Never Mind the Job Spec Ltd Privacy Policy
This Privacy Policy outlines how Never Mind the Job Spec Ltd with company number 12715262 of Number Sixty One, Alexandra Road, Lowestoft, Suffolk, England, NR32 1PL (‘Never Mind the Job Spec Ltd’, ‘we’, ‘us’, ‘our’, and ‘ours’) processes any personal data it holds about any of its data subjects (‘you’, and ‘your’).
Mr. Glenn Martin and Mr. Diego Crawford have responsibility for data protection matters at Never Mind the Job Spec Ltd, and can be contacted on +44(0)7557 30 6462 to assist with any queries in relation to this Privacy Policy.
A little bit about what we do
Never Mind The Job Spec Ltd is classed as a human resources provision and management of human resources functions business on the UK.GOV Companies House. We are an independent talent solutions company that takes full ownership of the internal and external end-to-end recruitment, for both permanent, fixed-term contract and/or contract/interim hires, on behalf of our clients. We also support and guide our clients in the employment best practice for the region or country they are hiring. Collectively for the purposes of this policy, we refer to such activities as services.
So, the information we collect and use is for providing Services to our clients and candidates, i.e. finding suitable roles for candidates with our clients, supplier information of those who help us run our business, as well as acting as an employer for our own staff and operations.
Respecting your personal data
At Never Mind the Job Spec Ltd we understand the importance of processing and protecting personal data. We take such matters very seriously and have set out how we collect, store and use personal data in this Privacy Policy.
All our staff are tuned into protecting and respecting your information. We will only process your personal data in line with this Privacy Policy and relevant laws, i.e. UK Data Protection Act 2018 which incorporates GDPR, and Privacy and Electronic Communications Regulations. If we need to process your data for any other reason, we will always let you know in advance.
Where we are processing candidate data, we may act in the capacity of a data controller for our own operations, or as a data processor in accordance with our client’s requirements.
So, what personal data do we collect and where do we get it from?
We collect information about our clients, suppliers, candidates, as well as our own staff.
Clients and suppliers
The type of data we collect includes but is not restricted to the following:
name, job title, business addresses, phone or mobile numbers, email addresses, other contact details such as websites or sources such as LinkedIn and social networking sites
we may process data such as any communication we may have had with you about roles including (where applicable) feedback on our candidates
if you’re a supplier, about the services you provide to us
any business between us and you
other contacts within your organisation
we obtain (whether in person, on a call or email) the personal data from you, your colleagues, candidates, the public domain, social media or LinkedIn
Cookie Banner
To manage the cookies and similar technologies used (tracking pixels, web beacons, etc.) and related consents, we use the consent tool “Real Cookie Banner”. Details on how “Real Cookie Banner” works can be found at: https://devowl.io/rcb/data-processing/
The legal bases for the processing of personal data in this context are Art. 6 (1) lit. c GDPR and Art. 6 (1) lit. f GDPR. Our legitimate interest is the management of the cookies and similar technologies used and the related consents.
The provision of personal data is neither contractually required nor necessary for the conclusion of a contract. You are not obliged to provide the personal data. If you do not provide the personal data, we will not be able to manage your consents.
Candidates
The type of data we collect includes but is not restricted to the following:
name, address, phone or mobile numbers, email addresses, other contact details such as websites or sources such as LinkedIn and social networking sites
information you would expect to find on a CV, including your employment status, work history, experience, education, skills
right to work information and proof of ID which may include passport, visas, driving licence
any other relevant information provided by you to us in correspondence, whether in person, by email,
written letter, or telephone calls
details of referees who may provide a reference
in some cases, where required by our clients, we may need to process data from third parties such as the disclosure and barring service to check for any criminal convictions or credit reference agencies, if we need to check your financial status
we obtain (whether in person, on a call or email) the personal data from you e.g. receipt of a CV or registration, your referees, other candidates, clients where you are referred to us, job boards, the public domain, social media or LinkedIn, or other relevant third party providers.
Our staff
The type of data we collect includes but is not restricted to the following:
information you would expect to find on a CV, including your employment status, work history, experience, education, skills
right to work information and proof of ID which may include passport, visas, driving licence
any other relevant information provided by you to us in correspondence, whether in person, by email,
written letter, or telephone calls
bank details, so we can pay you, and national insurance numbers and any information required for
tax purposes
details of referees who may provide a reference
next of kin or emergency contact details
we obtain (whether in person, on a call or email) the personal data from you e.g. receipt of a CV, your referees, job boards, the public domain, social media or LinkedIn
What do we do with your data?
Clients and suppliers
We collect and store (electronically or occasionally hard copy) your personal data so we can:
communicate with you, whether it be in person, on a call, by email, by letter
to provide our Services to you, identify and assist with your recruitment needs
send information to our candidates
store records of any business between us and you
if you’re a supplier, details so you can supply your services to us
answer your queries when you contact us
adhere to any agreed contractual obligations
market our services we feel may be of interest to you
back up information on our systems
We collect and store (electronically or occasionally hard copy) your personal data so we can:
communicate with you, whether it be in person, on a call, by email, by letter
help you find suitable roles with our clients
send information (such as CVs or profiles) to our clients
store records of any business between us and you
answer your queries when you contact us
(as applicable) issue contracts and process timesheets so we can invoice our clients, and pay you
monitor equality and diversity
market our services we feel may be of interest to you
back up information on our systems
Our staff
We collect and store (electronically or occasionally hard copy) your personal data so we can:
communicate with you, whether it be in person, on a call, by email, by letter
store records of your employment with us and adhere to employment laws
issue contracts, store bank details and national insurance numbers so we can pay you
monitor equality and diversity
back up information on our systems
Who do we share your data with?
We only share your personal data where we have to, and this may include but is not limited to:
individuals, clients, and suppliers in order to provide our Services
conducting employment reference checks with previous employers
checking qualifications with educational institutions
any parties who process data on our behalf including our IT and cloud or storage providers, outsourced payroll providers, DBS checks or screening providers
our insurers or legal advisers
as required by statute, e.g. HMRC or the ICO
We only process your personal data where we have a lawful basis to do so
The following sets out our lawful basis to process your personal data:
Our Legitimate Interests (i.e. providing our Services)
These include:
providing our Services to you
keeping records of any business we conduct
dealing with your queries
improving our Services
marketing our Services
monitoring quality and compliance including compliance with this Privacy Policy
Legal obligation
We may need to process your personal data to comply with legal, statutory, or regulatory obligations. These may include:
Conduct of Employment Agencies and Employment Businesses Regulations 2003, which requires us to obtain certain information from clients and assess suitability of candidates against a client’s requirements.
data protection laws for keeping your data safe
tax obligations and reporting requirements to HMRC
anti-fraud or bribery laws for fraud/crime prevention
Performance of a contract
It may be necessary for us to process your personal data:
to perform our obligations under a contract with you
or to take steps to enter into a contract with you.
Consent and sensitive personal data
In certain cases, for example where a client requests we do so, we may be required to process special category or sensitive personal data. Such data requires more protection. This may include (as required) but is not limited to:
carrying out Disclosure and Barring Service criminal convictions checks
credit reports for financial status checks
medical records
psychometric tests or evaluations for specific roles
race, religion, sexual orientation, marital status etc. for the purpose of equal opportunity monitoring
For such special categories of data, you have the right to withdraw your consent at any time. We will only process such data for the specified purpose which we will always let you know in advance, and request written consent. Should you require such consent to be withdrawn you may exercise the right to do so – please see the section below Individual Rights.
Individual Rights
The UK GDPR provides the following rights for individuals: 1. The right to be informed;
2. The right of access;
3. The right to rectification;
4. The right to erasure;
5. The right to restrict processing;
6. The right to data portability;
7. The right to object;
8. Rights in relation to automated decision making and profiling.
See below for how you can exercise these rights with us:
Right to be informed
Where you provide your personal data directly to us, we will communicate our Privacy Notice to you at the earliest opportunity or as soon as we can. We will usually do this at the first point we correspond with each other. Our usual format for this is via email where you will find a link to this to this Privacy Policy which can also be found on our website.
Right of access
If you wish to receive a copy of personal data we store about you this can be made available on request. To do this please email hello@nevermindthejobspec.org adding ‘Data Subject Access Request’ in the subject field, and in the email include your name and contact details and your reason for requesting a copy of the data we store about you. To ensure we are sending your personal data to you, we may need to contact you to verify your identity. Once we have verified your identity, we will supply you with a digital record of all your personal data as soon as we can. This will be within thirty days.
We will not charge you for supplying copies of your personal data in the first instance. However, in the event we find data subject access requests to be unfounded or excessive, particularly where repetitive, we will need to consider the effort required to handle such requests and we may charge a reasonable administrative fee.
Right to rectification
Where you feel the personal data we hold about you is inaccurate or incomplete, you have the right to advise us and we will rectify such data in accordance with your instructions. Please email info@nevermindthejobspec.org adding ‘Data Rectification Request’ to the subject field, and in the email let us know what it is that needs to be rectified. We will try to action your request as soon as is reasonably practicable. This will be within thirty days.
Right to erasure
If you no longer want us to process your personal data, we can remove your personally identifiable data from our databases on request. To do this please email hello@nevermindthejobspec.org adding ‘Data Erasure Request’ to the subject field, and in the email include your name, contact details and the reason why you no longer want us to process your data. To ensure we are sending your personal data to you, we may need to contact you to verify your identity. Once we have verified your identity, we will aim to erase all related personal data as soon as we can and we will contact you to let you know once completed. This will be within thirty days.
Please note we will need to store some basic information including your full name and basic contact details which may include your email address or your telephone number. This is in order to ensure we do not duplicate process and we have a sufficient record to ensure we do not unnecessarily contact you or further process your personal data. Should you change your mind or require our services at a later date, you can simply email us at hello@nevermindthejobspec.org to let us know.
Right to restrict processing
If at any point you object to us using your data in a particular way you have the right to suppress or block us processing your data. For example, if you do not want us to use your data for marketing purposes simply let us know.
You can exercise this right at any time, please email info@nevermindthejobspec.org adding ‘Data Restriction Request’ to the subject field, and in the email include your name and contact details, the reason for your request and how you want us to restrict the processing of your data. We will attempt to action your request as soon as we can. This will be within thirty days.
Right to data portability
Where you have provided your data directly to us and (as applicable) it is processed by automated means, you have the right to receive personal data back from us in a structured machine readable format and where you request (and if possible) we will transmit your personal data to another data controller. We will always try to facilitate such request where it is technically feasible to do so.
Please note this right is only applicable where the processing is based on the individual’s consent or for the performance of a contract.
Should you wish to exercise this right at any time, please email hello@nevermindthejobspec.org adding ‘Data Portability Request’ in the subject field, and in the email include your name and contact details, and the reason for your request. We will attempt to action your request as soon as we can. This will be within thirty days.
The right to object
In the event you object to our processing of your data where we have identified that such processing is based upon legitimate interest and you believe there are no grounds for us to continue to process your data, then you have the right to object.
Should you wish to exercise this right at any time, please email info@nevermindthejobspec.org adding ‘Data Objection Request’ in the subject field, and in the email include your name and contact details, and the reason for your request. We will attempt to action your request as soon as we can. This will be within thirty days.
Rights in relation to automated decision making and profiling
In the event we use (as applicable) automated decision-making software, and if you disagree with any decision which affects you, you have the right to object.
Should you wish to exercise this right at any time, please email hello@nevermindthejobspec.org adding ‘Automated Decision Clarification Request’ in the subject field, and in the email include your name and contact details, and the reason for your request. We will attempt to action your request as soon as we can. This will be within thirty days.
Where and how we store your personal data
Any personal data that we collect from you will be transferred to, and stored by, a third-party database system with who we have contractual arrangements with. By submitting your personal data, you agree to this transfer, storing and processing of your data. We will take all reasonable steps necessary to ensure that your data is handled securely and in accordance with this Privacy Policy. Should you not wish us to process your data, please let us know at hello@nevermindthejobspec.org.
Keeping your personal data secure and safe
We take the safety and protection of your personal data very seriously and take all reasonable steps to ensure your data is protected. We work with our IT and storage providers to ensure they can provide ongoing confidentiality, integrity, availability and resilience of processing systems and services, to make breaches far less likely.
Your data will only be accessed by our staff and third parties where authorised to do so. This will be in circumstances where access is required for us to provide our Services to you.
We will work with our IT and storage providers and own staff to ensure appropriate organisational and technical measures are taken against any unauthorised or illegal processing of your personal data, including the accidental loss of or damage to it.
We have worked to ensure we have the technology, procedures and appropriate training of relevant individuals to keep your personal data secure and safe from when we collect it, until it is no longer processed or required, or removed at your request.
Where we share your personal data with third parties, we will only make transfers where they too have appropriate technical and organisational measures to keep your personal data secure.
For technical (practical) specific information concerning how Never the Job Spec protects, processes, and stores customer, client and supplier personal data please refer to our ‘Data Protection and Privacy manual’ document dated October 2022.
How long do we hold your personal data for?
We will only hold your personal data for as long as it is required to provide our Services to you.
If we believe your data is no longer of use to us, for example if your skills are not appropriate to the Services we offer, or where we feel your data is out of date, we will take steps to remove or update your information to ensure it is relevant and accurate in our database.
You may request we remove or update your information as necessary. If your data has not be accessed in 36 months either through use of our services or where we have not contacted each other, relevant records will be archived as appropriate.
We do not hold personal data for longer than we are required to do so. Generally, we hold information for 6 years from the last point of engagement.
Where applicable, we will hold relevant personal data for the purpose of providing to bodies such as HMRC, this may include records about your pay, bonuses, holiday or sick pay or pensions records. We will only keep such information for as long as HMRC may require it for the purposes of tax legislation.
Where we are contractually obliged to do so, where we are required by law, or where your personal data highlights a specialist or niche skillset which is likely lead to an engagement or opportunity with one of our clients, we may hold information for longer. If you do not wish us to process your data, then you can exercise your rights as detailed in the section above Individual Rights.
Transferring data outside of the EEA
While our business is based in the UK, we may need to transfer your personal data outside of the EEA should one of our clients, candidates or suppliers require it to do so, as we may be contractually obliged to do so in such circumstances. Where such information is to be transferred we will only do so where there is an adequacy decision from the EU commission, or where there is appropriate data protection legislation in place. Where there is no such adequacy decision we will take appropriate steps as far is reasonably practicable to understand how the data will be processed, and where we identify any risks, we will try to ensure your data is protected in line with any applicable data protection legislation, for example by use of the Model or Standard Contractual Clauses.
Questions about this Privacy Policy or Complaints
If you have any questions or if you wish to make a complaint about the way your data is processed by us, please contact Mr. Diego Crawford on +44(0) 7557 30 6462 in the first instance who will try to help resolve your query.
Where you feel we have not acted in accordance with this Privacy Policy or if you believe a security breach has taken place you may raise the matter with the Information Commissioner’s Office at:
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Any changes to this Privacy Policy
This Privacy Policy was last updated in October 2022.
In the event we make any changes to this Privacy Policy, we will update this website page.
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