5Values is a recruitment business which provides work-finding services to its clients and to work-seekers. 5Values must process personal data (including sensitive personal data) in order to provide these services. In so doing, 5Values acts as a data controller within the meaning of the UK General Data Protection Regulation (UK GDPR).
5Values is committed to protecting and respecting individuals’ privacy and to being transparent on how we use data. This notice sets out the basis on which any personal data that is collected from you, or that is provided to us, will be processed.
The UK GDPR (Regulation (EU) 2016/679) is a regulation which replaces the Data Protection Regulation (Directive 95/46/EC). The Regulation aims to harmonise data protection legislation across EU members states and to provide a strict framework for commercial organisations. The Brexit transition period ended on 31 December 2020 and the UK has now officially left the EU. The UK GDPR has been directly incorporated into UK law.
For the purpose of data protection legislation in force from time to time, the data controller is 5Values Consulting Group Limited, 2nd Floor, One Castle Park, Tower Hill, Bristol, BS2 0JA (‘5Values’).
You may give your personal details to 5Values directly, such as on an application form or via our website or we may collect them from another sources such as a job board. 5Values must have a legal basis for processing your personal data under the UK GDPR. For the purpose 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 the terms of the following statement.
Summary of 5Values
5Values is a recruitment agency and a recruitment business as defined in the Employment Agencies and Employment Businesses Regulations 2003 (‘Our Business’). We also provide the following services:
Who 5Values collects personal data from
5Values collects personal data of the following types of people to allow us to undertake our business:
Prospective and placed candidates for temporary and permanent roles;
Prospective and live client contacts;
Supplier contacts to support our services;
Employees, consultants and temporary workers;
Referees and emergency contacts – for candidates, employees and prospective employees;
Other professional contacts e.g. podcast attendees.
5Values collects information about you to carry out our core business and ancillary activities.
Information that you give to 5Values or we collect about you
This is information about you that you give to 5Values by:
Filling in forms on our website
Corresponding with us by email, phone or otherwise
Registering or subscribing for our services
Entering our database
Attending our events (either virtually, online or in person)
Participating in discussion boards or other social media functions on our site or social media pages
Entering a survey or competition or promotion
Reporting a problem with our site
Applying for roles advertised on job boards or third party websites.
The information that you provide or that 5Values collects from you may include: your name, address, date of birth, private and corporate email address, phone number, financial information such as bank details, national insurance number, compliance documentation, references verifying your qualifications/experience, right to work documentation, curriculum vitae, photograph, links to your professional profiles available in the public domain or corporate website.
Information that 5Values collects when you visit our website
With regards to each of your visits to our website, 5Values will automatically collect the following information:
Technical information including the internet protocol (IP) address used to connect your computer to the internet, your login information if applicable, browser type and version, information about your visit including the full Uniform Resource Locators (URL), clickstream to, through and from our site (including date and time), page response times, download errors, length of visits to certain pages and page interaction information (such as scrolling, clicks and mouse-overs) and any phone number used to contact our offices.
Information we obtain from other sources
This is information that 5Values obtains about you from other sources such as LinkedIn, Facebook, social media sites, corporate websites, job board websites, online CV libraries, your business card, company registration databases and personal recommendations. Where your information is added to our database from any of these sources, we will notify you within 30 days of collecting the data of the fact that we hold personal data about you and for what purpose that we intend to retain and process it.
5Values works closely with third parties, including sub-contractors in technical, professional, payment and other services, advertising networks, analytic providers, credit reference agencies and professional advisors. 5Values may receive information about you from them or may share information with them for the purpose of our recruitment services and ancillary support services.
Purpose and legal basis of processing
5Values will collect your personal data (which may include special category personal data) and we will process said data for the purposes of:
Providing you with information, products and services that you request from us or we think will be of interest to you because it is relevant to your career or to your organisation;
Providing you with information about other goods and services we offer that are similar to those that you have already purchased, been provided with or enquired about;
Improving our service. Our core service is the introduction of candidates to our clients for the purpose of temporary or permanent engagement. However, our service expands to supporting individuals throughout their career and to support businesses with their resourcing needs and strategies.
The legal bases that 5Values relies on to offer its services and for processing personal data are:
Where 5Values relies on legitimate interest to process and retain personal date, our legitimate interests are as follows:
As a recruitment business and recruitment agency, our aim is to introduce candidates to clients for permanent employment, temporary assignments or independent professional contracts. The exchange of personal data of our candidates and our client contact details is a fundamental part of this process. To be able to deliver our services, 5Values needs to be able to contact candidates and clients on a regular basis via email, telephone, online or notifications such as job alerts.
In order to offer this service and support our candidates’ career aspirations and our clients’ resourcing needs, 5Values requires a database of client and candidate data./ The database will contain both historical and current candidate information, client contacts and resourcing requirements. To maintain, expand and develop our business, 5Values also needs to record personal data of prospective candidates and client contacts.
5Values will provide work finding services through a variety of means including, but not limited to: searching on its database, advertising for applicants, searching online job boards such as Job Site, LinkedIn and social media platforms or networking sites.
5Values considers that it is reasonable to expect that if a candidate has applied to an advert, registered on our website, uploaded their details to a job board or has an ‘Open to Opportunities’ status on social media then they are happy for us to collect and use their personal data to provide recruitment services on the basis of legitimate interest.
In the event that consent is required to lawfully process your data, 5Values will request consent from you. This consent can be provided orally, in writing (including by email) or by an online process and your response will be recorded on our system.
Where consent is the only lawful basis for our processing of your personal data, you have the right to withdraw your consent to this particular processing at any time. Please email firstname.lastname@example.org in order to notify us of a withdrawal of consent.
Consent may be required in the following situations:
To request information such as references, verification of qualifications or relating to criminal convictions to the extent that this is permissible, appropriate and in accordance with local laws.
Send you details of promotions, offers, networking and client events which we think may be of interest to you.
Proactively market your details to our clients or on our website or social media channels with the purpose of generating interest and suitable jobs on your behalf.
5Values will rely on legal or contractual obligation to process personal data when:
It is required by law;
It is necessary in order to enter into a contract or agreement to provide services to you or your organisation; and/or
Where you are providing services to us.
Other uses that 5Values may make of your data
We will also use your data:
To improve and administer our website and for internal operations such as troubleshooting, data analysis, research and statistical purposes.
To notify you about changes to our service.
To make suggestions and recommendations to you and others about our services that may be of interest to you or others.
To measure and understand the effectiveness of advertising we serve to you and others and to deliver relevant advertising to you.
To ensure that our website and database remains safe and secure.
To keep our database updated.
To allow you to participate in interactive features of our service should you choose to do so.
Automated decision making
5Values does not undertake automated decision making and profiling. A person will always be involved in the decision-making process and we use our systems to search and identify personal data in accordance with parameters that are set by a person.
Refusing to provide personal data
You may refuse to provide your personal and special category data. You have the right to ask 5Values to delete, amend or stop processing your data if we have already received or collected it. However, if you do not provide us with personal or special category data or if you request a restriction on the processing of your data, 5Values may not be able to provide you with the services that you have requested or that are stated in this policy.
Disclosure of your information inside and outside the EEA
We will share your personal information with any member of our group both within the UK, the EEA and outside of the EEA and selected third parties. Our Group includes our subsidiaries, ultimate holding company and its subsidiaries, our associated companies as defined within section 1159 of the UK Companies Act 2006. Third parties will include:
Clients for the purpose of introducing candidates to them;
Candidates for the purpose of arranging interviews and engagements;
Clients, business partners, suppliers and sub-contractors for the performance and compliance obligations of any contract we enter into with them or you;
Sub-contractors including email marketing specialists, event organisers, payment and other financial service providers;
Advertisers and advertising networks that require the data to select and serve relevant adverts to you and others. We do not disclose information about identifiable individuals to our advertisers but will provide them with aggregate information about our users. We may also use such aggregate information to help advertisers reach a target audience and we may make use of the personal data we have collected to enable us to comply with our advertisers’ wishes by displaying their advertisement to that target audience;
Analytics and search engine providers that assist us in the improvement and optimisation of our site;
Credit reference agencies, our insurance brokers, compliance partners and other sub-contractors for the purpose of assessing your suitability for a role where this is a condition of us entering into a contract with you.
We will disclose your personal information to third parties if 5Values or substantially all of its assets are acquired by a third party, in which case personal data held about its customers will be one of the transferred assets.
The lawful bases for the third party processing will include their own legitimate interests, satisfaction of their contractual obligations to us as our data processor, for the purpose of a contract in place or in contemplation and to fulfil their legal obligations.
Where personal data is stored and collected
The data that 5Values collects from you may be transferred to and stored at a destination outside of the EEA. It may be transferred to third parties outside of the EEA for the purpose of our recruitment services. It may also be processed by staff operating outside of the EEA who work for us or for one of our suppliers. This includes staff engaged in among other things our recruitment services and the provision of support services. By submitting your personal data, you agree to this processing. 5Values will all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy notice.
All information that you provide to us will be stored on secure services. Any payment transactions will be encrypted. Where we have given you or you have chosen a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential.
The transmission of data via the internet is not completely secure and although 5Values does its best to protect your personal data, we cannot guarantee the security of you data transmitted to our site and any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
5Values understands the duty to retain accurate data and only for as long as is needed to satisfy our legitimate interests or provided that you are happy for us to do so. Different laws require us to keep data for different periods of time and we shall ensure that we act in accordance with these laws.
The criteria that we use to determine whether we should retain your personal data include:
The nature of the personal data
Its perceived accuracy
Our legal obligations and basis for processing
Whether an interview or placement has been arranged
Your engagement and communication with us
Our understanding of the industry sector and job roles
We may store and handle your data in the following ways:
We may pseudonymise parts of your data, particularly following a request for restriction or erasure of your data to ensure that we do not re-enter your personal data on our database unless requested to do so
We may archive part or all of your personal data or retain it only on certain systems (e.g. financial systems) or delete all or part of it from our main Customer Relationship Management (CRM) system.
You have the right to ask us not to process your personal data for marketing purposes. We will usually inform you before collecting your data if we intend to use your data for marketing purposes or if we intend to disclose your information to any third party for the purpose of marketing. We will collect express consent from you, if legally required, before using your personal data for marketing purposes. You can exercise your right not to have your data used for marketing purposes at any time by contacting us at email@example.com. You can also unsubscribe from marketing communications by clicking the ‘unsubscribe’ button within those communications.
Our site and social media pages may from time to time contain links to and from the websites of our partner networks, affiliates and advertisers. If you follow a link to any of these websites, you should note that they will have their own privacy policies and may use your personal data in a way that you would not choose. 5Values do not accept any responsibility or liability for these policies and you should check these policies before you submit your personal data.
The UK GDPR provides you with the right to:
Request correction of the personal information that we hold about you and this enables you to correct any inaccurate or incomplete information.
Request erasure of your personal information. This allows you to request that 5Values deletes or removes personal information where there is no good reason for us to continue to process it or where you have objected to processing (see below). Please note that these requests may not always be able to be granted as there may be a lawful basis for continued processing e.g. because we are required to keep the data for a period of time under law.
Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation that makes you want to object to processing o this ground. You also have the right to object to processing for direct marketing purposes.
Request the restriction of processing of your personal information e.g. because you want us to establish the accuracy or the reason for processing.
Request the transfer of your personal information to another party in certain formats, if practicable.
Make a complaint to a supervisory body which in the United Kingdom is the Information Commissioner’s Office (ICO).
Access to Information
The UK GDPR gives you the right to access information that is held about you and we encourage you to contact us to ensure that your data is accurate and complete. A subject access request should be submitted to firstname.lastname@example.org. There is no fee applicable unless the request is manifestly unfounded or excessive e.g. because of their repetitive character.
Any changes we make to this policy will be posted on this page and, where appropriate, notified to you by email. Please check back frequently to see any updates or changes.
You also have the right to raise concerns with the ICO on +44 (0)303 123 1113 or any relevant supervisory authority should the processing take place outside the UK.