Privacy Policy

Here at Fresh Minds Talent Ltd (“Freshminds”) we provide permanent and project recruitment, and consulting services to clients looking to recruit the best talent for their businesses.

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

(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 collect the information necessary to be able to find available opportunities and projects for you and further information needed to assess your eligibility through the different stages of recruitment. This information includes CV’s, identification documents, educational records, work history, employment and references.

We may also collect sensitive personal data about you, in the form of health data for example. We only collect sensitive personal data from you, and further process this data, where you have given your explicit consent.

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

  • From an agent/third party acting on your behalf

  • Through publicly available sources

  • By reference or word of mouth

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 there is a reasonable expectation that such information may be collected and further processed by job recruiters for the purpose of sourcing candidates for different opportunities.

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 and experience via our website and at a face-to-face interview with you where possible. 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 be collecting more information from you at the interview (or equivalent) stage and onwards in that manner.

How long do we keep your personal data for?

We keep your information in accordance as follows:

Candidate data: 6 years from last contact.

Contractor data: 6 years from last contact.

We only retain client information 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);

  • (potential) disputes;

  • if you have made a request to have your information deleted; and

  • guidelines issued by relevant data protection authorities.

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. The search for which you are considered, to ascertain if you are a good fit for the available position. 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 necessary for our legitimate interests in that we need the information in order 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, we may also rely on our processing being necessary to perform a contract for you, for example in contacting you.

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 match you with available job opportunities. 

Do we make automated decisions concerning you?

No, we do not carry out automated profiling.

Do we use Cookies to collect personal data on you?

To provide better service to you on our websites, we use cookies to collect your personal data when you browse. See our cookie policy here for more details.

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 security measures and approved model clauses in place to protect your personal data. To find out more about how we safeguard your information as related to transfers contact us at gdpr@freshminds.co.uk

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. Further information and advice about your rights can be obtained from the data protection regulator in your country.

  • The right to be informed 

  • The right of access 

  • The right to rectification 

  • The right to erasure 

  • The right to restrict processing 

  • The right to data portability 

  • The right to object to processing 

  • The right to lodge a complaint 

  • The right to withdraw consent 

We usually act on requests and provide information free of charge, 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.

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 have further questions on the processing of your personal data, contact here: gdpr@freshminds.co.uk