RTriibe Limited is a recruitment and employment agency.
RTriibe Limited respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and when we collect personal data from you. It will also tell you about your privacy rights and how the law protects you. Please also use the Glossary to understand the meaning of some of the terms used in this privacy notice.
- Important information and who we are
Purpose of this privacy notice
This privacy notice aims to give you information on how RTriibe Limited collects and processes your personal data, including any data you may provide when registering or contracting with us for the provision of our services to you by completing a registration form or by corresponding with us by telephone, email or otherwise).
It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.
RTriibe Limited is the controller and responsible for your personal data (collectively referred to as “rTriibe”, “we”, “us” or “our” in this privacy notice).
We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below.
Full name of legal entity: RTriibe Limited
Name or title of data privacy manager: Peter Andrews
Email address: firstname.lastname@example.org
Postal address: RTriibe Limited, Kemp House, 160 City Road, London, EC1V 2NX, UNITED KINGDOM
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
Changes to the privacy notice and your duty to inform us of changes
This version was last updated on 1st May 2019
The data protection law in the UK will change on 25 May 2018. Although this privacy notice sets out most of your rights under the new laws, we may not yet be able to respond to some of your requests (for example, a request for the transfer of your personal data) until May 2018.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
Third-party links on our website
Our website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
- The data we collect about you
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
- Identity Data including national insurance number, nationality, immigration status (if applicable), title or marital status, first name, surname, date of birth and gender.
- Contact Data including home address, telephone number, mobile number, and email address.
- Employment Data including details of your qualifications, your C. V., your employment history (including remuneration history) and present employment circumstances, your job title, the name and contact information of your employer (inapplicable), and details of your referees.
- Technical Data including internet protocol (IP)address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you may use to access our website.
- Usage Data including information about how you may use our website and services.
- Marketing and Communications Data including your preferences in receiving marketing from us and our third parties and your communication preferences.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data buts not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
If you fail to provide personal data
Where we need to collect personal data by law or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with our services). In this case, we may have to cancel a service you have with us or refuse to accept your application to register with us.
- How is your personal data collected?
We use different methods to collect data from and about you including through:
- Direct interactions. You may give us your Identity, Contact, Financial, Employment and Profile Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
- apply to register for, or request, our services; or
- request marketing information to be sent to you or agree that we can send marketing information to you.
- Third parties or publicly available sources. We may receive personal data about you from various third parties as Setout below:
- Technical Data from the following parties:
o Analytics providers such as Google;
o Advertising networks; and
o Search information providers.
- Identify and Contact Data from publicly available sources such as Companies House and the Electoral Register based inside the EU.
- Your referees (where you have provided us with their details, and we have been asked by a Client to do so).
- Educational providers and relevant accredited or professional bodies.
- The Disclosure and Barring Service.
- The Home Office.
- Credit reference agencies.
- Job boards, online CV libraries, employment agencies, umbrella companies (and similar).
4. How we use your personal data
We will only use your personal data when the law allows us to. Most commonly, we will process your personal data in the following circumstances:
- Where we need to perform a contract have entered into with you (or are about to enter into with you) in relation to the provision of our Services.
- Where it is necessary for our legitimate interests (or those of a third-party) and your interests and fundamental rights do not override those interests. This may include marketing our services to you.
- Where we need to comply with a legal or regulatory obligation.
Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending you marketing information (if necessary).
Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground, we are relying on to process your personal data where more than one ground has been set out in the table below.
|Purpose/Activity||Type of data||Lawful basis for processing including basis of legitimate interest|
|To provide our recruitment Services to you as a candidate. This may include: keeping your personal data on file for a period of time. We will never store your personal data for longer than three years without your express consent;to assess data about you against vacancies which we judge may be suitable for you;to enable you to submit your CV apply online for jobs or to subscribe to alerts about jobs we think may be of interest to you;to respond to your questions and enquiries;to send your information to clients with your consent in order to apply to positions; andto carry out our obligations to you in relation to the Services.||(a)Identity (b)Contact (c)Employment (e)Technical (f)Usage (g)Marketing and Communications||Performance of a contract with you Necessary for our legitimate interest in providing the Services you have requested. Necessary for our legitimate interest in marketing our services to you|
|To administer and protect our business and our website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)||(a)Identity (b)Contact (c)Technical||Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) Necessary to comply with a legal obligation|
|To use data analytics to improve our website, products/services,marketing, customer relationships and experiences||(a)Technical (b)Usage||Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)|
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising:
Promotional offers from us
We may use your Identity, Contact, Technical, and Usage Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
You may receive marketing communications in relation to products and/or services similar to those which you have previously requested from us and you have not opted out of receiving such marketing.
We will get your express opt-in consent before we share your personal data with any company outside our group of companies for marketing purposes.
You can ask us or third parties to stop sending you marketing messages at any time by contacting our data processing manager.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us in connection with the provision of our services to you and any other lawful reason why we may process your personal data.
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you would like further details as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to-do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
5. Disclosures of your personal data
We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.
- External Third Parties as set out in the Glossary.
- Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
6. International transfers
Our external CRM provider is based outside the European Economic Area(EEA) and their processing of your personal data will involve a transfer outside the EEA.
Wherever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it as that afforded to it by us. We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission or if the service provider has entered into a specific contract with us approved by the European Commission.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
7. Data security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
8. Data retention
How long will you use my personal data for?
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
By law we have to keep basic information about our clients (including Contact, Identity, and Transaction Data) for [six] years after they cease being customers for [tax] purposes.
Income circumstances you can ask us to delete your data: see the section entitled Request Erasure below for further information.
in some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
9. Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please see below to find out more about these rights.
You have the right to:
Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no-good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
If you wish to exercise any of the rights set out above, please contact our data protection manager.
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting our data processing manager.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
External Third Parties
- Clients(in relation to applications for positions made with your consent).
- Our external CRM provider.
- Professional advisers, including lawyers, bankers, auditors and insurers based who provide legal, banking, insurance and accounting services.
- HM Revenue & Customs, regulators and other authorities who require reporting of processing activities in certain circumstances.
- Any third party to whom we are required by law to disclose data in connection with the detection of crime, the collection of taxes or duties, in order to comply with any applicable law or order of a court of competent jurisdiction, or in connection with legal proceedings.