The policy applies to this website, and across the services that we provide. It was last updated in May 2018.
Company name: Coba Education Limited ('the Company')
Company contact details: The data protection lead is Mrs Karen Thomas, email@example.com.
Document: Privacy Notice
Topic: Data Protection
Date: 02 May 2018
The Company is a recruitment business which provides work-finding services to its clients and work-seekers. The Company must process personal data, including sensitive personal data so that it can provide these services – in doing so, the Company acts as a data controller.
You may give your personal details to the Company directly, such as on an application or registration form or via our website, or the company may collect them from another source such as a jobs board. The Company must have a legal basis for processing your personal data. For the purposes of providing you with work-finding services and/or information relating to roles relevant to you the company will only use your personal data in accordance with the terms of the following statement.
1. Collection and use of personal data
a. Purpose of processing and legal basis
The Company will collect your personal data, which may include sensitive personal data and will process your personal data for the purposes of providing you with work-finding services. This includes for example, contacting you about job opportunities, assessing your suitability for those opportunities, updating our databases, putting you forward for job opportunities, arranging payments to you and developing and managing our services and relationship with you and our clients.
In some cases the company may be required to use your data for the purpose of investigating, reporting and detecting crime and also to comply with laws that apply to us. The company may also use your information during the course of internal audits to demonstrate our compliance with certain industry standards.
The legal bases the company rely upon to offer these services to you are:
- Your consent
- Where the company have a legitimate interest
- To comply with a legal obligation that the company have
- To fulfil a contractual obligation that the company have with you
b. Legitimate interest
This is where the Company has a legitimate reason to process your data provided it is reasonable and does not go against what you would reasonably expect from us. Where the Company has relied on a legitimate interest to process your personal data our legitimate interests is/are as follows:
- Managing our database and keeping work-seeker records up to date
- Contacting you to seek your consent where the company need it
- Providing work finding services to you, including sending your information to our clients where you have demonstrated an interest in doing that particular type of work but not expressly consenting to us passing on your CV
c. Recipient/s of data
The Company will process your personal data and/or sensitive personal data with the following recipients:
- Clients e.g. schools and nurseries
- Your former or prospective new employers that the company obtain or provide references to
- The Recruitment and Employment Confederation (REC) which the company are member of an audited by and any other trade bodies
- Any other third parties who carry out audits to ensure that the company run our business properly
- Payroll service providers who manage our payroll on our behalf
- Any umbrella companies that the company pass your data to if this is your chosen method of payment
- Other recruitment agencies in our supply chain (e.g. master/neutral venders and second tier suppliers)
- Our insurances providers and our legal advisers
- Social networks
- Our IT and CRM providers
- Public information sources and third party organisations that the company use to carry out suitability checks on you as a work-seeker e.g. Companies House, the Disclosure and Barring Service (DBS), National College for Teaching and Leadership (NCTL)
- Government, law enforcement agencies and other regulators e.g. the Police, Home Office, HMRC, Employment Agencies Standards Inspectorate (EASI), Local Authority Designated Officers (LADOs)
- Trade Unions
- Any of our group of companies
- Any other organisations you ask us to share their data with
d. Statutory/contractual requirement
Your personal data is required by law and/or a contractual requirement (e.g. our client may require this personal data), and/or a requirement necessary to enter into a contract. You are obliged to provide the personal data and if you do not the consequences of failure to provide the data are:
- The company will be unable to run any of our safeguarding/compliance checks the company are required by law before introducing you to supplying you to a client
2. Overseas transfers
The Company may transfer only the information you provide to us to countries outside the European Economic Area (‘EEA’) for the purposes of providing you with work-finding services. The company will take steps to ensure adequate protections are in place to ensure the security of your information. The EEA comprises the EU member states plus Norway, Iceland and Liechtenstein.
3. Data retention
The Company will retain your personal data only for as long as is necessary for the purpose the company collect it. Different laws may also require us to keep different data for different periods of time.
The Conduct of Employment Agencies and Employment Businesses Regulations 2003, require us to keep work-seeker records for at least one year from (a) the date of their creation or (b) after the date on which the company last provide you with work-finding services.
The company must also keep your payroll records, holiday pay, sick pay and pensions auto-enrolment records for as long as is legally required by HMRC and associated national minimum wage, social security and tax legislation.
Where the Company has obtained your consent to process your personal and sensitive personal data the company will do so in line with our retention policy, please email firstname.lastname@example.org if you wish to see a copy. Upon expiry of that period the Company will seek further consent from you. Where consent is not granted the Company will cease to process your personal data and sensitive personal data.
4. Your rights
Please be aware that you have the following data protection rights:
- The right to be informed about the personal data the company process on you;
- The right of access to the personal data the company process on you;
- The right to rectification of your personal data;
- The right to erasure of your personal data in certain circumstances;
- The right to restrict processing of your personal data;
- The right to data portability in certain circumstances;
- The right to object to the processing of your personal data that was based on a public or legitimate interest;
- The right not to be subjected to automated decision making and profiling; and
- The right to withdraw consent at any time
Where you have consented to the Company processing your personal and sensitive personal data you have the right to withdraw that consent at any time by contacting Mrs Karen Thomas, email@example.com.
There may be circumstances where the company will still need to process your data for legal or official reasons. The company will inform you if this is the case. Where this is the case, the company will restrict the data to only what is necessary for the purpose of meeting those specific reasons.
If you believe that any of your data that the Company processes is incorrect or incomplete, please contact us using the details above and the company will take reasonable steps to check its accuracy and correct it where necessary.
You can also contact us using the above details if you want us to restrict the type or amount of data we process for you, access your personal data or exercise any of the other rights listed above.
5. Complaints or queries
If you wish to complain about this privacy notice or any of the procedures set out in it, please contact: Mr Martin Chamberlain or Mrs Karen Thomas.
Head Office – Coba Education Limited, 12 Brookfield, Duncan Close, Moulton Park, Northampton, NN3 6WL.
You also have the right to raise concerns with Information Commissioner’s Office (ICO) on 0303 123 1113 or by clicking here or any other relevant supervisory authority should your personal data be processed outside of the UK, if you believe that your data protection rights have not been adhered to.