PRIVACY POLICY

1. About this Privacy Policy 

We are an employment business which seeks to find individuals work with our hirer clients, and provides the services of workers we have engaged (Workers) to the hirer.  This privacy policy is designed to give you, the Worker, information as to how we will obtain and process personal data relating to you in connection with the services we provide to you. It is important that you read this Privacy Policy together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you.  We will process your personal data as a “data controller”. This means that we have responsibility (on our own or acting jointly with another party) for deciding how we hold and use personal data relating to you. 

2. Who we are and how to contact us

Intsol Recruitment Ltd t/a Integrated Solutions (Company, We, us, our) is a limited company registered in England and Wales under company number 07647610 and has its registered address at 78 Stockingswater Lane, Enfield EN3 7RL.  Our Data Protection Officer is Sam Complin and can be contacted at [email protected] or on 0208 443 1616

3. The data we collect and process about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

• Identity Data including name, title, date of birth, nationality, gender, and place of birth.

• Contact Data including postal address, residential address, email address and telephone numbers, next of kin.

• Worker Status Data including visa information, passport information, and information relating to your right to work in the UK.

• Payroll and PAYE Data including bank details, national insurance number, tax code, information relating to hours worked and rate of pay. For limited liability companies, this will include your company registration certificate and information pertaining to your public liability insurance. 

• Criminal Record Data, for a DBS Check, including the last five years of residential address history.

• DVLA Data, including details on driving history like penalty points, or endorsements. 

• Medical History Data, including any past or current, chronic or mild, illnesses.

• Job History Data, including previous job history and past employer references.

4. How we collect personal data 

We may obtain your personal data directly from you (e.g. in a Curriculum Vitae, application or registration form, via our website, or in correspondence, a meeting or telephone call, direct message on social media or our website), a hirer, the third party company we engage to provide payroll and administration services on our behalf, or via direct message from you on social media, a contact form on our website, applications from an online job site, or a former employer. 

5. How and why we use your personal data 

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• Where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.  

• Where it is necessary to comply with a legal or regulatory obligation that we are subject to. 

We have set out in the table below a description of the ways we may use your personal data, and the legal bases we rely on to do so.  Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground applies.

Purpose/Activity	Types of data	Lawful basis for processing including basis of legitimate interest
Registering you at one of our offices	Identity Data, Contact Data, Worker Status Data, Payroll and PAYE Data, Criminal Record Data, Medical History Data, Job History Data	The data you give us will be processed prior to an interview to ensure that you fit the role you are applying to.
Setting you up as a new candidate in our internal database	Identity Data, Contact Data, Worker Status Data, Payroll and PAYE Data, Criminal Record Data, Medical History Data, Job History Data	The data you gave us at registration is processed and uploaded securely to our internal database.
Setting you up as a new worker on our payroll system	Identity Data, Worker Status Data, Payroll and PAYE Data	Your data is uploaded securely to our payroll system, which is shared with our third party payroll company, New Millenia.
Processing you for a successful job	Identity Data, Worker Status Data, Criminal Record Data	Your right to work documents, DVLA, and DBS status are processed and will be shared with the client you will be working for, if necessary for the job role.
Verifying your references	Job History Data	The references and job history you provided will be verified by our internal references team.
DBS check request	Identity Data, Worker Status Data, Criminal Record Data	Your information is sent to the Disclosure and Barring Service of the Home Office to ensure you have no criminal convictions that will disbar you from a specific job or role, for instance, working with children and vulnerable people.

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.   If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.  Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

6. Sensitive personal data

We do not intend to collect any “special categories of personal data” (such as information which reveals your political, religious or philosophical beliefs, sexual orientation, race or ethnic origin or information relating to your health). However, to the extent that you do provide us with any special categories of data, we will only use that data for the purposes of our relationship with you and providing our recruitment services to you. This may be for one or more of the following reasons:

• with your explicit consent (in limited circumstances);
• where we need to carry out our legal obligations or exercise rights in connection with employment;
• where the processing is necessary for the purposes of preventive or occupational medicine or for assessing your working capacity;
• where it is needed in the public interest, such as for equal opportunities monitoring or in relation to our occupational pension scheme.

7. If you fail to provide personal data

Where we need to collect personal data by law or in order to perform a contract to which you are a party, and you fail to provide that data when requested, we may not be able to perform the contract. In this case, we may have to cancel the contract, but we will notify you if this is the case at the time. 

8. Disclosures of your personal data

We may share personal data with hirers or other third parties in connection with the provision of our recruitment services. We may also disclose personal data to:

• third party service providers who process data on our behalf, such as:
  • outsourced payroll services;
  • IT support;

• professional advisers including lawyers, bankers, auditors and insurers for the purpose of providing consultancy, banking, legal, insurance and accounting services to us;

• HM Revenue & Customs, regulators and other authorities who require reporting of processing activities in certain circumstances;

• third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

We require all our data processors to respect the security of your personal data and to treat it in accordance with the law. We do not allow our data processors to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

9. International transfers

We do not transfer your personal data outside the European Economic Area (EEA).

10. Data security

We have put in place security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. 

11. Data retention

We will only retain your personal data, including identity data, contact data, worker status data, criminal record data, medical history data, and job history data, for a period of five years to fulfil the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements. For accounting purposes, your identity, payroll and PAYE data will be retained indefinitely since payroll data cannot be deleted. 

12. Your rights in respect of your personal data

You have certain rights in respect of the personal data that we process about you (where we determine the purpose and means for which that personal data shall be processed): 

• the right to request access to the personal data that we hold about you and how we process it; 

• you may have the right in accordance with applicable data protection law to have personal data we hold about you rectified or restricted; 

• you may, in some circumstances, have the right to have personal data we hold about you deleted (although note 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);

• in some circumstances, you may have the right to receive or ask for your personal data to be transferred to a third party;

• you have the right to object to how we process your personal data where that processing is based upon legitimate interests and there are no compelling grounds for the continued processing of that data;

• where we are processing personal data relating to you on the basis that we have your consent to do so, you may withdraw your consent at any time (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. 

If you wish to exercise any of the rights set out above in respect of your personal data, please contact us at [email protected] or 0208 443 1616.  We may ask you to verify your identity if you make a request to us to exercise any of the rights set out above. We may also contact you to ask you for further information in relation to your request to speed up our response. You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances. You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

13. Your duty to inform us of changes

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

14. Changes to this privacy policy

We reserve the right to update this privacy policy at any time, and we will provide you with a new privacy policy when we make any substantial changes. We may also notify you in other ways from time to time about the processing of your personal data.