Axon Moore Group Limited (”We” or “Axon Moore”) are committed to protecting and respecting your privacy.
Our Group means our subsidiaries, our ultimate holding company Axon Moore Group Limited and its subsidiary Axon Moore Group Limited and our associated companies as defined in section 1159 of the UK Companies Act 2006 (our Group).
This notice sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us.
The General Data Protection Regulation (GDPR) (Regulation (EU) 2016/679) is a new regulation which 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.
Your new rights under the GDPR are set out in this notice but will only apply once the GDPR becomes law on 25th May 2018.
Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.
We are not required to appoint a Data Protection Officer however, correspondence on any data protection matters should be marked for the attention of Richard Winsland at Axon Moore Group Limited of Suite 1.1, Canada House, Chepstow Street, Manchester, M1 5FW.
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.
Information you give to us or we collect about you
This is information about you that you give us by filling in our forms or by corresponding with us by 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, 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 email address, phone number, financial information, compliance documentation, payroll information, references verifying your qualifications and experience and your right to work in the UK, curriculum vitae, photograph ID, links to your professional profiles available in the public domain (e.g. LinkedIn, Twitter, business Facebook or corporate website), disability information, health information, criminal convictions, ethnic origin and date of birth.
Information we obtain from other sources
We may obtain information about you from other sources such as LinkedIn, corporate websites, job board websites, online CV libraries, your business card and personal recommendations. We review data protection policies and consent processes of our suppliers to ensure they are compliant with GDPR.
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 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 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 to supporting businesses’ resourcing needs and strategies.
Our legal basis for the processing of personal data is our legitimate business interests, described in more detail below, and also performance of a contract, legal obligations and consent for some 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 process information relating to 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.
Our Legitimate Business Interests
Our legitimate interests in processing, 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 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.
Should we want or need to rely on consent to lawfully process your data we will request your consent orally, by email, by signing a paper form 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.
A cookie, also known as an HTTP cookie, web cookie, or browser cookie, is usually a small piece of data sent from a website and stored in a user’s web browser while a user is browsing a website. When the user browses the same website in the future, the data stored in the cookie can be retrieved by the website to notify the website of the user’s previous activity. Cookies are not viruses, spyware, or Trojans that cause harm to your machine.
What cookies does this website use?
This website uses a variety of cookies to help improve the quality of your experience:
- Essential & Functional Cookies. Without these cookies certain functions of our website would not work, such as login, registration and password areas.
- Analytics Cookies. These cookies monitor how visitors use our website. This helps us to improve the customer flow and provide additional resources for popular pages. This analytics information is anonymous, we can only see what you visited, not who you are.
- Advertising Cookies. We don’t use a great deal of advertising on our site, but if we do, these cookies help us to know if you have seen an advert before, so we don’t keep bombarding you with the same one, however, we may show it a couple of times, so you don’t forget!
- Third Party Cookies. These are cookies dropped via our site, but by other websites, so if we host a video on YouTube.com and embed that on our site, when you click play YouTube drops a cookie on your machine so it knows you have watched it. Or if you hit the ‘Like’ button on one of our pages (please do!) the social media site will drop a cookie. We do try, wherever possible, to only allow third-party cookies to be dropped on your machine from websites we trust.
I don’t like cookies and want to turn them off!
This can be done in your individual web browser, but like we have mentioned, certain functions of our websites will not work correctly. If you want to turn off third party advertising cookies then visit http://www.youronlinechoices.com/uk/ – be prepared to receive a lot of random advertising about websites and products that really do not interest you.
Disclosure of your information
We may share your personal information with:
- 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 into with them or you;
- Our timesheet / payroll bureau Francis Webbs;
- CRB, background and health check agencies;
- Our online timesheet system, OTS;
- Our pension provider NOW: Pensions;
- Our auditors.
We may 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 Axon Moore 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.
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.
Where we store and process your personal data
The data that we collect from you will not be transferred to, or stored at, a destination outside the UK. It will not be transferred to third parties outside of the UK for the purpose of our recruitment services. By submitting your personal data, you agree to this transfer, storing or processing. We 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 which enables you to access certain parts of our site (including our timesheet site, OTS), 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 business interests and that you are happy for us to do so. Accordingly, we have a data retention period of up to 6 years 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 may 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; and
- Our recruitment expertise and knowledge of the industry by country, sector and job role.
- We may archive part or all of your personal data or retain it on our financial systems only, deleting all or part of it from our main Customer Relationship Manager (CRM) system. 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 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.
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 exercise your right to accept or prevent such processing by checking certain boxes on the forms we use to collect your data. You can also exercise the right at any time by contacting us at firstname.lastname@example.org
The GDPR provides you with the following rights:
- Right to be informed– Individuals have the right to be informed about the collection and use of their personal data.
- Right of access– Individuals have the right to access their personal data and supplementary information.
- Right to rectification– Individuals have the right to have their personal data rectified.
- Right to erasure– Individuals have the right to be erased, this is also known as the ‘right to be forgotten’.
- Right to restrict processing – Individuals have the right to ‘block’ or suppress processing of personal data.
- Right to data portability– Individuals have the right to obtain and reuse their own personal data for their own purposes across different services.
- Right to object – Individuals have the right to object to processing of their personal data.
- Right to make a complaint – Individuals have the right to make a complaint to a supervisory body which in the UK 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 1998 and the 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 GDPR once it is in force.
A subject access request should be submitted to email@example.com
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 updates or changes to our privacy notice.
Questions, comments and requests regarding this privacy notice are welcomed and should be addressed to firstname.lastname@example.org