Fresh Minds Talent Limited is a company registered in England and Wales with the number 08662856 and its registered office at Kingsbourne House, 229-231 High Holborn, London, WC1V 7DA.
For information on our Data Processing Agreement: read here.
For information on our Data Sharing Agreement read here.
What does this policy cover?
We take your personal data seriously at Freshminds. This policy
(a) sets out the types of personal data that we collect about you and how we store it
(b) explains how and why we collect and use your personal data
(c) explains how long we keep your personal data for
(d) explains when, why and with who we will share your personal data;
(e) sets out the legal basis we have for using your personal data;
(f) explains the effect of refusing to provide the personal data requested;
(g) explains the different rights and choices you have when it comes to your personal data; and
(h) explains how we may contact you and how you can contact us.
What personal data do we collect about you?
We may also collect sensitive personal data about you, in the form of health data, data about your race or ethnicity, for example. This is known as “special category data”, and we only collect and further process this data, where you have given your explicit consent.
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
Where do we collect personal data about you from?
The following are the different sources we may collect personal data about you from:
Directly from you: if you provide us with your CV and contact details together with any other personal data, based either on your consent or on a contract between us.
From an agent/third party acting on your behalf: if a client contacts us and asks us to invite you to interview or consider a job opportunity, if you are referred to us by a partner for a role we are seeking to fill. In this event, our processing is done initially based on our legitimate interests and subsequently may be based on consent or contract.
Through publicly available sources: Where we collect your information through publicly available sources as set out above, we may do this with the aid of software programs. These programs are given parameters on the requirements of a role and search through publicly available sources to find such candidates. These programs are designed to only output information on candidates that meet the search criteria. The parameters of this program are restricted to only searching for [Name, Age and Job role] candidate information from public sites where it is our understanding (based on our reasonable endeavours used to research the public source) that such information is provided by the candidate (data subject) based on their consent that their personal data may be collected and further processed by job recruiters for the purpose of sourcing candidates for different opportunities;
By reference or word of mouth: where a client or an agent on your behalf provides us with your personal data with a recommendation or a reference for a post.
How and why we use your personal data?
We use your personal data to match your skills, experience and education with potential employers or those clients looking to bring in extra capacity to fulfil a project requirement. We will initially collect basic information on you, such as contact details, job role, CV and experience via our website and at a face-to-face interview with you where possible, based either on your consent or the contract between us. We will then pass this on to the client in search of personnel. If you are chosen by the client and go through to the next stage we will then request further information from you at the interview (or equivalent) stage, again based on your consent or a contract between us.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity.
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
We may use your personal data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you. We do this based on our legitimate interests (which we balance against your rights) or with your consent where you request information.
You will also receive marketing communications from us if you have requested information from us or if you have used our services in the past and have not opted out of receiving that marketing.
We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
You can ask us (or third parties) to stop sending you marketing messages at any time by contacting us at any time or by using the “unsubscribe” link at the bottom of our marketing messages.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us for the provision of services (where our legal basis for using the personal data is based on contract, not consent).
How long do we keep your personal data for?
We usually keep your information as follows:
Candidate data: 6 years from last contact.
Contractor data: 6 years from last contact.
We only retain personal data for as long as is necessary for us to use your information as described above or to comply with our legal obligations. However, please be advised that we may retain some of your information after you cease to use our services, for instance, if this is necessary to meet our legal obligations, such as retaining the information for tax and accounting purposes.
When determining the relevant retention periods, we will take into account factors including:
our contractual obligations and rights in relation to the information involved;
legal obligation(s) under applicable law to retain data for a certain period of time;
statute of limitations under applicable law(s);
if you have made a request to have your information deleted; and
guidelines issued by relevant data protection authorities.
In some circumstances, we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
Otherwise, we securely erase your information once this is no longer needed.
Who do we share your personal data with?
Your personal data is shared with the client who initiates a search for personnel, based either on your consent or the contract between us. Your personal data will be provided only to enable the client to ascertain if you are a good fit for the available position. With your consent or based on our contract, we may also conduct checks on you to verify the information you have provided and where we do this we may share your information with www.cvonline.co.uk
What legal basis do we have for using your information?
For prospective candidates, contractors, referees and clients, our processing is based either on contract (and pre-contractual dealings) or on our legitimate interests in processing personal data to be able to assess suitability for potential roles, to find potential candidates and to contact clients and referees.
If you are interviewed and submitted as a candidate, then this may involve the processing of more detailed personal data, including sensitive data, such as health information, that you or others provide about you. In that case, we always ask for your consent before undertaking such processing.
For clients, suppliers or other business contacts, we rely on our processing being necessary to perform a contract for you as a legal basis for our processing, for example, in contacting you to provide our services.
What happens if you do not provide us with the information we request or ask that we stop processing your information?
If you do not provide the personal data necessary, or withdraw your consent for the processing of your personal data, we may not be able to provide our services to you or match you with available job opportunities.
Do we make automated decisions concerning you?
No, we do not carry out automated profiling.
Do we transfer your data outside the EEA?
To better match your employee profile with current opportunities, we may transfer your personal data to clients and partners in countries outside the EEA. These countries' privacy laws may be different from those in your home country. Where we transfer data to a country which has not been deemed to provide adequate data protection standards we always have appropriate security measures and contractual safeguards in place to protect your personal data.
This applies where we transfer your personal data for CV formatting to our trusted partner, an arrangement which is governed by written data processing agreements and additional safeguards to ensure the security of all personal data.
To find out more about how we safeguard your information as related to transfers, contact us at firstname.lastname@example.org
What rights do you have in relation to the data we hold on you?
By law, you have a number of rights when it comes to your personal data.
You have the right to:
Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data 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 data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons, which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data 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 as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
If you want us to establish the data’s accuracy.
Where our use of the data is unlawful, but you do not want us to erase it.
Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
You have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
We usually act on requests and provide information free of charge within 30 days but may charge a reasonable fee to cover our administrative costs of providing the information for baseless or excessive/repeated requests or further copies of the same information.
Alternatively, we may be entitled to refuse to act on the request where we believe it to be excessive, malicious or disingenuous.
Please consider your request responsibly before submitting it. We’ll respond as soon as we can. Generally, this will be within one month from when we receive your request, but if the request is going to take longer to deal with, we’ll come back to you and let you know.
How will we contact you?
We may contact you by phone, email or social media. If you prefer a particular contact means over another, please just let us know.
How can you contact us?
If you are unhappy with how we’ve handled your information or would like to correct or update your information or exercise any of your other legal rights over your personal data, or if you have further questions on the processing of your personal data, contact here: email@example.com