Recruitment, Golden Cross House, 8 Duncannon Street, London, WC2N 4JFAlternatively you can email us at info@maxwellstephens.com or by clicking the unsubscribe link in any marketing e-mail we send to you.  

‍Change to our Privacy Policy
‍Any changes to this Privacy Policy will be posted on this Site so you are always aware of what information we collect, how we use it, and under what circumstances we disclose it. If at any time we decide to use your information in a manner significantly different from that stated in this Privacy Policy, or otherwise disclosed to you at the time it was collected, we will notify you by email, and you will be able to choose whether or not we use your information in the new manner. In case of any query regarding the information on this Site, please contact info@maxwellstephens.comIntroductionThis statement sets out Maxwell Stephens Limited's actions to understand all potential modern slavery risks related to its business and to put in place steps that are aimed at ensuring that there is no slavery or human trafficking in its own business and its supply chains. As part of Maxwell Stephens’ business operations, the organisation recognises that it has a responsibility to take a robust approach to slavery and human trafficking.Maxwell Stephens is absolutely committed to preventing slavery and human trafficking in its corporate activities, and to ensuring that its supply chains are free from slavery and human trafficking