Privacy Notice - May 2018
Square One Resources Limited is committed to protecting and respecting your privacy.
This policy sets out the basis on which your personal data will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how it will be treated by us.
For the purpose of the General Data Protection Regulations (the “Regulations”) the data controller is: Square One Resources Limited of 6 Devonshire Square, London, EC2M 4YE.
Data Privacy Principles
The core data privacy principles below are the foundation of this policy:
Lawfulness, fairness and transparency
Square One shall process personal information fairly, and in accordance with this policy and applicable laws.
Square One will take all reasonable steps to ensure that personal information is accurate and complete and will rectify or erase any incorrect personal information without delay.
Square One will ensure that personal information collected is for specified, explicit and legitimate purposes and only to the extent necessary to fulfil those purposes.
Square One will only keep personal data for as long as is necessary to fulfil the purposes for which it was collected or to comply with applicable law/for tax purposes/for Government or regulatory requirements.
All personal information collected will be processed in a secure manner.
Information we may collect
We may collect and process the following data about you:
- Information that you provide by filling in forms on our site. This includes your CV and any other information provided at the time of registration or at the time of posting material or requesting further services.
- Information that is available to Square One either publicly or through such services as job boards and social media accounts
- Where we are or propose to provide our professional services to you, such relevant information including your contact information, professional information (such as your job title and particular skills), right to work documentation (if applicable), If you contact us, we may keep a record of that correspondence.
- Square One may also ask you to complete surveys that we use for research purposes, and other marketing campaigns although you do not have to respond to them.
- Details of your visits to our site and the resources that you access.
- Information necessary to continue a professional relationship.
Reason for collecting information
Square One is an employment business and employment agency (as defined by the Conduct Regulations). With this purpose in mind, in pursuit of these legitimate interests, Square One will process information relevant to our business and in order to be able to provide professional services to potential and current candidates and clients.
Basis for collecting information
Square One will only collect and use information as described in this policy or as expressly advised to you. Depending on the nature of the information, we will process data in order to comply with applicable laws and regulations relevant to Square One’s business. In addition to this, where the apparent processing appears to go beyond legal or governmental requirements, Square One will be processing information in accordance with our “legitimate interests” where we have determined that such interests are not overridden by your interests or fundamental rights and freedoms.
IP Addresses and Cookies
We may collect information about your computer including where available your IP address, operating system and browser type for system administration. This is data about our users’ browsing actions and patterns and does not identify any individual.
For the same reason we may obtain information about your general Internet usage by using a cookie file which is stored on the hard drive of your computer. Cookies contain information that is transferred to your computer’s hard drive. They help us to improve our site and to deliver a better and more personalised service. They enable us:-
- to estimate our audience size and usage pattern;
- to store information about your preferences and so allow us to customise our site according to your individual interests;
- to speed up your searches;
- to recognise you when you return to our site.
You may refuse to accept cookies by activating the setting on your browser, which allows you to refuse the setting of cookies. However, if you select this setting you may be unable to access certain parts of our web site.
Where we store your personal data
All information you provide to us is stored on our secure servers. Where we have provided 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. So, whilst we will do our best to protect your personal data, we cannot ensure 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 prevent unauthorised access.
How long will we store data?
This will depend on a number of factors, but will centralise around the nature of our relationship with you. For each category of data, we have considered the manner in which we process data against the rights and freedoms of the individual to ensure that we are acting reasonably and proportionately.
Broadly speaking there are two scenarios that will determine the timeframes for retention of data:
- Legally/financially - For example, in accordance with standard accounting practice, we will retain finance related data, such as records of payments, invoice details, etc. for a period of 7 years unless, in the unlikely event, there are mitigating factors that allow us to keep data for longer.
- Commercially – for legitimate business reasons we will retain data for a reasonable period of time where we may need to contact you in the future.
“Reasonable Period of Time”
What that reasonable period of time is will depend on your particular situation. For example, we have taken the view that for Contractors and Candidates, we would need to retain basic contact information together with a summary of your skills and experiences (which will most likely be in the form of your CV). In our opinion, it would be reasonable to retain such information for a period of 3 years after last contact, unless there are additional factors to consider (for example, if you say you are on a project for the next 18 months and we should contact you then).
Where you are a Contractor and we have entered into contractual agreements for your services, we will naturally hold contact information for you, and such information will be held in accordance with the principles above. However, we will also have been sent financial information, background information and right to work documentation. Due to the increased sensitivity involved with this type of information, unless there are additional factors to consider, we will only hold such information for the duration of your contract and for a period of 5 years after expiry of your contract.
Use of the information
We may use information held about you in the following ways:
- to comply with applicable laws and regulations as well as contractual requirements with third parties;
- to ensure that content from our web site is presented in the most effective manner for you and for your computer
- to provide you with information or services;
- to allow you to participate in interactive features of our service where you choose to do so;
- to notify you about changes to our service.
Where you provide us with a copy of your CV we may reformat the information contained in it using our standard template before providing it to any potential employer. We will not, however, make any material changes to the information.
We may disclose your personal information to any member of the Square One Resources Limited group. This means any subsidiaries, any ultimate holding company and its subsidiaries as defined in section 1159 of the UK Company Act 2006.
We may disclose your personal information to third parties:
- in the event that we sell or buy any business or assets in which case we may disclose your personal data to the seller or buyer of such business or assets;
- if Square One Resources 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 of course 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 in order enforce or apply our Terms and Conditions and other agreements; or protect the rights, property, or safety of Square One Resources Limited, our customers, or others. This may include exchanging information with other companies and organisations for fraud protection and credit risk reduction. We may from time to time use your data to carry out reference and security checks. Where potential employers require us to assist them in the carrying out of criminal record searches or police checks you agree that we have the right to use your data for this purpose.
We will provide your data to potential employers that have notified us of vacancies for which you may be qualified but only with your express permission. It is your responsibility to notify us of any employers to whom you do not wish to submit your details.
You have the right to request us not to disclose any of your personal data or information or to pass information to third parties as well as the following:
- Review of the information we hold about you;
- Correction of this information if it is factually wrong;
- Erasure of your personal data or restrict the processing concerning of personal data concerning to you under certain circumstances;
- Provision of copies of the personal data which you have provided us via the forms, in a structured, commonly used and machine-readable format.
We will usually inform you before collecting your data, if we intend to disclose your information to any third party and you can exercise that right by contacting us at firstname.lastname@example.org. In addition, should you feel that Square One have misused your data or in breach of the GDPR, you should also feel free to contact the ICO.
Following the introduction of the GDPR, you will have additional rights including the right to be forgotten and to data rectification.
These standards apply to any and all material (“Contributions”) which you contribute to our site or to any interactive features associated with it. This includes without limitation any contribution that you make to:
- Chat rooms
- Bulletin boards
You must comply with the spirit of the following standards (as well as any additional relevant documents). The standards apply to each part of any Contribution as well as to its whole.
Be accurate where they state facts;
Be genuinely held where they state opinions;
Comply with applicable law in any country from which they are posted (In any event you should remember that our site is aimed at UK users only).
Contributions must not:
- Contain any material which is defamatory of any other person;
- Contain any material which is obscene or offensive;
- Infringe any copyright, database right or trade mark of any other person;
- Be likely to deceive any person;
- Be made in breach of any legal duty owed to a third party such as a contractual duty or a duty of confidence;
- Be likely to harass, upset, embarrass, alarm or annoy any other person;
- Be likely to disrupt our service in any way;
- Give the impression that they emanate from us where this is not the case;
- Advocate promote or assist any unlawful act such as (by way of example only) copyright infringement or computer misuse;
Access to information
The Act gives you various rights including the right to access information held about you. Your right to access can be exercised in accordance with the Act.