Privacy and Data Policy
Pure Developers is a division of Lacorta Resourcing Limited. Lacorta Resourcing Limited (”We”, “The Company”) are committed to protecting and respecting your privacy.
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.
Even though the UK has expressed its intention to leave the EU in March 2019, the GDPR will be applicable in the UK from 25th May 2018. The Government intends for the GDPR to continue in UK law post Brexit and has also introduced a Data Protection Bill to replace the current Data Protection Act in due course.
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.
For the purposes of data protection legislation in force from time to time the data controller is Lacorta Resourcing Ltd. Registered Address: Lacorta Resourcing Limited, 3 Galley House, Moon Lane, High Barnet, Hertfordshire, EN5 5YL. Trading Address: 86-90 Paul Street, 3rd Floor, London, EC2A 4NE. Postal communication should be sent to our Trading Address.
Email communication relating to data protection matters within our organisation should be sent firstname.lastname@example.org with the following included in the subject line “F.A.O. Data Protection Officer at Pure Developers”.
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 also provide Pre-Employment Screening and Reference Checking services.
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
- New Employees of our clients’ to support our pre-employment screening service
- 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 forms on our site www.puredevelopers.co.uk or www.lacorta.co.uk (our sites) or by corresponding with us by phone, e-mail or otherwise. It includes information you provide when you register to use our site, to enter our database, subscribe to our services, participate in pre-employment screening for a third party client attend our events, participate in discussion boards or other social media functions on our site, 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 e-mail address and phone number, age/date of birth, financial information, compliance documentation and references verifying your qualifications and experience and your right to work in the United Kingdom, curriculum vitae and photograph, links to your professional profiles available in the public domain e.g. LinkedIn, Twitter, business Facebook or corporate website.
Information we collect about you when you visit our website.
With regard to each of your visits to our site we will automatically collect the following information:
Technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information if applicable.
Information we obtain from other sources.
This is information we obtain about you from other sources such as LinkedIn, corporate websites, job board websites, online CV libraries, your business card, personal recommendations, our clients, other candidates, conversations on the telephone, Notes following a conversation or meeting.
We are working closely with third parties including companies within our Group, business partners, sub-contractors in technical, professional, payment and other services, advertising networks, search information providers, credit reference agencies, professional advisors, our clients, your referees and/or former employers. We may receive information about you from them for the purposes of our recruitment services and ancillary support services.
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 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 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, although we will also rely on contract, legal obligation and consent for 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 hold information on 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. Examples of when consent may be the lawful basis for processing include permission to introduce you to a client (if you are a candidate) or when conducting reference checking and pre-employment screening on behalf of third party clients (if you are their employee or have been offered a position with them).
Our Legitimate Business Interests
Our legitimate interests in 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.
We must comply with a number of statutory provisions when providing our Recruitment Services, which necessitate the processing of personal data. These include the Conduct of Employment Agencies and Employment Businesses Regulations 2003, which amongst other things requires us to assess suitability of candidates and obtain information from Clients.
We are also required to comply with statutory and regulatory obligations relating to business generally, for example tax, bribery and fraud/crime prevention legislation, and co-operating with regulatory authorities such as HMRC.
In providing our Recruitment and Pre-Employment Screening Services, we will carry out some processing of personal data which is necessary for the purpose of our legitimate interests, which may include:
– Using your personal data:
- Collecting and storing your personal data, whether in manual or electronic files
- To contact you regarding our Recruitment Services
- To assess suitability of Candidates and roles, for example referencing or other feedback
- Engaging you for a role with us or with our Clients including any related administration eg: timesheets and payroll
- To collate market information or trends including providing analysis to potential or actual Clients
- Sending information to third parties with whom we have or intend to enter into arrangements which are related to our Recruitment Services
- Providing information to regulatory authorities or statutory bodies and our legal or other professional advisors including insurers.
- Retaining a record of our dealings
- Establishing quality, training and compliance with our obligations and best practice
- For the purpose of backing up information on our computer systems
- To personalise your experience and our offering, whether via our website or otherwise
Should we want or need to rely on consent to lawfully process your data we will request your consent orally, by email 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.
Other Uses we will make of your data:
- Use of our website
- to notify you about changes to our service
- to ensure that content from our site is presented in the most effective manner for you and for your computer.
We will use this information:
- to administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
- to improve our site to ensure that content is presented in the most effective manner for you and for your computer;
- to allow you to participate in interactive features of our service, when you choose to do so;
- as part of our efforts to keep our site safe and secure;
- to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you;
- to make suggestions and recommendations to you and other users of our site about goods or services that may interest you or them.
We do not undertake automated decision making or profiling. We do use our computer systems to search and identify personal data in accordance with parameters set by a person. A person will always be involved in the decision making process.
- help us to distinguish visitors and identify whether you have visited the website previously, so that we can understand your browsing habits and make the experience as meaningful to you personally as is possible and to improve the website
- deal with the administration of the website, to analyse and compile statistics about its use (e.g. how many visitors and which pages they visit) and to improve it. They are not used to read data from your hard drive, and cannot retrieve information from any other cookies created by other websites.
Standing alone, cookies do not identify you personally. They merely recognise your browser. Unless you choose to identify yourself, for example by registering with us or purchasing from us, then you remain anonymous to us. Cookies come in two types: session-based and persistent:
- Session cookies exist only during an online session. They disappear from your computer when you close your browser software or turn off your computer
- Persistent cookies remain on your computer after you have closed your browser or turned off your computer. They include such information as a unique identifier for your browser. We use persistent cookies that only we can read and use, to identify the fact that you are a website user or prior website user (whatever the case may be) and to track your use. We are especially careful about the security and confidentiality of the information stored in persistent cookies. These cookies expire after six months.
Some cookies are essential for parts of the website to operate and have already been set. You can delete and block all cookies from our website but that means that some parts of the website will not work. Users who disable their web browser’s ability to accept cookies will be able to browse our website, but will not be able to successfully and completely use our websites and services. For information on blocking cookies refer to the instructions on your Browser which is often located under the “Tools” section. Help is also available at allaboutcookies.org and also at direct.gov.uk
You can delete any cookies on your computer by referring to the instructions for your file management software to locate the file or directory that stores cookies and delete it. Help is also available at allaboutcookies.org
Disclosure of your information inside and outside of the EEA
We shall not share your personal data unless we are entitled to do so. The categories of persons with whom we may share your personal information include:
- 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;
- subcontractors including email marketing specialists, event organisers, payment and other financial service providers
- analytics and search engine providers that assist us in the improvement and optimisation of our site;
- credit reference agencies, our insurance broker, compliance partners and other sub-contractors for the purpose of assessing your suitability for a role where this is a condition of us entering into a contract with you.
We will 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 Lacorta Resourcing Limited 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.
- If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or to protect the rights, property, or safety of Lacorta Resourcing Limited our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
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 may be transferred to, and stored at, a destination outside the European Economic Area (”EEA”). It may be transferred to third parties outside of the EEA 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. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, 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. In most circumstances your data will not be retained for more than 6 years from the last point at which we provided any services or otherwise engaged with you and it is our policy to only store your personal data for as long as is reasonably necessary for us to comply with our legal obligations and for our legitimate business.
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 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.
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: The Data Protection Officer at 86-90 Paul Street, 3rd Floor, London, EC2A 4NE or email@example.com (including “F.A.O. Data Protection Officer at Pure Developers” in the email subject line).
Our site may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
The GDPR provides you with the following rights.
- Request correctionof the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
- Request erasureof your personal information. This enables you to ask us to delete or remove personal information 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 information where you have exercised your right to object to processing (see below).
- Object to processingof your personal information 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. You also have the right to object where we are processing your personal information for direct marketing purposes.
- Request the restriction of processingof your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
- Request the transferof your personal information to another party in certain formats, if practicable.
- Make a complaintto a supervisory body which in the United Kingdom 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: firstname.lastname@example.org (including “F.A.O. Data Protection Officer at Pure Developers” in the email subject line).
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 e-mail. 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 The Data Protection Officer at Pure Developers – email@example.com (including “F.A.O. Data Protection Officer at Pure Developers” in the email subject line).