Change IT Consulting

PRIVACY NOTICE (TIER 4) ( REF UK GDPR REC 4.1)

1. SCOPE

   1. All data subjects whose personal data is collected, in line with the requirements of the GDPR
      

2. RESPONSIBILITES

   1. The Data Protection Officer (DPO) is responsible for ensuring that this notice is made available to data subjects prior to Change IT Consulting Ltd] collecting/processing their personal data

   2. All Employees/Staff of Change IT Consulting Ltd who interact with data subjects are responsible for ensuring that this notice is drawn to the data subject’s attention and their consent to the processing of their data is secured. 
      
      

3. WHO ARE WE?

   Change IT Consulting Ltd is a recruitment consultancy specialising in the provision of contract (interim) and permanent recruitment services to the private and public sector.

   Our Data Protection Officer (DPO) and data protection representatives can be contacted directly here:

   • d.malkin@change-itc.com

   •  07865 062319

   • dpo@change-itc.com

THE PERSONAL DATA WE WOULD LIKE TO COLLECT COLLECT/PROCESS ON YOU

 

Personal data type:	Source (where Change IT Consulting Ltd obtained the personal data from if it has not been collected directly from you, the data subject. Note if the personal data has been accessed from publicly accessible sources):
Name	Application Forms, CV`s or resume
Address	Application Forms, CV`s or resume
Contact Details (tel no and e-mail)	Applications Forms, CV`s or resume
Personal details (NI number, Date of birth, Gender)	Application Form, CV, Resume, Passport or other identity documents
Details of Qualifications, skills, experience, employment history	Application Forms, CV`s or resume, References supplied from previous employers.  We will inform you that we are doing this,
Information about remuneration incl benefits	Application Form, interviews or other direct assessment
Whether you have a disability for which the organization needs to make reasonable adjustments during the recruitment process	Interview or direct assessment.
Information about Eligibility to work in the UK	Interview, CV or resume, Passport or other identity documents
References	Application Form, CV or resume, interview or other direct assessments

 

THE PERSONAL DATA WE COLLECT WILL BE USED FOR THE FOLLOWING PURPOSES: 

•      To enter a contract with you for recruitment services 

•      To comply with legal obligations of the recruitment process for example checking eligibility to work 

•      To present your work history portfolio, CV, Resume to a prospective client for the benefit of seeking employment.  Please note, all personal details will be removed at this stage. 

•      To update our Cloud based CRM to your availability for work and to present suitable opportunities to you in a time frame to be discussed or mutually agreed. 

•      Change IT Consulting Ltd has a legitimate interest in processing personal data during the recruitment process and for keeping records of the process.  This is to allow us to manage the recruitment process, assess and confirm a candidate`s suitability for employment and decide to whom to offer a job opportunity. 

•      If your application is unsuccessful, Change IT Consulting may keep your personal data on its CRM in case there are future employment opportunities for which you may be suited.  We will ask for your consent before keeping your data and you are free to withdraw your consent at any time. 

 

OUR LEGAL BASIS FOR PROCESSING THE PERSONAL DATA: 

•      Change IT Consulting needs to process data to take obligatory steps at your request prior to entering into a contract with you 

•    In some cases, we need to process data to ensure we are complying with our legal obligations to you, the end client and to UK law.  For example, it is mandatory to  check and supply details conforming to an applicant’s eligibility to work in the UK prior to employment commencement 

•    In some cases, we will be required to process personal data to ensure we are fulfilling preemployment checks for an end client, especially in the Public Sector 

 

ANY LEGITIMATE INTERESTS PURSUED BY US, OR THIRD PARTIES WE USE, ARE AS FOLLOWS: 

•      Change IT Consulting has a legitimate interest in processing personal data during the recruitment process and for keeping records of the process to cover any potential audit requests externally 

•    Processing data from applicants allows us to manage the recruitment process, assess and confirm a candidate’s suitability for employment and decide with whom we are to engage and employ 

•    We may also need to process data from job applicants to respond to and defend against legal claims 

 

THE SPECIAL CATEGORIES OF PERSONAL DATA CONCERNED ARE: 

•      Racial and Ethnic Origin 

•      Religious Beliefs 

•      Health data 

•      Sexual Orientation 

•      Disabilities 

•      We process such information to carry put our obligations and exercise specific rights in relation to employment.     

     

3.2           CONSENT

•      By consenting to this privacy notice you are giving us permission to process your personal data specifically for the purposes identified. 

•      Consent is required for Change IT Consulting Ltd to process both types of personal data, but it must be explicitly given. Where we are asking you for sensitive personal data we will always tell you why and how the information will be used.  

•      The data subject shall have the right to withdraw his or her consent at any time. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal. Prior to giving consent, the data subject shall be informed thereof. It shall be as easy to withdraw as to give consent.  In line with Withdrawal of Consent procedure GDPR DOC 2.7A   

If you wish to exercise any of your rights to remove your consent, please contact  David Malkin at d.malkin@change-itc.com  

 

3.3           DISCLOSURE

Change IT Consulting will not pass on your personal data to third parties without first obtaining your consent. The caveat to this will be when your application for employment is successful and there is an offer of employment forthcoming.  On receiving your consent, we will then share your data with former employers to obtain reference for you, employment background checks or any other necessary pre-employment checks.  

 

3.4           RETENTION PERIOD

If your application for employment is unsuccessful, the organisation will hold your data on file for 6 (six) months after the end of the relevant recruitment process. If you agree to allow us to keep your personal data on file, we will hold your data on file for a further 6 (six) months for consideration for future employment opportunities. At the end of that period, or once you withdraw your consent, your data is deleted or destroyed. You will be asked when you submit your CV whether you give us consent to hold your details for the full 12 months in order to be considered for other positions or not. If your application for employment is successful, personal data gathered during the recruitment process will be transferred to your placement folder within the CRM (electronic) and retained during your employment. The periods for which your data will be held will be provided to you in a new privacy notice. 

         

3.5           YOUR RIGHTS AS A DATA SUBJECT

At any point while we are in possession of or processing your personal data, you, the data subject, have the following rights: 

•      Right of access – you have the right to request a copy of the information that we hold about you. 

•      Right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete. 

•      Right to be forgotten – in certain circumstances you can ask for the data we hold about you to be erased from our records. 

•      Right to restriction of processing – where certain conditions apply to have a right to restrict the processing. 

•      Right of portability – you have the right to have the data we hold about you transferred to another organisation. 

•      Right to object – you have the right to object to certain types of processing such as direct marketing. 

•      Right to object to automated processing, including profiling – you also have the right to be subject to the legal effects of automated processing or profiling. 

•      Right to judicial review: in the event that Organisation Name refuses your request under rights of access, we will provide you with a reason as to why. You have the right to complain as outlined in clause 3.6 below. 

All of the above requests will be forwarded on should there be a third party involved (as stated in 3.4 above) in the processing of your personal data.  

3.3           DISCLOSURE

Change IT Consulting will not pass on your personal data to third parties without first obtaining your consent. The caveat to this will be when your application for employment is successful and there is an offer of employment forthcoming.  On receiving your consent, we will then share your data with former employers to obtain reference for you, employment background checks or any other necessary pre-employment checks.  

 

3.4           RETENTION PERIOD

If your application for employment is unsuccessful, the organisation will hold your data on file for 6 (six) months after the end of the relevant recruitment process. If you agree to allow us to keep your personal data on file, we will hold your data on file for a further 6 (six) months for consideration for future employment opportunities. At the end of that period, or once you withdraw your consent, your data is deleted or destroyed. You will be asked when you submit your CV whether you give us consent to hold your details for the full 12 months in order to be considered for other positions or not. If your application for employment is successful, personal data gathered during the recruitment process will be transferred to your placement folder within the CRM (electronic) and retained during your employment. The periods for which your data will be held will be provided to you in a new privacy notice.  

 

                 

3.5           YOUR RIGHTS AS A DATA SUBJECT

At any point while we are in possession of or processing your personal data, you, the data subject, have the following rights: 

•      Right of access – you have the right to request a copy of the information that we hold about you. 

•      Right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete. 

•      Right to be forgotten – in certain circumstances you can ask for the data we hold about you to be erased from our records. 

•      Right to restriction of processing – where certain conditions apply to have a right to restrict the processing. 

•      Right of portability – you have the right to have the data we hold about you transferred to another organisation. 

•      Right to object – you have the right to object to certain types of processing such as direct marketing. 

•      Right to object to automated processing, including profiling – you also have the right to be subject to the legal effects of automated processing or profiling. 

•      Right to judicial review: in the event that Organisation Name refuses your request under rights of access, we will provide you with a reason as to why. You have the right to complain as outlined in clause 3.6 below. 

All of the above requests will be forwarded on should there be a third party involved (as stated in 3.4 above) in the processing of your personal data. 

 

                 

3.6            YOUR RIGHTS AS A DATA SUBJECT

In the event that you wish to make a complaint about how your personal data is being processed by Change IT Consulting Ltd (or third parties as described in 3.4 above), or how your complaint has been handled, you have the right to lodge a complaint directly with the supervisory authority and Change IT Consulting’s data protection representatives [Data Protection Officer (DPO)], David Malkin GDPR Owner/David Malkin  

 

	Supervisory authority contact details	[Data Protection Officer (DPO)] /  [GDPR Owner] contact details
Contact Name:	David Malkin	David Malkin
Address line 1:	95 Spencer Street	95 Spencer Street
Address line 2:	Jewellery Quarter	Jewellery Quarter
Address line 3:	Birmingham	Birmingham
Address line 4:	B186DA	B186DA
Email:	d.malkin@change-itc.com	d.malkin@change-itc.com
Telephone:	07865 062319	07865 062319

   

             

data subject shall have the right to withdraw his or her consent at any time. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal. Prior to giving consent, the data subject shall be informed thereof. It shall be as easy to withdraw as to give consent.  In line with Withdrawal of Consent procedure GDPR DOC 2.7A 

4                     ONLINE PRIVACY STATEMENT

PERSONAL DATA 

Under the UK & EU’s General Data Protection Regulation (GDPR) personal data is defined as:  

“any information relating to an identified or identifiable natural person ('data subject'); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person”. 

 

HOW WE USE YOUR INFORMATION 

This privacy notice tells you how we, Change IT Consulting will collect and use your personal data for recruitment campaigns, profiling, recruitment reviews, securing employment contracts, manage your recruitment process, assess and confirm a candidate`s suitability for a position and carry out all relevant pre-employment background checks. 

 

WHY DOES CHANGE IT CONSULTING LTD NEED TO COLLECT AND STORE PERSONAL DATA? 

In order for us to provide you with a complete recruitment process we need to collect personal data for determining suitability for a position, marketing your application in the most appropriate manner and carry out all relevant background checks on successful hiring.  In any event, we are committed to ensuring that the information we collect, and use is appropriate for this purpose, and does not constitute an invasion of your privacy.  

In terms of being contacted for marketing purposes Change IT Consulting Ltd would contact you for additional consent. 

 

WILL CHANGE IT CONSULTING LTD SHARE MY PERSONAL DATA WITH ANYONE ELSE? 

We may pass your personal data on to third-party service providers contracted to Change IT Consulting Ltd in the course of dealing with you. Any third parties that we may share your data with are obliged to keep your details securely, and to use them only to fulfill an already disclosed service on our behalf.  When they no longer need your data to fulfil this service, they will dispose of the details in line with Change IT Consulting’s procedures. If we wish to pass your sensitive personal data onto a third party we will only do so once we have obtained your consent, unless we are legally required to do otherwise. 

 

HOW WILL CHANGE IT CONSULTING LTD USE THE PERSONAL DATA IT COLLECTS  ABOUT ME? We may pass your personal data on to third-party service providers contracted to Change IT Consulting Ltd in the course of dealing with you. Any third parties that we may share your data with are obliged to keep your details securely, and to use them only to fulfill an already disclosed service on our behalf.  When they no longer need your data to fulfil this service, they will dispose of the details in line with Change IT Consulting’s procedures. If we wish to pass your sensitive personal data onto a third party we will only do so once we have obtained your consent, unless we are legally required to do otherwise

 

 

UNDER WHAT CIRCUMSTANCES WILL CHANGE IT CONSULTING LTD CONTACT ME?    

Our aim is not to be intrusive, and we undertake not to ask irrelevant or unnecessary questions. Moreover, the information you provide will be subject to rigorous measures and procedures to minimise the risk of unauthorised access or disclosure. 

             

CAN I FIND OUT THE PERSONAL DATA THAT THE ORGANISATION HOLDS ABOUT ME? 

Change IT Consulting Ltd at your request, can confirm what information we hold about you and how it is processed. Change IT Consulting Ltd does hold personal data about you, you can request the following information:  

 

•      Identity and the contact details of the person or organisation that has determined how and why to process your data. In some cases, this will be a representative in the EU.  

•      Contact details of the data protection officer, where applicable. 

•      The purpose of the processing as well as the legal basis for processing. 

•      If the processing is based on the legitimate interests of Change IT Consulting Ltd or a third party, information about those interests. 

•      The categories of personal data collected, stored and processed. 

•      Recipient(s) or categories of recipients that the data is/will be disclosed to. 

•      If we intend to transfer the personal data to a third country or international organisation, information about how we ensure this is done securely. The EU has approved sending personal data to some countries because they meet a minimum standard of data protection.
In other cases, we will ensure there are specific measures in place to secure your information. 

•      How long the data will be stored. 

•      Details of your rights to correct, erase, restrict or object to such processing. 

•      Information about your right to withdraw consent at any time. 

•      How to lodge a complaint with the supervisory authority. 

•      Whether the provision of personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract, as well as whether you are obliged to provide the personal data and the possible consequences of failing to provide such data. 

•      The source of personal data if it wasn’t collected directly from you. 

•      Any details and information of automated decision making, such as profiling, and any meaningful information about the logic involved, as well as the significance and expected consequences of such processing. 

 

WHAT FORMS OF ID WILL I NEED TO PROVIDE IN ORDER TO ACCESS THIS?  

Change IT Consulting Ltd accepts the following forms of ID when information on your personal data is requested: 

Passport, Driving Licence, Birth certificate, Utility Bill (from the last 3 months) 

                 

CONTACT DETAILS OF THE [DATA PROTECTION OFFICER (DPO)] / [GDPR OWNER]: 

 

	[Data Protection Officer (DPO)] / [GDPR Owner] contact details
Contact Name:	David Malkin
Address line 1:	95 Spencer Street
Address line 2:	Jewellery Quarter
Address line 3:	Birmingham
Address line 5:	B186DA
Email:	d.malkin@change-itconsulting.com
Telephone:	07865 062319

 

 

DOCUMENT OWNER AND APPROVAL

The Data Protection Officer (DPO) is the owner of this document and is responsible for ensuring that this record is reviewed in line with the review requirements of the GDPR. 

A current version of this document is available to all members of staff on the shared CRM and is published and can be seen on request. 

A current version of this document is available to all members of staff on the shared CRM and is published and can be seen on request.