The Company is a recruitment business which provides work-finding services to its clients and work-seekers. The Company must process personal data (including sensitive personal data) so that it can provide these services – in doing so, the Company acts as a data controller.

You may give your personal details to the Company directly, such as on an application or registration form or via our website, or we may collect them from another source such as a jobs board. The Company must have a legal basis for processing your personal data. For the purposes of providing you with work-finding services and/or information relating to roles relevant to you, we will only use your personal data in accordance with the terms of the following statement.

Collection and use of personal data

Purpose of processing and legal basis

The Company has collected your personal data (which may include sensitive personal data) and will process your personal data for the purposes of providing you with work-finding services. The legal bases we rely upon to offer these services to you are:

• Express Consent – your permission to process your personal data to enable us to find employment on your behalf.

• Legitimate Interest – It will be necessary to process your data for the performance of a contract and to provide work seeking services

• Contractual Obligation – certain recruitment frameworks that we are appointed to and contracts with hirers require us to store certain information for set time periods

• Legal Obligation – we are required to store information under a Legal Obligation for statutory organisations including HMRC

FUTURE EMPLOYMENT DATA LIFECYCLE

Candidates that register with Future Employment either directly or via a 3rd Party will pass through the following status during their tenure. Their status and the basis for which we hold and process their data as well as the basis on which we hold that information will develop through the data lifecycle as the table below illustrates:

STATUS	EXPRESS CONSENT	CONTRACTURAL OBLIGATION	LEGAL OBLIGATION	LEGITIMATE INTEREST
Candidates Newly Registered     Third Party Registrations   Retention Period 24 Months	Consent Form	X	X	As Future Employment Ltd are going to provide work-seeking services based on their application or registration with a 3rd party. This will be alongside an Express Consent request.
Ex-starters   Retention Period 7 years from the end of last assignment	X	Recruitment Frameworks   Client (Hirer) Contracts Neutral Vendor or Managed Service Providers acting on behalf of a hirer	HMR&C   Statutory Organisations	Provided with work seeking services
Temporary Workers   Retention Period – ongoing in order to fulfill our work seeking and payroll services	X	Recruitment Frameworks   Client (Hirer) Contracts Neutral Vendor or Managed Service Providers acting on behalf of a hirer	HMR&C   Statutory Organisations	Payroll to process payments and work-seeking services
Placed Candidate   Retention Period – 6 years from placement start date in order to satisfy any requirements under contractual blame	X	Client Contracts and Future Employment Terms of Business	Statutory Obligation	As Future Employment Ltd are going to or have provided work-seeking services
Interviewed Candidate   Retention Period – 6 years from placement start date in order to satisfy any requirements under contractual blame	X	Client Contracts   Terms of Business	X	As Future Employment Ltd are going to or have provided work-seeking services

Categories of data

The Company has collected the following personal data on you:

Personal data:

• Name
• Address
• Email address
• Telephone number
• CV and work history as well as additional information contained within the CV or Registration Form

 Legitimate interest

Where the Company has relied on a legitimate interest to process your personal data our legitimate interests is as follows:

• The provision of work seeking services following an application or CV submission

Recipients of data

The Company will process your personal data and/or sensitive personal data with the following recipients:

• Clients seeking permanent or temporary staff relevant to your profession and location
• 3rd Parties in the execution of payroll and compliance for temporary workers including Neutral Vendor or Managed Service Providers

 Data retention

The Company will retain your personal data only for as long as is necessary. Different laws require us to keep different data for different periods of time.

The Conduct of Employment Agencies and Employment Businesses Regulations 2003, require us to keep work-seeker records for at least one year from (a) the date of their creation or (b) after the date on which we last provide you with work-finding services.

We must also keep your payroll records, holiday pay, sick pay and pension’s auto-enrolment records for as long as is legally required by HMRC and associated national minimum wage, social security, and tax legislation.

Where the Company has obtained your consent to process your personal data, we will do so in line with our retention policy.  Upon expiry of that period, the Company will seek further consent from you. Where consent is not granted the Company will cease to process your personal data and sensitive personal data.

Your rights

Please be aware that you have the following data protection rights:

• The right to be informed about the personal data the Company processes on you;
• The right of access to the personal data the Company processes on you;
• The right to rectification of your personal data;
• The right to erasure of your personal data in certain circumstances;
• The right to restrict processing of your personal data;
• The right to data portability in certain circumstances;
• The right to object to the processing of your personal data that was based on a public or legitimate interest;
• The right not to be subjected to automated decision making and profiling; and
• The right to withdraw consent at any time.

Where you have consented to the Company processing your personal data and sensitive personal data, you have the right to withdraw that consent at any time by contacting our Managing Director, Regan Stewart regan@future-employment.co.uk or our Data Controller, Emma Williams  emma.williams@future-emplpoyment.co.uk who handles data protection issues.

Source of the personal data

The Company sourced your personal data/sensitive personal data by the following means:

• Direct Communication
• Future Employment Website
• Job Boards
• CV Libraries
• Team Agency
• Social Media Platform such as LinkedIn

This information came from a publicly accessible source.

Complaints or queries

If you have any questions about this Fair Processing Notice or any of the procedures set out in it please contact our Managing Director, Regan Stewart: regan@future-employment.co.uk or our Data Controller, Emma Williams: emma.williams@future-employment.co.uk who handle data protection issues.

You also have the right to raise concerns with Information Commissioner’s Office on 0303 123 1113 or at https://ico.org.uk/concerns/, or any other relevant supervisory authority should your personal data be processed outside of the UK, if you believe that your data protection rights have not been adhered to.