Privacy Policy

Howells Solutions Limited (“Howells Solutions”) is a company registered in England & Wales, company number 09367063, with a registered office at Newstead House, Pelham Road, Nottingham, United Kingdom, NG5 1AP. wearehowells.co.uk is the internet domain for Howells Solutions Limited.

We are an Employment Agency providing Permanent Recruitment Services and an Employment Business providing temporary assignments. We are committed to protecting our client and candidate data and privacy and all information supplied to Howells Solutions Limited will be processed in accordance with relevant data protection legislation, as currently in force.

Howells Solutions is a registered data controller with the Information Commissioner’s Office under registration number: ZA264063.

Howells Solutions’ Privacy Officer can be contacted by email on dataprotection@wearehowells.co.uk

Should you have any concerns, please give us the opportunity to deal with them in the first instance. However, you have the right to make a complaint at any time to the Information Commissioner’s Office (ICO).

Types of Personal Data We Collect

As part of our recruitment services, we collect data on candidates and clients in order to match candidate and client in appropriate permanent, temporary or contract job roles.

Howells Solutions will only ever request, use, store, transfer and process personal information that will assist us with providing recruitment services.

For candidates, this means matching your CV to relevant permanent, temporary and contract opportunities.

For clients, this means sourcing candidates that have the appropriate qualifications, skills and experience for the employment opportunities you have within your business.

The types of data we might request include, but are not limited to:

Candidates

personal contact information such as name, postal address, telephone number and email address career history salary and package information right to work documentation educational and professional qualifications bank details National Insurance number professional and personal references, as required in accordance with the job role type (temporary, permanent or contract). log in data for our candidate portal Special Category: Some clients may require us to carry out criminal background checks so we may need to collect additional personal data we need to collect in order to facilitate these checks

Clients

contact information for staff members such as names, email addresses, job titles, telephone numbers and office addresses information about your business provided to us directly as well as information available within the public domain regarding your business, although this is not personal data.

We may also collect, use, store and transfer personal data about visitors to our website. This includes, but is not limited to, your IP address, log in data (where applicable), browser type, location, time zone settings and operating system/platform and other technology on the service you use to access our website and information relating to how you use our website (such as the time spent on the website, number of visits and pages visited).

We will also collect certain details from our suppliers such as names, email addresses and telephone numbers of your employees. We collect this data for the purpose of being able to use and pay for your service as appropriate.

We may also collect information about individuals from a candidate or an employee for referencing or emergency contact purposes. This information will include name, address, email address, telephone number and job title as appropriate.

Method of Personal Data Collection

Please see below the ways in which we collect personal data for the purposes of providing recruitment services.

Candidates

Submission of a CV Applying for a position on our website From a phone call or email with one of our consultants From a Third-Party website such as a job board (TotalJobs, CV Library From a third-party source such as job boards and social media sites (including but not limited to: TotalJobs, CV Library and LinkedIn), including an application made by yourself via one of these third-parties.

Clients

From direct communication with employees of your company via phone, email or face-to-face meeting From the company website

Suppliers

From when we enter into an agreement for services with you

Referees / Emergency Contact Information

From candidates themselves

Website Users

From your cookies when you visit our website in accordance with the cookie settings within your browser.

Use of Personal Data

Please see below the ways in which we use your personal data:

Candidates

Any personal data will be used for the sole purpose of providing a professional and effective recruitment service. This includes, but Is not limited to: Matching your CV against job opportunities we have with our clients in order to assess your suitability for the role; Applying for jobs on your behalf; Allowing you to submit a CV or apply for a job vacancy on our website; Allowing us to carry out obligations between yourself and a third-party (such as an umbrella company, which would be your employer, should you work through such a company)*; Administering a placement; including, but not limited to, completing and processing timesheets, facilitating our payroll or invoicing processes and completing employment contracts and compliance process in accordance with the relevant employment and tax legislation; Marketing our recruitment services; and Obtaining references

*In this instance, the third-party should establish they have the appropriate legal basis for processing your data and the ongoing processing of your data will be subject to our agreement with that company.

Clients

Any personal data will be used for the sole purpose of providing a professional and effective recruitment service. This includes, but is not limited to: Assisting us with the delivery of the agreed recruitment service Sourcing candidates for job vacancies Setting up interviews (via telephone, video conference or in person) Facilitating the placement of candidates in temporary, contract or permanent positions

Supplier

We will use personal data we have collected to ensure we can contact you in relation to the performance of our contract for an agreed service and to ensure we can pay you for such services.

Referees / Emergency Contact Information

We will only use your personal data to contact you when required i.e. when we require a reference for a candidate or employee or when we need to contact you in the event of an accident or an emergency.

Website Users

We will use the information collected to monitor and improve the performance of our website.

Marketing: we may also use personal data collected from candidates and client to send targeted marketing communications relating to industry news and job vacancies that might be of interest. You can unsubscribe to these mailings via the Candidate Portal or by contacting us directly.

Sharing of Data

In certain circumstances, we might share your data for the purposes of providing recruitment services. The table below details with whom your data might be shared:

Candidates

To find you employment opportunities, we will share personal data with other parties. The data shared will be only the relevant details to allow the third-party to carry out the purpose for which the data is shared.

This might include sharing your CV with our client for a specific job opportunity or on a speculative basis. It might also include sharing your data with a third-party service provider who perform functions on our behalf such as our accountant, criminal background check service provider, umbrella companies and HMRC.

Clients

To find suitable candidates for your job vacancies and arrange interviews and placements, we will share the personal data of your company.

Referees / Emergency Contact Information

We might provide completed references to our clients as part of our recruitment services.

We might provide employee or candidate emergency contact details to our clients with whom our temporary workers or contractors are placed if required in the event of an emergency. We might also provide these details to the relevant emergency services if required in the event of an emergency.

Supplier

We might need to provide your details with other service providers to whom we provide services or receive services from.

Website users

We might share your personal data with service providers who assist us with the analysis of the data to monitor and improve the use of our website.

If we ever sell or buy business or assets, we may disclose your personal data to the prospective seller or buyer. If we are acquired (in whole or in part) by a third party, the data we hold on you may be one of the assets transferred.

Storage your Personal Data

Your data will be stored and backed up securely within the UK on our IT systems as provided by our service providers.

In the rare circumstances, the data we have collected may be transferred outside the European Economic area. If this is to occur, we will obtain your explicit consent beforehand.

The security of your data is very important to us and we have processes and procedures in place to prevent the misuse of or unauthorised access to your data.

The personal data of our candidates, clients and suppliers are held in a variety of places, including:

Our CRM system; Our employee’s computers; Microsoft Applications; Emails; and Paper files.

In order to protect your data our computers and systems are protected by passwords and virus checking. We also train our staff as to the importance of data privacy and the internal processes in place.

We will keep your data no longer than necessary and will remove your personal data when no longer required.

We will usually keep data for the following periods:

Candidates who are not placed with one of our clients and have applied for a role via a job board advert

3 years from the date of the job application

Candidates who are not placed with one of our clients and matched to a role following a search via a job board

3 years from the date of the last contact

Candidates who are placed in a permanent position with one of our clients

6 years from the commencement of the employment

Candidates who are placed in a temporary position with one of our clients

6 years from the end of the placement

Candidates who are placed in a contractor position with one of our clients

6 years from the end of the placement

Your Rights

Under the GDPR, you have various rights related to the processing of your data by us.

Your Right to be Informed

You have the right to be informed about the collection and use of your personal data. This policy provides this information. However, if you would like to more information about the collection and use of your personal data, please contact us and we will respond to your request promptly, and in any event, within 28 days of receipt.

Your Right to Access

You have the right to access the personal data we hold on you. If you would like to access your data, please contact us and we will respond to your request promptly, and in any event, within 28 days of receipt. Any such request will usually be free of charge, but we reserve the right to charge a reasonable fee for administration costs where the request is manifestly unfounded or excessive or for multiple copies following an initial data.

Your Right to Rectification

If you believe your data is inaccurate or incomplete, you can contact us and we will respond to your request promptly, and in any event, within 28 days of receipt. If you are a candidate you can also change your contact details via our Candidate Portal.

Your Right to Restriction Processing

You have the right to request that the processing of your personal data is restricted in certain circumstances. This means that you can limit the way that we use your data.

These circumstances are:

you contest the accuracy of your personal data and we are verifying the accuracy of the data; the data has been unlawfully processed but you do not want us to delete your personal data; we no longer need the personal data but you need us to keep it in order to establish, exercise or defend a legal claim; or you have objected to us processing your data and we are processing this request and considering whether we have legitimate interest in continuing this processing. If you would like to exercise your right to restrict processing of your personal data, you can contact us and we will respond to your request promptly, and in any event, within 28 days of receipt

Your Right to Data Portability

You have the right to transfer the data we hold to another data controller. If you would like to request this, contact us to discuss what is required and we will respond to your request promptly, and in any event, within 28 days of receipt.

Your Right to Withdraw Consent

If you have previously given us consent to process your data for a specific purpose and you wish to withdraw that consent, we will cease to process your data for that specific purpose unless there is, in our opinion, a legitimate reason for us to continue process your data for that specific purpose such a legal obligation or a legitimate interest. You should be aware that if you withdraw consent we may not be able to offer our recruitment services to you. If you wish to exercise this right, you can contact us and we will respond to your request promptly, and in any event, within 28 days of receipt.

Your Right to Object

You have the right to object to the processing of your personal data in the following circumstances:

where it is being used for direct marketing purposes; where it is being used for performance of a task carried out in the public interest; where it is being used in the exercise of official authority; or where we used your personal data based on our legitimate interests.

If you object to the processing of your data for direct marketing purposes, we will stop processing your data immediately.

For the other circumstances, you should show that the processing impacts on your fundamental rights and freedoms.

If you have consented to us processing your data, you cannot object to us processing it, but you do have the right to withdraw your consent (see above).

Please contact us if you wish to exercise your right to object and we will respond to your request promptly, and in any event, within 28 days of receipt, unless it relates to direct marketing purposes (see above).

Your Right to Erasure

You have the right to request that your personal data is deleted from our systems. If you would like to request that your personal data is deleted, please contact us and we will respond to your request promptly, and in any event, within 28 days of receipt. We will delete your data if so requested provided continued retention is not required and permitted by law (for example, relevant tax and employment legislation). If we have shared your personal data, we will take reasonable steps to inform other data controllers about your erasure request.

Our Legal Basis for Processing your Data

The legal basis on which we process your personal data depends upon purpose for which your data is being processed. We may process your data on more than one lawful ground depending on the specific purpose for which we are processing your data.

The basis on which we process your data are as follows:

Basis

Explanation

Legitimate Interest

We believe that it is necessary for us to collect and process certain personal data in order to provide recruitment services to clients and candidates.

Consent

Where at all possible, we will give you the opportunity to consent to the processing of your data.

Legal Obligation

In certain circumstances, we will have a legal obligation to process your data. For example under the relevant employment and tax laws.

Contract

Where there is a contract between us, we will process your data in so far as it is necessary for the performance of this contract.

Please see the table below which briefly sets out the basis on which we process your personal data:

Purpose

Type(s) of data

Basis of processing

Candidate

Registering a candidate via third-party job board application

Contact information including name, address, email address, telephone number.

Career Information including CV, employment history, education & qualification, salary & package information, notice period and referee details as well as completed references.

Legitimate interest – necessary to provide recruitment services to you and assess your suitability for the relevant job opportunity.

Consent – requested on direct contact and managed via our Candidate Portal.

Registering a candidate via third-party job board search

Contact information

Career Information

Legitimate interest – necessary to provide recruitment services to you and assess your suitability for the relevant job opportunity.

Consent – requested on direct contact and managed via our Candidate Portal.

Registering a candidate via direct contact with the candidate

Contact information

Career Information

Legitimate interest – necessary to provide recruitment services to you and assess your suitability for the relevant job opportunity.

Consent - requested on direct contact and managed via our Candidate Portal.

Administering our business (including data analysis, testing, system maintenance, IT support, reporting and storage of data)

Contact Information

Technical details such as IP address and browser information obtained from you accessing our website or Candidate Portal

Legitimate interest – necessary for us to administer our business, IT services, IT security and prevent fraud.

Managing our relationship with a candidate including notification regarding changes to this privacy policy and direct marketing

Contact Information

Marketing & Communication preferences as you may have provided to us or our third parties

Legal obligation – we must provide a clear and transparent privacy policy under the relevant data protection law

Legitimate interest – necessary for us to keep our records up to date and ensure candidates are only getting relevant marketing materials.

Providing Recruitment Services including matching you with relevant job opportunities, arranging the necessary interviews and confirming placements.

Contact information

Career Information

Right to work documentation – such as a passport, driving licence, proof of address.

Legitimate interest – necessary to provide recruitment services to you.

Consent – requested on direct contact and managed via our Candidate Portal.

Contract – our clients often require us to obtain right to work documentation from candidates as part of their contract with us.

Facilitating payroll and invoicing processes for a placement

Contact Information

Financial information including bank details and NI number and/or UTR Number.

Payment details including timesheets, pay rates, pay slips, P45s, P60s, expense records.

Contract – necessary to pay you under your employment contract (whether with us or a third-party umbrella company)

Legitimate interest – necessary for us to be able to recover our fees for a placement

Retaining employee and placement records

Contact Information

Career Information

Financial information

Payment details

Legal Obligation – required to keep employment records under relevant employment and tax legislation.

Contract - required to provide references to future employers, if so requested, confirming dates of any placement. This is part of our obligation to you as our employee.

Client

Managing our relationship with a client including notification regarding changes to this privacy policy and direct marketing

Contact information

Marketing & Communications information

Contract – required to perform the contract between us and your company.

Legal Obligation - we must provide a clear and transparent privacy policy under the relevant data protection law

Legitimate Interest – necessary for us to keep our records up to date and ensure candidates are only getting relevant marketing materials.

Administering our business (including data analysis, testing, system maintenance, IT support, reporting and storage of data)

Contact information

Technical data

Legitimate interest – necessary for us to administer our business, IT services, IT security and prevent fraud.

Providing Recruitment Services including matching candidates with your relevant job opportunities, arranging the necessary interviews and confirming placements.

Contact information

Company profile information including any information provided to us regarding job opportunities such as structure charts, job descriptions, job opportunity information (i.e. salary, package etc.), site addresses, third-party client information

Marketing & Communications information

Contract – required to perform the contract between us and your company.

Suppliers

Performing and managing our contract with you including using your services

Contact details

Contract – required to perform the contract between us and your company.

Carrying out invoicing activities

Contact details

Financial Information

Payment details (including, in particularly, cost of services, rates, discounts etc.)

Contract – required to perform the contract between us and your company.

Referees

Obtaining a reference for a candidate

Contact details

Legitimate interest – necessary for us to provide our recruitment services in that we need to confirm a candidate’s career history is correct to assess their suitability for job opportunity.

Emergency Contact Information

Holding emergency contact information for candidates

Contact details

Legitimate interest – necessary in the event of an emergency or accident whilst a candidate is interviewing with a client via our company, meeting with us or working in a temporary or contract placement with one of our clients.

Website Users

Administering our business (including data analysis, testing, system maintenance, IT support, reporting and storage of data)

Technical data

Legitimate interest – necessary for us to administer our business, IT services, IT security and prevent fraud.

Cookies

Cookies 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.

We may also use cookies to analyse the traffic to our website and therefore improve its functionality.

There is basically only Google analytics running on our website. These are: _ga, _gid, _gat

To see the cookies you accept or change them, you will need to do this within your browser. If you do not want to receive cookies, you will need to opt-out by changing your own browser setting. If you reject all cookies, this may affect the functionality of our website.

Changes to our Privacy Policy

Our Privacy Policy may be updated or altered from time to time. Any changes to this Privacy Policy will be posted on our website.