Privacy Policy

INTRODUCTION

• This Privacy Policy explains what we do with your personal data, whether we are in the process of helping you find a job, continuing our relationship with you once we have found you a role, providing you with a service, receiving a service from you, using your data to ask for your assistance in relation to one of our Candidates, or you are visiting our website.
• It describes how we collect, use, and process your personal data, and how, in doing so, we comply with our legal obligations to you. Your privacy is important to us, and we are committed to protecting and safeguarding your data privacy rights.
• This Privacy Policy applies to the personal data of our Website Users, Candidates, Clients, Suppliers, and other people whom we may contact to find out more about our Candidates or whom they indicate is an emergency contact.
• For applicable data protection legislation (including but not limited to the General Data Protection Regulation (Regulation (EU) 2016/679) (the “GDPR”), the company responsible for your personal data is Infinitek Limited of Suite 20, Manchester One, 53 Portland Street, Manchester, Greater Manchester, England, M1 3LD referred to as “Infinitek” or “us.”
• It is important to point out that we may amend this Privacy Policy from time to time. Please just visit this page if you want to stay up to date, as we will post any changes here.
• If you are dissatisfied with any aspect of our Privacy Policy, you may have legal rights and, where relevant, we have described these as well.

The information described below is, of course, in addition to any personal data we are required by law to process in any given situation.

CANDIDATE DATA: Depending on the relevant circumstances and applicable local laws and requirements, we may collect some or all the information below to enable us to offer you employment opportunities which are tailored to your circumstances and your interests. In certain circumstances our calls with you may be recorded, depending on the applicable local laws and requirements.

Identity Data: data that identifies you, such as your first name, last name, username, job title, employer, title, date of birth, marital status, and gender.

Contact Data: contact details including your personal and/or business email address, postal address, and telephone number.

Profile Data: data we store in connection with your profile when you register on our site, including your username and password (to access your account on our site) and (in the case of applicants) history of job applications and placements made via us, your preferences, interests, feedback, and other communications with us and/or our clients.

CV Data: information submitted as part of a job application and/or the registration process, including qualifications, experience and references and any other information contained on a CV.

Application Data: applicant’s history of responding to job advertisements and the progress of those applications.

Financial Data: if you are a client representative paying for our services, we may capture your personal data either peripherally or if you use personal payment details.

Social Media Data: when you connect with us or like or follow our social media accounts we may have access to your personal data through the social media platform, including your social media handle, photograph, date of birth, location, occupation, interests and other information and content you make available via your social media accounts.

Technical Data: electronic information which is automatically logged/stored by processing equipment, including internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our site.

Usage Data: information about how you use our site and our services, including how you navigate our site and if you encounter any problems.

Marketing and Communications Data: data that we capture when you sign up to our newsletters, including your preferences regarding receiving marketing communications from us.

Please note that the above is not exhaustive.

CLIENT DATA: The data we collect about Clients is actually very limited. We generally only need to have your contact details or the details of individual contacts at your organisation (such as their names, telephone numbers and email addresses) to enable us to ensure that our relationship runs smoothly. We also hold information relating to your online engagement with Candidate profiles and other material published by Infinitek, which we use to ensure that our marketing communications to you are relevant and timely. We may also hold extra information that someone in your organisation has chosen to tell us. In certain circumstances our calls with you may be recorded, depending on the applicable local laws and requirements. If we need any additional personal data for any reason, we will let you know.

SUPPLIER DATA: We don’t collect much data about Suppliers – we simply need to make sure that our relationship runs smoothly. We’ll collect the details for our contacts within your organisation, such as names, telephone numbers and email addresses. We’ll also collect bank details, so that we can pay you. We may also hold extra information that someone in your organisation has chosen to tell us. In certain circumstances our calls with you may be recorded, depending on the applicable local laws and requirements.

PEOPLE WHOSE DATA WE RECEIVE FROM CANDIDATES AND STAFF, SUCH AS REFEREES AND EMERGENCY CONTACTS: All we need from referees is confirmation of what you already know about our Candidate or prospective member of Staff, so that they can secure that job they really want.

Emergency contact details give us somebody to call on in an emergency. To ask for a reference, we’ll obviously need the referee’s contact details (such as name, email address and telephone number). We’ll also need these details if our Candidate or a member of our Staff has put you down as their emergency contact so that we can contact you in the event of an accident or an emergency.

WEBSITE USERS We collect a limited amount of data from our Website Users which we use to help us to improve your experience when using our website and to help us manage the services we provide. This includes information such as how you use our website, the frequency with which you access our website, your browser type, the location you view our website from, the language you choose to view it in and the times that our website is most popular. If you contact us via the website, we will collect any information that you provide to us, for example your name and contact details.

We collect your data automatically via cookies, in line with cookie settings in your browser. If you are also a Candidate or Client of Infinitek, we may use data from your use of our websites to enhance other aspects of our communications with or service to you.

HOW CAN YOU ACCESS, AMEND OR TAKE BACK THE PERSONAL DATA THAT YOU HAVE GIVEN TO US?

One of the GDPR’s main objectives is to protect and clarify the rights of EU citizens and individuals in the EU with regards to data privacy. This means that you retain various rights in respect of your data, even once you have given it to us. These are described in more detail below.

To get in touch about these rights, please contact us. We will seek to deal with your request without undue delay, and in any event within one month (subject to any extensions to which we are lawfully entitled). Please note that we may keep a record of your communications to help us resolve any issues which you raise.

Right to object: this right enables you to object to us processing your personal data where we do so for one of the following four reasons: (i) our legitimate interests; (ii) to enable us to perform a task in the public interest or exercise official authority; (iii) to send you direct marketing materials; and (iv) for scientific, historical, research, or statistical purposes.

The “legitimate interests” and “direct marketing” categories above are the ones most likely to apply to our Website Users, Candidates, Clients, and Suppliers. If your objection relates to us processing your personal data because we deem it necessary for your legitimate interests, we must act on your objection by ceasing the activity in question unless:

• we can show that we have compelling legitimate grounds for processing which overrides your interests; or
• we are processing your data for the establishment, exercise, or defence of a legal claim.

If your objection relates to direct marketing, we must act on your objection by ceasing this activity.

Right to withdraw consent: Where we have obtained your consent to process your personal data for certain activities (for example, for our marketing arrangements or automatic profiling), you may withdraw this consent at any time and we will cease to carry out the particular activity that you previously consented to unless we consider that there is an alternative reason to justify our continued processing of your data for this purpose in which case we will inform you of this condition.

Data Subject Access Requests (DSAR): You may ask us to confirm what information we hold about you at any time, and request us to modify, update or delete such information. We may ask you to verify your identity and for more information about your request. If we provide you with access to the information we hold about you, we will not charge you for this unless your request is “manifestly unfounded or excessive”. If you request further copies of this information from us, we may charge you a reasonable administrative cost where legally permissible. Where we are legally permitted to do so, we may refuse your request. If we refuse your request, we will always tell you the reasons for doing so.

Please note that in certain jurisdictions in which we operate, we comply with additional local law requirements regarding data subject access requests and may refuse your request in accordance with such laws.

Right to erasure: You have the right to request that we erase your personal data in certain circumstances. Normally, the information must meet one of the following criteria:

• the data are no longer necessary for the purpose for which we originally collected and/or processed them.
• where previously given, you have withdrawn your consent to us processing your data, and there is no other valid reason for us to continue processing.
• the data has been processed unlawfully (i.e., in a manner which does not comply with the GDPR).
• it is necessary for the data to be erased for us to comply with our legal obligations as a data controller; or
• if we process the data because we believe it necessary to do so for our legitimate interests, you object to the processing and we are unable to demonstrate overriding legitimate grounds for our continued processing.

We would only be entitled to refuse to comply with your request for one of the following reasons:

• to exercise the right of freedom of expression and information.
• to comply with legal obligations or for the performance of a public interest task or exercise of official authority.
• for public health reasons in the public interest.
• for archival, research or statistical purposes; or
• to exercise or defend a legal claim.

When complying with a valid request for the erasure of data we will take all reasonably practicable steps to delete the relevant data.

Right to restrict processing: You have the right to request that we restrict our processing of your personal data in certain circumstances. This means that we can only continue to store your data and will not be able to carry out any further processing activities with it until either: (i) one of the circumstances listed below is resolved; (ii) you consent; or (iii) further processing is necessary for either the establishment, exercise or defence of legal claims, the protection of the rights of another individual, or reasons of important EU or Member State public interest.

The circumstances in which you are entitled to request that we restrict the processing of your personal data are:

• where you dispute the accuracy of the personal data that we are processing about you. In this case, our processing of your personal data will be restricted for the period during which the accuracy of the data is verified.
• where you object to our processing of your personal data for our legitimate interests. Here, you can request that the data be restricted while we verify our grounds for processing your personal data.
• where our processing of your data is unlawful, but you would prefer us to restrict our processing of it rather than erasing it; and
• where we have no further need to process your personal data, but you require the data to establish, exercise, or defend legal claims.

If we have shared your personal data with third parties, we will notify them about the restricted processing unless this is impossible or involves disproportionate effort. We will, of course, notify you before lifting any restriction on processing your personal data.

Right to rectification: You also have the right to request that we rectify any inaccurate or incomplete personal data that we hold about you. If we have shared this personal data with third parties, we will notify them about the rectification unless this is impossible or involves disproportionate effort. Where appropriate, we will also tell you which third parties we have disclosed the inaccurate or incomplete personal data to. Where we think that it is reasonable for us not to comply with your request, we will explain our reasons for this decision.

Right of data portability: If you wish, you have the right to transfer your personal data between data controllers. In effect, this means that you can transfer your Infinitek account details to another online platform. To allow you to do so, we will provide you with your data in a commonly used machine-readable format that is password-protected so that you can transfer the data to another online platform. Alternatively, we may directly transfer the data for you. This right of data portability applies to: (i) personal data that we process automatically (i.e. without any human intervention); (ii) personal data provided by you; and (iii) personal data that we process based on your consent or in order to fulfil a contract.

Right to lodge a complaint with a supervisory authority: You also have the right to lodge a complaint with your local supervisory authority.

If you would like to exercise any of these rights or withdraw your consent to the processing of your personal data (where consent is our legal basis for processing your personal data), details of how to contact us can be found here. Please note that we may keep a record of your communications to help us resolve any issues which you raise.

You may ask to unsubscribe from job alerts at any time.

It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during the period for which we hold your data.

HOW DO WE STORE AND TRANSFER YOUR DATA INTERNATIONALLY?

In order to provide you with the best service and to carry out the purposes described in this Privacy Policy, your data may be transferred:

• to third parties (such as advisers or other Suppliers to the Infinitek business);
• to overseas Clients;
• to Clients within your country who may, in turn, transfer your data internationally;
• to a cloud-based storage provider; and
• to other third parties

We want to make sure that your data is stored and transferred in a way which is secure. We will therefore only transfer data outside of the European Economic Area or EEA (i.e. the Member States of the European Union, together with Norway, Iceland and Liechtenstein) where it is compliant with data protection legislation and the means of transfer provides adequate safeguards in relation to your data.

To ensure that your personal information receives an adequate level of protection, we have put in place appropriate procedures with the third parties we share your personal data with to ensure that your personal information is treated by those third parties in a way that is consistent with, and which respects the law on data protection.

How do we use cookies?

We use cookies to do two things:

• to track your use of our website. This enables us to understand how you use the site and track any patterns that emerge individually or from larger groups. This helps us to develop and improve our website and services in response to what our visitors want and need; and
• to help us advertise jobs to you that we think you’ll be interested in. Hopefully this means less time for you trawling through endless pages and will get you into the employment you want more quickly.

Cookies are either:

• Session cookies: these are only stored on your computer during your web session and are automatically deleted when you close your browser – they usually store an anonymous session ID allowing you to browse a website without having to log in to each page, but they do not collect any information from your computer; or
• Persistent cookies: a persistent cookie is stored as a file on your computer, and it remains there when you close your web browser. The cookie can be read by the website that created it when you visit that website again. We use persistent cookies for Google Analytics and for personalisation (see below).

Cookies can also be categorised as follows:

• Strictly necessary cookies: These cookies are essential to enable you to use the website effectively, such as when applying for a job, and therefore cannot be turned off. Without these cookies, the services available to you on our website cannot be provided. These cookies do not gather information about you that could be used for marketing or remembering where you have been on the internet.
• Performance cookies: These cookies enable us to monitor and improve the performance of our website. For example, they allow us to count visits, identify traffic sources and see which parts of the site are most popular.
• Functionality cookies: These cookies allow our website to remember choices you make (such as your username, language, or the region you are in) and provide enhanced features. For instance, we may be able to provide you with news or updates relevant to the services you use. These cookies can also be used to remember changes you have made to text size, font, and other parts of web pages that you can customise. They may also be used to provide services you have requested such as viewing a video or commenting on a blog. The information these cookies collect is usually anonymised.
• Personalisation cookies: These cookies help us to advertise details of potential job opportunities that we think may be of interest. These cookies are persistent (for as long as you are registered with us) and mean that when you log in or return to the website, you may see advertising for jobs that are like jobs that you have previously browsed.

OUR LEGAL BASES FOR PROCESSING YOUR DATA

LEGITIMATE INTERESTS

Article 6(1)(f) of the GDPR is the one that is relevant here – it says that we can process your data where it “is necessary for the purposes of the legitimate interests pursued by [us] or by a third party, except where such interests are overridden by the interests or fundamental rights or freedoms of [you] which require protection of personal data.”

We don’t think that any of the following activities prejudice individuals in any way – in fact, they help us to offer you a more tailored, efficient service, so everyone’s a winner! However, you do have the right to object to us processing your personal data on this basis. If you would like to know more about how to do so, please get in touch.

CONSENT

In certain circumstances, we are required to obtain your consent to the processing of your personal data in relation to certain activities. Depending on exactly what we are doing with your information, this consent will be opt-in consent or soft opt-in consent.

Article 4(11) of the GDPR states that (opt-in) consent is “any freely given, specific, informed and unambiguous indication of the data subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.” In plain language, this means that:

• you must give us your consent freely, without us putting you under any type of pressure.
• you must know what you are consenting to – so we’ll make sure we give you enough information.
• you should have control over which processing activities you consent to and which you don’t. We provide these finer controls within our privacy preference centre; and
• you need to take positive and affirmative action in giving us your consent – we’re likely to provide a tick box for you to check so that this requirement is met in a clear and unambiguous fashion.
• We will keep records of the consents that you have given in this way.

We have already mentioned that, in some cases, we will be able to rely on soft opt-in consent. We are allowed to market products or services to you which are related to the recruitment services we provide if you do not actively opt-out from these communications.

As we have mentioned, you have the right to withdraw your consent to these activities.

ESTABLISHING, EXERCISING OR DEFENDING LEGAL CLAIMS

Sometimes it may be necessary for us to process personal data and, where appropriate and in accordance with local laws and requirements, sensitive personal data in connection with exercising or defending legal claims. Article 9(2)(f) of the GDPR allows this where the processing “is necessary for the establishment, exercise or defence of legal claims or whenever courts are acting in their judicial capacity”.

This may arise for example where we need to take legal advice in relation to legal proceedings or are required by law to preserve or disclose certain information as part of the legal process.

How you can get in touch with us:

• to access, amend or take back the personal data that you have given to us.
• if you suspect any misuse or loss of or unauthorised access to your personal information.
• to withdraw your consent to the processing of your personal data (where consent is the legal basis on which we process your personal data).
• with any comments or suggestions concerning this Privacy Policy

You can email us at the following address:

[email protected]

HOW TO CONTACT YOUR LOCAL SUPERVISORY AUTHORITY

Details of your local supervisory authority: The Information Commissioner’s Office. You can contact them in the following ways:

Phone: 0303 123 1113

Email: [email protected]

Post: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF

Privacy Policy last updated: July 2023