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Privacy Policy

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DATE:                                 May 2018

REVIEW DATE:                  May 2019

VERSION:                           2


Swanstaff Recruitment Limited (‘the Company’), registered number 03121740 of Lakeview West, Galleon Boulevard, Dartford, Kent DA2 6QE 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.

This policy aims to inform our candidates, clients and website users how we are committed to protecting individuals’ privacy and data.  It sets out to inform you about the types of personal data we collect from candidates, the purposes for which we use the data and the ways that the data is handled.  In line with the EU General Data Protection Regulation 2016/679 (“GDPR”) and UK laws implementing GDPR.

You may give your personal details to the Company directly, such as on an application or registration form or via our website, or we 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 we will only use your personal data in accordance with this privacy policy. At all times we will comply with current data protection laws.


1.    Collection and use of personal data

  • a.    Purpose of processing and legal basis
  • b.    Legitimate interest
  • c.    Statutory/Contractual requirement
  • d.    Recipients of data

2.    Information to be provided when data is not collected directly from the data subject

a.    Categories of data

b.    Sources of data

3.    Overseas transfers

4.    Data retention

5.    Your rights

6.    Cookies

7.    Login files

8.    Links to external sites

9.    Sale of the business

10.  Data security

11.  Changes to this privacy policy

12.  Complaints or queries

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.

If you have opted-in we may also send you marketing information and news via email/ text.  You can opt-out from receiving these at any time by clicking “unsubscribe” when you receive these communications from us.

In some cases we 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. We may also use your information during the course of internal audits to demonstrate our compliance with certain industry standards.

We must have a legal basis to process your personal data. The legal bases we rely upon to offer our work-finding services to you are:

  • Where we have a legitimate interest – either we, or a third party, will need to process personal data for the purposes of our legitimate interests, provided we have established that those interests are not overridden by your rights and freedoms, including your right to protect your data.  Legitimate interests include optimising our website and user experience, informing you of our products and services, updating you on processes and procedures and operational changes, responding to requests and enquiries from you or a third party
  • To comply with a legal obligation that we have – we are subject to certain legal requirements which may require us to process your personal data.  We may also be legally obligated to disclose your personal information to a regulatory body or law enforcement agency
  • To fulfil a contractual obligation that we have with you – in order to enter into a contract with you, or to perform our obligations of a contract with you, we are required to process your personal data
  • Your consent – in some circumstances, we will ask for your consent to process your personal data in a particular way

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:

  • To provide our services to you;
  • To manage our database and keeping work-seeker records up to date;
  • To match your details and requirements against relevant job opportunities and to assist you to find suitable positions, including sending your information to clients where you have demonstrated an interest in doing that particular type of work;
  • Contacting you to seek your consent where we need it;
  • To give you information about similar products or services that you have used from us recently;
  • To market products or services that we think would be of interest to you, updating you on industry news or changes, informing you of events, promotions and competitions, reports and other information.  We will give you the option to opt out of such communications and an option to unsubscribe will be provided within each communication;
  • To personalise your website and mobile app experience to reflect your preferences;
  • To answer your enquiries;
  • To fulfil our contractual obligations with clients;

This list is not intended to be exhaustive.

c.    Statutory/Contractual requirement

The Company has certain legal and contractual requirements to collect personal data (e.g. to comply with the Conduct of Employment Agencies and Employment Businesses Regulations 2003, immigration and tax legislation, and in some circumstances safeguarding requirements.)  Our clients may also require this personal data, and/or we may need your data to enter into a contract with you. If you do not give us personal data we need to collect we may not be able to continue to provide work-finding services to you. 

d.    Recipient/s of data

The Company will process your personal data and/or sensitive personal data with the following recipients:

  • Clients (whom we may introduce or supply you to)
  • Former employers whom we may seek references from
  • Prospective new employers that you wish for us to provide details to
  • The Recruitment and Employment Confederation or other relevant trade bodies where relevant
  • Third parties that carry out audits to ensure our adherence to legal or contractual requirements
  • Payroll service providers who manage payroll on our behalf or other payment intermediaries whom we may introduce you to
  • Other recruitment agencies in the supply chain, where relevant
  • Our insurers if necessary
  • Our legal advisors if required
  • Our IT and CRM providers – Oxford Software, Emerito & ITRM
  • Public information sources and third party organisations where we process data to carry out suitability checks on work seekers e.g. Companies House, the Disclosure and Barring Service (DBS), Nursing and Midwifery Council (NMC), General Medical Council (GMC), DVLA, credit reference agencies
  • Government, law enforcement agencies and other regulators e.g. the Police, Home Office, HMRC, Employment Agency Standards Inspectorate (EASI), Local Authority Designated Officers (LADOs), Gangmasters Licensing Authority
  • Trade unions if recognised
  • Other organisations you request us to share your details with e.g.  mortgage companies, letting agencies, debt companies

2.   Information to be provided when data collected not from the data subject

Swanstaff collect data from candidates when they apply for positions and/or register with us as detailed in Section 1.  As a recruitment business, we collect data on potential job seekers using various other methods.

a. Categories of data:

The Company may collect the following personal data on you, usually from your Curriculum Vitae (“CV”) or job seeker profile:

Personal data:

  • Name, address, mobile no., email address
  • National insurance no.
  • Nationality (through right to work check)
  • Work history & preferences
  • Qualifications, training and education history
  • Hobbies and interests

Sensitive personal data:

  • Health information including whether you have a disability
  • Criminal conviction information from the Disclosure and Barring Service
  • Religious beliefs or values
  • Race or ethnic origin
  • Sexual preferences

b. Source of the personal data:

The Company sources personal data/sensitive personal data:

  • From jobs boards such as Reed, CV Library, Monster, Total Jobs, Indeed, LinkedIn, Recruitive, Job Mate
  • A former employer or colleague
  • A referee whose details you provided to us
  • Cookies listed in section 6

This information came from a publicly accessible source or a service you signed up for and gave permission for them to share your data; such as a job board.

3.   Overseas Transfers

The Company will not transfer 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 EEA comprises the EU member states plus Norway, Iceland and Liechtenstein.

4.   Data Retention

The Company will retain your personal data only for as long as is necessary for the purpose we collect it. Different laws may also require us to keep different data for different periods of time. For example, 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 we last provide you with work-finding services.

We must also keep your payroll records, holiday pay, maternity 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. This is currently 3 to 6 years.

Where the Company has obtained your consent to process your personal and sensitive personal data, we will do so in line with our retention policy. 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.

Terms of engagement with temporary workers and terms of business with clients must be retained for a period of 6 years in case of any potential civil claim under the Limitation Act 1980.

Working time records must be kept for 2 years from the time that they were created.

Annual appraisal/assessment records will be kept as long as necessary, usually 1 year after employment or engagement has ended.

References will be kept for a minimum period of 1 year and are kept for the duration of a temporary worker’s engagement with Swanstaff.

Right to work in the UK information must be kept for 2 years after employment or engagement has ended.

Gender pay gap reporting information is to be retained by Swanstaff for 1 year but will be retained on the government website and the Swanstaff website for 3 years.

5.   Your rights

Please be aware that you have the following data protection rights:

  • The right to be informed about the personal data the Company processes on you;
  • The right of access to the personal data the Company processes 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 data and sensitive personal data you have the right to withdraw that consent at any time by contacting our HR Department by email to gdpr@swanstaff.co.uk or by post to our Head Office address; Lakeview West, Galleon Boulevard, Dartford, Kent DA2 6QE.  Please note that if you withdraw your consent to further processing that does not affect any processing done prior to the withdrawal of that consent, or which is done according to another legal basis.

There may be circumstances where the Company will still need to process your data for legal or official reasons. Where this is the case, we will tell you and we will restrict the data to only what is necessary for 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 we 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.

6. Cookies

We may obtain data about you from cookies.  These are small text files that are placed on your computer by websites that you visit. They are widely used in order to make websites work, or work more efficiently, as well as to provide information to the owners of the site. Cookies also enable us to deliver more personalised content on our website and within our communications to you.

We use cookies to save information about what type of job or course you're looking for on our website. This allows easy access to our site, with recommendations that are relevant to you. If your computer is shared by other people, we advise that you untick the 'keep me signed in' checkbox when you sign in to www.swanstaff.co.uk. This will remove all details from the cookie.

Swanstaff uses Google AdWords conversion tracking to measure advertising performance and improve the quality of the adverts you see. Find out more about Google Site Statistics visit https://services.google.com/sitestats/en.html?cid=1070115141

Most web browsers allow some control of most cookies through the browser settings. If you would like more information about cookies, go to the website All About Cookies - www.allaboutcookies.org.

Please note that in a few cases some of our website features may not function if you remove cookies from your browser.

7. Log Files

We use IP addresses to analyse trends, administer the site, track users’ movements, and to gather broad demographic information for aggregate use.  IP addresses are not linked to personally identifiable information.

8. Links to external websites

The Company’s website may contains links to other external websites. Please be aware that the Company is not responsible for the privacy practices of such other sites.  When you leave our site we encourage you to read the privacy statements and/or policies of each and every website that collects personally identifiable information.  This privacy policy applies solely to information collected by the Company’s website. 

9. Sale of business

If the Company’s business is sold or integrated with another business your details may be disclosed to our advisers and any prospective purchasers and their advisers and will be passed on to the new owners of the business.

10. Data Security

The Company takes every precaution to protect our users’ information. Only employees who need the information to perform a specific job (for example, consultants, our accounts team or a marketing assistant) are granted access to your information.

Our internal CRM system, Aspire, is held on our central server.  Swanstaff uses SSL Sha256 certificate encryption when connections to the server are made. Only authenticated users that have been created and authorised by HR have access. These accounts are set to have their passwords changed at first login, and then a minimum of every 60 days. The passwords must contain uppercase, lower case, numbers & a special character.

Each server is installed with a firewall and antivirus which are centrally controlled by the IT team. The servers sit behind a Drayek 3900 firewall that is locked down to only allow connections from known locations.

Access to the files on the server is managed via an active directory, each folder structure is built to only allow the necessary users access; including limiting edit and delete rights, and this is reviewed quarterly by our Internal IT team.

The hard drives that hold the data are encrypted using BitLocker. When the data is backed up and stored it is encrypted using ShadowProtect.

The Company uses all reasonable efforts to safeguard your personal information. However, you should be aware that the use of email/ the Internet is not entirely secure and for this reason the Company cannot guarantee the security or integrity of any personal information which is transferred from you or to you via email/ the Internet.

If you share a device with others we recommend that you do not select the “remember my details” function when that option is offered.

If you have any questions about the security at our website, you can email gdpr@swanstaff.co.uk.

11. Changes to this privacy policy

Due to pending UK legislation and the nature of the subject within this policy, there are likely to be changes after the 25th May 2018.  This policy is intended to be a working document and we will update this privacy policy as and when required.  We will post any changes on the policy with revision dates.  If we make any material changes, we will notify you.

12. Complaints or queries

If you wish to complain about this privacy notice or any of the procedures set out in it please contact Swanstaff first using the details below:

By email to: 


By post to:      

HR Department

Swanstaff Head Office

Lakeview West

Galleon Boulevard




You also have the right to raise concerns with Information Commissioner’s Office on 0303 123 1113 or at https://ico.org.uk/concerns/, 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.