As a recruitment company McCarthy Recruitment processes personal data in relation to it own staff, candidates and individual client contacts. It is vitally important that we abide by the principles of the General Data Protection Regulations set out below.
McCarthy Recruitment holds data on individuals for the following general purposes:
The General Data Protection Regulations require McCarthy Recruitment as a data controller to process data in accordance with the principles of data protection. These require that the data shall be:
“Personal data” means data relating to a living individual who can be identified from the data, or from the data in combination with other freely available information.
“Processing” is defined as obtaining, recording or holding the data or carrying out and operation or set of operations on the data. It includes organising, adapting or amending the date. All of the data within McCarthy Recruitment will have been processed in order to be added to the database or computer network. Data processing can happen on any type of computer or digital device, this includes but is not limited to Desktop PC’s, Laptops, Tablets & Smart Phones.
Data should be reviewed on a regular basis to ensure that it is accurate, relevant and up to date and those people listed in the appendix shall be responsible for doing this.
Data may only be processed if it falls into the 2 lawful basis for processing personal data for McCarthy Recruitment these are;
Explicit Consent will apply to all marketing activity sent to you through our web database
Legitimate Business Interests will apply to all recruitment & employee activity
However, caution should be exercised before forwarding personal details of any individuals on which the data is held to any third party such as past, current or prospective employers; suppliers; customers and clients or any other third party. You must ensure you have either the candidate, client or employee’s consent before forwarding personal data out of the business.
As a recruitment business we are bound by Regulation 28 of the Conduct of Employment Agencies and Employment Business Regulations 2003 to obtain the prior consent of an individual before disclosing any information relating to them other than for the purposes of finding them work, or in relation to legal proceedings or to a professional body where they are a member. Prior explicit consent must be obtained before disclosing any information relating to an individual work seeker to their current employer.
Data in respect of the following is “sensitive personal data” and any information held on any of these matters MUST not be passed on to any third party without the express written consent of the individual:
All employees should ensure that adequate safety measures are in place. For example:
It should be remembered that incorrect processing of personal data may give rise to a breach of contract and/or negligence leading to a claim against McCarthy Recruitment. A failure to observe the contents of this policy will be treated as a disciplinary offence.
Data subjects are entitled to obtain access to their data on request and after payment of a processing fee. All requests to access data by data subjects should be referred to the DPO.
Any requests for access to a reference given by a third party must be referred to your line manager and should be treated with caution if the reference was given in relation to the individual making the request. This is because the person writing the reference also has a right to have their personal details protected in line with the GDPR and not disclosed without their consent.
Finally it should be remembered that all individuals have the following rights under the Human Rights Act 1988 and in dealing with personal data these should be respected at all times:
McCarthy Recruitment recognises the importance of Information Security to ensure business continuity and minimize business damage by preventing and reducing the impact of security breaches.
This policy is raised by the Managing Director to protect the company’s information assets from all threats whether internal or external, deliberate or accidental.
It is the policy of the company to ensure that:
All breaches of security, whether actual or suspected, will be reported to, and investigated by the DPO.
It is the responsibility of the DPO to provide guidance on the implementation of this policy.
It is the responsibility of all staff to adhere to this policy
This policy does not constitute a contract and McCarthy Recruitment reserves the right to change its terms at any time. Failure to comply with this policy may lead to disciplinary action up to and including dismissal.