Last updated 01/11/2023
Introduction
GWV Talent Solutions Limited (”We”) is committed to protecting and respecting your privacy and we are the company responsible for your personal data as a Data Controller. We may act as a data processor or joint controller under certain circumstances.
Any mention of “We or Our Group” includes our company and our trading names of Gerrard White Consulting and Vermelo RPO, as defined in section 1159 of the UK Companies Act 2006 (our Group).
This Privacy Policy describes and sets out the basis on which any personal data we collect from you, or that you provide to us, will be used and processed by us. Your privacy is important to us and we are committed to safeguarding your data privacy rights as well as ensure that we comply with all legal obligations placed upon us.
We are subject to applicable data protection legislation including but not limited to the General Data Protection Regulation. The UK General Data Protection Regulation (UK GDPR) (Regulation (EU) 2016/679) is a regulation that replaces the Data Protection Regulation (Directive 95/46/EC). 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.
The Brexit transition period ended on 31 December 2020 and the UK has officially left the EU. The UK GDPR has been directly incorporated into UK law sitting alongside the Data Protection Act 2018.
Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. It is important to note that we reserve the right to amend this Privacy Policy from time to time. Please visit our Privacy Policy Page on our website if you want to stay up to date, we will post any changes here.
If you are dissatisfied with any aspect of our Privacy Policy and associated procedures, please contact us at compliance@gerrardwhite.com.
For the purposes of data protection legislation in force from time to time the Data Controller is GWV Talent Solutions Limited, 16 Lonsdale Gardens, Tunbridge Wells, Kent TN1 1NU.
Our Data Protection Officer is Kathryn Hunt – kathryn,hunt@gerrardwhite.com, Head of Operations and is overseen by Anthony Butler anthony.butler@gerrardwhite.com, Managing Director.
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 also provide the following other services: outsourcing, consultancy, managed service provider and/or recruitment process outsourcer. We collect the personal data of the following types of people to allow us to undertake our business;
Prospective and placed candidates for permanent, contract or temporary roles;
Prospective and live client contacts;
Supplier contacts to support our services;
Employees, contingent workers, consultants, temporary workers;
We collect information about you to carry out our core business and ancillary activities.
Candidates include individuals with whom we have not had prior contact but whom we reasonably consider would benefit from or would be interested in our services and/or to be considered for any roles being recruited for by GWV Talent Solutions including permanent, contract and temporary positions. Candidates also include applicants to any role being advertised or promoted by GWV Talent Solutions by our group or under a client’s branding as well as those parties who have suppled a speculative CV not in relation to a specific job or those that have engaged with GWV Talent Solutions about our services. Contractors, Temporary Workers and any applicants supplied by third parties put forward for roles with clients of GWV Talent Solutions (via Vermelo RPO) as part of an MSP/RPO offering will also be treated as candidates for the purposes of this policy.
Privacy Information for Candidates
The section of this Privacy Policy applies to candidates.
This is information about you that you give us by providing a CV, filling in forms on our website or email, www.gerrardwhite.com or www.vermelorpo.com, or a client’s career page managed by us or by corresponding with us by phone, e-mail or otherwise. It includes information you provide when you register to use our website, apply for a role via our own website or a client’s career page managed by us, 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 or 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
phone number
financial information
compliance documentation
references verifying your qualifications and experience
your right to work in the United Kingdom
your driving license and/or passport/identity card
national insurance number
curriculum vitae and photograph
links to your professional profiles available in the public domain
emergency contacts / next of kin information
education details
employment history
referee details and references
remuneration details (current and past)
personal interests
bank details
criminal conviction data
media searches
fitness and proprietary information
FCA register validation
FCA disciplinary validation
special category information
personal data revealing racial or ethnic origin;
personal data revealing political opinions;
personal data revealing religious or philosophical beliefs;
personal data revealing trade union membership;
genetic data;
biometric data (where used for identification purposes);
data concerning health;
data concerning a person’s sex life; and
data concerning a person’s sexual orientation.
How do we collect your personal data?
We collect your personal data in the following ways:
Personal data that you give to us;
Personal data we receive from other sources; and
Personal data that we collect automatically
Information we collect about you automatically when you visit our website
With regard to each of your visits to our site we will automatically collect the following information:
IP address
user reports
login information (if applicable)
browser type and version
browser plug-in types and versions, operating system and platform
email engagement history
Information we obtain from other sources.
This is the information we may obtain about you from other sources such as LinkedIn, corporate websites, job board websites, online CV libraries, client's career pages managed by us. your business card and personal recommendations or extra information that your referees or our clients may tell us about you.
We work closely with third parties including companies and brands 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. We may receive information about you from them for the purposes of our recruitment services and ancillary support services.
Purposes of the processing and the legal basis for the processing
We use information held about you in the following ways:
Pre-hire recruitment activities
Recruitment activities
Pre hire employment screening activities
Marketing and customer satisfaction activities
Facilitate payroll and invoicing processes
Validate identity
Assessment and screening activities
We use this data 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 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 permanent, contract or temporary engagement. However, our service expands to supporting individuals throughout their career and to supporting businesses’ resourcing needs and strategies.
In the majority of cases, we will use your personal data for the purposes above if we deem it necessary to do so for our 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.” 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.We will rely on legal obligation in some cases, where we are required by law or regulation to process your data.
We will in some circumstances rely on consent for particular uses of your data. Where we rely on consent, you will be asked for your express consent. An example of when we will rely on consent as the legal basis for processing your data is when we process your data for marketing purposes.
Our Legitimate Interests
Our legitimate interests in collecting and retaining your personal data is 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 contact details is a fundamental 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. The database will contain 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.
Special Category Data
We are fully committed to ensuring that all of our recruitment processes are aligned with our Inclusion and Diversity policies and we may process special category data to support this. Where appropriate and in accordance with all legislation, we may use this information to comply with equal opportunities policies of both GWV Talent Solutions and external client’s policies.
We may also use special category data to assess a person’s eligibility for certain types of roles as part of pre hire background screening processes including details of criminal convictions and adverse credit. This will require your additional consent.
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 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 particular processing at any time.
Other uses we will make of your data:
We will also use your data:
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 when you are using your computer or other devices;
To notify you about changes to our service;
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.
As of 1st November 2023, we do not undertake automated decision making or profiling. We 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. If automated decision making or profiling is used, we will provide information about how decisions are made, the significance and the consequences of the decision making.
As new and innovative technology becomes available, some of our systems and processing activities which use automated systems may amount to Automated Decision Making within the meaning of Article 22 of the GDPR regulations. This means a process of making a decision by automated means with limited, or even no, human intervention in reaching the decision. We will only use automated decision making in relation to your personal data where we consider this is necessary.
It may become necessary for us to process your data in reliance on the legitimate interests basis and in accordance with law in connection with defending legal claims or to comply with legal obligation at request from a law enforcement agency or regulator. 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”. This may become necessary if we need to take legal advice in relation to legal proceedings or are required by law to disclose certain information as part of a legal process.
Do you have to provide us with personal data?
You may refuse to give us your personal and sensitive personal data. Furthermore, you have the right to ask us to delete, change or stop processing your data that we have already received or collected. If you do not provide us with personal or sensitive personal data, or if you request a restriction of processing however, we may not be able to provide you with the services that you have requested and that are stated in this policy.
Privacy Information for Clients
The section of this Privacy Policy applies to clients only.
Clients includes our customers, clients and others to whom GWV Talent Solutions Limited provides services to or whom we reasonably consider would be interested in our services.
This data may include:
name
job title
telephone number
email address
information relating to your engagement with candidates
IP address
website browsing data
email engagement with GWV Talent Solutions Limited
account access information
device information
information that a candidate or your organisation may tell us about you
We collect personal data that we receive from you, that we collect and receive from other sources and personal data that we collect automatically.
We may use your personal information and client data to:
provide services
to offer services
marketing activities
defend legal claims
Our services consist of (i) providing you with candidates on a permanent, contract or temporary basis; ii) RPO services; iii) MSP services and or iv) advisory, consultancy and talent insight services.
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.”
Subject to applicable laws and requirements, we will not, as a matter of course seek your consent when sending marketing materials to a corporate postal or email address. If you are not happy about this, please notify us at compliance@gerrardwhite.com.
Third Party Suppliers
This section of the Privacy Policy applies to third party suppliers including partnerships, companies, sole traders and independent contractors and freelance workers.
In certain circumstances, we may engage third party suppliers and, in this context, suppliers who are individual contractors, freelance workers or employees of suppliers or umbrella companies, will be treated as Candidates for data protection purposes and they should refer to the Candidates section of this policy. Please note that in such circumstances, we require that the third party supplier communicates this Privacy Policy to all its employees.
Website Users
This section of the Privacy Policy applies to anyone who uses / accesses any of the GWV Talent Solutions website including www.gerrardwhite.com and www.vermelorpo.com.
We collect a limited amount of data from our website users or when you register for one of our newsletters or webinars which we use to help us to improve your experience when using our website and to help us manage or offer the services we provide.
This may include:
names
telephone number
email address
IP address
user choices
user reports
device information
account access information
any information that you may provide to us
When you visit our website, there is certain information that we will automatically collect, whether or not you decide to use our services namely your IP address, the date and the times and frequency with which you access the website, the way you browse its content and other technical information. We may also collect data from you when you contact us via the website, for example if you register for one of our newsletters, webinars or participate in any further offer of our website. We collect your data automatically via cookies or similar technology.
We may use the data collected from our website to provide you with the service you registered for or the services you participated in or help to protect our systems from attacks and other illegal activities.
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 also allows us to improve our site. For detailed information on the cookies we use and the purposes for which we use them see our Cookie notice - https://gerrard-white.staging.krakatoa.eu-2.volcanic.cloud/legal_documents/cookies
Disclosure of your information inside and outside of the UK and the EEA
Where appropriate and in accordance with legislation, we may share your personal information with:
Any member of our group both in the UK, the EEA and outside of the EEA;
Appropriate colleagues within group;
Individuals and organisations who hold information related to your reference or application such as past employers, educators or examining bodies or employment and recruitment agencies with your permission;
Tax, audit or other authorities where we believe in good faith that the law requires us to share this data;
Service providers (whether third parties or a group company) who perform functions on our behalf such as external consultants, professional advisors, lawyers, auditors or accountants or technical support.
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, service providers, suppliers and sub-contractors for the performance and compliance obligations of any contract we enter into with them or you;
Subcontractors including email marketing specialists, event organisers, payment and other financial service providers;
Outsourced IT and document storage providers where we have an appropriate processing agreement (or similar protection in place);
Marketing technology platforms;
Analytics and search engine providers that assist us in the improvement and optimisation of our site;
Credit reference agencies, our insurance broker, background screening partner, 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;
MSP / RPO suppliers as part of our clients’ programmes;
Internal and external auditors of our clients where we are required to in order to meet our compliance and regulatory obligations.
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 GWV Talent Solutions 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 we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order 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 GWV Talent Solutions Limited, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
If you are a referee of one of our candidates, we may share the information provided with:
Clients;
Internal and external auditors of our clients where we are required to in order to meet our compliance and regulatory obligations.
The lawful basis for the third party processing will include:
Their own legitimate 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.
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 UK or European Economic Area (”EEA”). It may be transferred to third parties outside of the UK or the EEA for the purpose of our recruitment services. It may also be processed by staff operating outside the UK or 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 processing. GWV Talent Solutions Limited 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. Any payment transactions will be encrypted. Where we have given you (or where you have chosen) a password that 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.
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.
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 interests and that you are happy for us to do so. We also consider the amount, nature and sensitivity of the personal data in question. Accordingly, we have a data retention policy, a copy of which is available upon request at compliance@gerrardwhite.com.
We do the following to try to ensure that the data we hold 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 include:
the nature of the personal data;
its perceived accuracy;
our legal obligations;
whether an interview or placement has been arranged; and
our recruitment expertise and knowledge of the industry by country, sector and job role
We may store and handle your data in the following ways:
We may archive part or all of your personal data, retain it on our financial systems only or delete all or part of the data from our main Customer Relationship Manager (CRM) system.
We may pseudonymise parts of your data, particularly following a request for restriction or erasure of your data, to ensure that we do not re-enter your personal data on to our database, unless requested to do so.
For your information, Pseudonymised Data is created by taking identifying fields within a database and replacing them with artificial identifiers, or pseudonyms.
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 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.
You can also exercise the right to not have your data used for marketing purposes at any time by contacting us at GWV Talent Solutions Limited, 16 Lonsdale Gardens, Tunbridge Wells, Kent TN1 1NU or compliance@gerrardwhite.com.
Our site may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliate. 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 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.
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/.
Access to information
The Data Protection Act 2018 and the UK 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 UK GDPR.
A subject access request should be submitted to compliance@gerrardwhite.com. No fee will apply and will be managed in accordance with our Data Subject Rights Procedure.
Third Party Services
In the course of offering and providing services, candidates, temporary workers, contractors or third party suppliers may wish to access independent websites and third party services which are not operated by us. Such sites are not under our control and we are not responsible for their privacy policies. You will therefore need to make your own independent judgement about whether to use such sites including whether to use their services.
Occasionally, a third party service provider that has been engaged by us, may process personal data that we have given to them as a data controller in their own right. Third party service providers are not under our control and we are not responsible for their privacy policies. You will therefore need to make your own independent judgement.
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 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 GWV Talent Solutions Limited, 16 Lonsdale Gardens, Tunbridge Wells, Kent TN1 1NU or emailed to compliance@gerrardwhite.com.