“Manchester Staff Ltd welcomes the introduction of GDPR in May 2018 and is very conscious of information security. Manchester Staff Ltd takes the security of personal data very seriously regardless as to whether our organisation is considered a data processor or data controller.” – Ian Buckley, Director
Manchester Staff Ltd has been working towards being fully compliant with GDPR throughout 2017 & 2018 so that our customers can be confident that they are dealing with a compliant organisation and that the security of their data is taken seriously.
In conjunction with GDPR compliance, Manchester Staff Ltd have conducted comprehensive reviews of all activities across the business and how supporting data is processed. The company’s activities fall within three key areas:
- A data controller of its own employee data.
- A data controller or processor of third party data such as activity relating to direct marketing.
- A data processor or controller of candidate & client personal data
- Following a full review and assessment of GDPR, Manchester Staff is making changes to its activities and company policies/procedures where necessary in order to be fully compliant.
- Manchester Staff Ltd is reviewing all of its suppliers for compliance with GDPR.
- Manchester Staff Ltd is creating a detailed policy and ‘frequently asked questions’ document so that customers can clearly see Manchester Staff Ltd’s activity in respect of GDPR.
- The Manchester Staff Ltd website and any direct marketing that the organisation may send out is being updated so that customers have the confidence that any contact will be within GDPR guidelines. The website will contain Manchester Staff Ltd’s updated privacy policies.
What we need.
Manchester Staff Ltd only collect basic personal data which may include information about your current/previous job responsibilities and location based information for job purposes. This includes name, address, phone number, email address etc.
Why we need it.
We need to know your basic personal data in order to provide you with recruitment services in line with GDPR. We will not collect any personal data from you that we do not need in order to provide and oversee our recruitment services to you.
What we do with it.
All the personal data we have is processed by our staff in the UK, however for the purposes of IT hosting and maintenance, this information is located on our servers and no other parties have access to your personal data unless the law allows them to do so.
Please see the GDPR commitment statement from our CRM system ‘Bullhorn’ which is located online at:
Please also see below the GDPR statement from our timesheet system and payroll solution provider ‘Sonovate Limited’:
The General Data Protection Regulation, or GDPR, is due to come into force on 25th May 2018. This will replace the current Data Protection Act 1998 (DPA). Whilst many of the new legislation’s main concepts and principles are aligned with the current DPA there are new elements and significant enhancements to strengthen and unify data protection for all individuals within the European Union.
Over the last year, Sonovate has conducted a comprehensive cross-business review to identify any areas where changes are required to our current policies and procedures to achieve GDPR compliance. We have been engaging with legal data protection experts to ensure we interpret the new legislation correctly and apply it throughout the business. This approach has insured that Sonovate will establish and embed GDPR accountability principals to fully support our commitment to protecting all personal information held within our systems.
In conjunction with the GDPR compliance, we have conducted comprehensive reviews of all activities across our business and how supporting data is processed. As a result, we have full transparency of our data classifications, where data resides, including all aspects of our infrastructure architecture, backups & resilience, and how this is processed and secure.
Our platforms are all built on Microsoft Azure SaaS based cloud architecture, and we have again conducted comprehensive reviews of all additional third-party suppliers and their compliance with the new regulations.
At Sonovate, we have always taken data security and data privacy extremely seriously. Our aim has always been to provide our customers with the highest level of data security and be accountable for the information held on our applications. As such we regularly review and reinforce our security practices.
All customer data is stored within Microsoft UK & European data centres (for resilience purposes). Microsoft is committed to being GDPR compliant across all their cloud services when enforcement begins on May 25. Our commitment to using Microsoft cloud platforms stems from them being the first enterprise cloud services provider to implement rigorous controls governing the transfer of data outside of European Union, as the first cloud provider to achieve compliance with ISO’s important 27018 cloud privacy standards. Microsoft Azure has 53 major certifications and attestations – more than any other major public cloud provider.
When it comes to security, Microsoft’s visibility into the evolving threat landscape also helps us protect the data that moves through our systems. With a cloud footprint that includes over 100 datacentres and more than 200 cloud services, this ensures that we have robust solutions and procedures in place to support our business and secure our customer data.
Frequently asked questions
What personal data do you process?
Any data which relates to an identifiable person (Candidate). Name, address, mobile, email, National Insurance, passport, driving license, career history etc.
For what purpose do you process this personal data?
Data is collected for specific, legitimate and explicit purposes of providing recruitment services in order to help our clients find the right candidates for active and also non active positions within the hiring company’s organisation, and also to help candidates with their search for a new position either in the Contract or the Permanent job markets.
What are the risks to data subjects’ rights and freedoms if the personal data is destroyed, lost, altered, disclosed without authority, or accessed without authority.
Following a full review of our policies/procedures and also a full review of GDPR guidelines, we believe the risks are minimal as the information we obtain is contained solely in our CRM database or in some instances, the database of our timesheet/payroll solution providers CRM database (if permission is granted by the data subject). It is not shared with any outside third parties, except clients who a candidate’s skill set may be suitable for. In the event data is lost, altered or disclosed without authority etc. the candidate could report us to ICO which could mean fines of up 4% of our turnover. There could also potential compensation claims that can be made by the data subject. Non-financial risks include reputational damage as the ICO will name non-compliant organisations which would effect our reputation in the industry with our candidates & clients. The risks are high in relation to penalties, but this the same for all UK recruitment companies and we believe the risks are low. The worst case scenario is that the ICO could stop us processing personal data.
What provisions do you have in place to either delete or return the personal data once the service comes to an end?
When a data subject requests this, we will contact the data subject, discuss the deletion or return of records, and then remove accordingly. Otherwise it is our intention to keep the candidates details on our system, as this coincides with our “legitimate business interests” but is also in the interest of the data subject who may be seeking or open to a new job opportunity.
What provisions/training do you have in place to ensure that your employees process the personal data in accordance with Manchester Staff Ltd instructions?
We have provided ‘on the job’ training to our staff so that they understand GDPR and have also prepared a specific training session including a PowerPoint presentation which fully explains GDPR and the responsibilities of Manchester Staff Ltd and its staff members. All staff members have signed a document to confirm their understanding of the training provided in relation to GDPR.
What process do you have in place to avoid personal data breaches?
Adverts placed on job boards or similar recruitment websites will contain information outlining how we will process personal data in line with GDPR regulations.
Our GDPR policy is publicly available on our website.
Do you understand the GDPR requirements in detail and are you satisfied that you are aware of the impact these will have on your business?
Yes, we are happy that we have a good understanding of GDPR requirements and the impact they have on our business.
Do you anticipate full GDPR compliance by 25th May 2018 or before?
Has your work to date identified any changes that will be required to our relationship as a result of GDPR?
Manchester Staff Ltd is committed to ensuring that your privacy is protected. Should we ask you to provide certain information by which you can be identified when using this website, then you can be assured that it will only be used in accordance with this privacy statement.
Manchester Staff Ltd may change this policy from time to time by updating this page. You should check this page from time to time to ensure that you are happy with any changes.
What we collect
We may collect the following information:
Name and company name
Contact information including email address
Demographic information such as postcode, preferences and interests
Other information relevant to customer surveys and/or offers
What we do with the information we gather
We require this information to understand your needs and provide you with a better service, and in particular for the following reasons:
Internal record keeping.
We may use the information to improve our products and services. We may periodically send promotional emails about new products, special offers or other information which we think you may find interesting using the email address which you have provided.
We are committed to ensuring that your information is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect online.
Links to other websites
Our website may contain links to other websites of interest. However, once you have used these links to leave our site, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this privacy statement. You should exercise caution and look at the privacy statement applicable to the website in question.
Controlling your personal information
You may choose to restrict the collection or use of your personal information in the following ways:
We will not sell, distribute or lease your personal information to third parties. We may use your personal information to send you promotional information about third parties which we think you may find interesting if you tell us that you wish this to happen.
You may request details of personal information which we hold about you under the Data Protection Act 1998. A small fee of £10 will be payable. If you would like a copy of the information held on you please contact us via the form on our contact page.
If you believe that any information we are holding on you is incorrect or incomplete, please contact us. We will promptly correct any information found to be incorrect.
1.1 We are committed to safeguarding the privacy of our website visitors and service users.
1.2 This policy applies where we are acting as a data controller with respect to the personal data of our website visitors and service users; in other words, where we determine the purposes and means of the processing of that personal data.
1.4 Our website incorporates privacy controls which affect how we will process your personal data. By using the privacy controls, you can specify whether you would like to receive direct marketing communications and limit the publication of your information.
1.5 In this policy, “we”, “us” and “our” refer to Manchester Staff Ltd.[For more information about us, see Section 13.]
2.1 This document was created using a template from SEQ Legal (https://seqlegal.com).
How we use your personal data
3.1 In this Section 3 we have set out:
(a) the general categories of personal data that we may process;
(b) in the case of personal data that we did not obtain directly from you, the source and specific categories of that data;
(c) the purposes for which we may process personal data; and
(d) the legal bases of the processing.
3.2 We may process data about your use of our website and services (“usage data“). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is our analytics tracking system called Google Analytics. This usage data may be processed for the purposes of analysing the use of the website and services. The legal basis for this processing is consent OR our legitimate interests, namely monitoring and improving our website and services.
3.3 We may process your account data (“account data“). The account data may include your name, address, phone numbers and email address and your CV. The source of the account data is received in two ways, either direct web-form entry by yourself, or obtained via a third party such as a Job Board or CV database you have subscribed to. The Third party CV database service we may obtain your data from is www.cv-library.co.uk and www.reed.co.uk. The account data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is consent OR our legitimate interests, namely the proper administration of our website and business.
3.4 We may process your information included in your personal profile on our website (“profile data“). The profile data may include your name, address, telephone number, email address, profile pictures, gender, date of birth, relationship status, interests and hobbies, educational details and employment details. The profile data may be processed for the purposes of enabling and monitoring your use of our website and services. The legal basis for this processing is consent OR our legitimate interests, namely the proper administration of our website and business OR the performance of a contract between you and us and/or taking steps, at you request, to enter into such a contract for example, finding a job in the case of jobseekers, and finding new staff in the case of employers.
3.5 We may process your personal data that are provided in the course of the use of our services (“service data“). The service data may include your name, address, telephone number, email address, profile pictures, gender, date of birth, relationship status, interests and hobbies, educational details and employment details. The source of the service data is you. The service data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is consent OR our legitimate interests, namely the proper administration of our website and business OR the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
3.6 We may process information that you post for publication on our website or through our services (“publication data“). The publication data may be processed for the purposes of enabling such publication and administering our website and services. The legal basis for this processing is consent OR our legitimate interests, namely [the proper administration of our website and business OR the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
3.7 We may process information contained in any enquiry you submit to us regarding goods and/or services (“enquiry data“). The enquiry data may be processed for the purposes of offering, marketing and selling relevant goods and/or services to you. The legal basis for this processing is consent.
3.8 We may process information relating to transactions, including purchases of goods and services, that you enter into with us and/or through our website (“transaction data“). The transaction data may include your contact details, your card details and the transaction details. The transaction data may be processed for the purpose of supplying the purchased goods and services and keeping proper records of those transactions. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract and our legitimate interests, namely our interest in the proper administration of our website and business.
3.9 We may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters (“notification data“). The notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters. The legal basis for this processing is consent.
3.10 We may process information contained in or relating to any communication that you send to us (“correspondence data“). The correspondence data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and communications with users.
3.11 We may process any of your personal data identified in this policy where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.
3.12 We may process any of your personal data identified in this policy where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.
3.13 In addition to the specific purposes for which we may process your personal data set out in this Section 3, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
3.14 Please do not supply any other person’s personal data to us, unless we prompt you to do so.
Providing your personal data to others
4.1 We may disclose your personal data to any member of our group of companies this means our subsidiaries, our ultimate holding company and all its subsidiaries insofar as reasonably necessary for the purposes, and on the legal bases, set out in this policy.
4.2 We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
4.3 We may disclose your personal data to our suppliers or subcontractors insofar as reasonably necessary for assisting in your job search or employee recruitment search.
4.4 Financial transactions relating to our website and services are handled by our internal accounts team and payment services providers, Lloyds Bank. We will share transaction data with our payment services providers only to the extent necessary for the purposes of processing your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds.
4.6 In addition to the specific disclosures of personal data set out in this Section 4, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
International transfers of your personal data
5.1 In this Section 5, we provide information about the circumstances in which your personal data may be transferred to countries outside the European Economic Area (EEA).
5.2 The hosting facilities for our website are situated in the United Kingdom and the USA. The European Commission has made an “adequacy decision” with respect to the data protection laws of each of these countries. Transfers to each of these countries will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the European Commission.
5.3 You acknowledge that personal data that you submit for publication through our website or services may be available, via the internet, around the world. We cannot prevent the use (or misuse) of such personal data by others.
Retaining and deleting personal data
6.1 This Section 6 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.
6.2 Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
6.3 We will retain your personal data as follows:
(a) Personal Data will be retained for a minimum period of 1 year following the date of processing, and for a maximum period of 4 years.
6.4 Notwithstanding the other provisions of this Section 6, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
7.1 We may update this policy from time to time by publishing a new version on our website.
7.2 You should check this page occasionally to ensure you are happy with any changes to this policy.
7.3 We may notify you of changes to this policy by email or through the private messaging system on our website.
8.1 In this Section 8, we have summarised the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.
8.2 Your principal rights under data protection law are:
(a) the right to access;
(b) the right to rectification;
(c) the right to erasure;
(d) the right to restrict processing;
(e) the right to object to processing;
(f) the right to data portability;
(g) the right to complain to a supervisory authority; and
(h) the right to withdraw consent.
8.3 You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee.
8.4 You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.
8.5 In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims.
8.6 In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.
8.7 You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.
8.8 You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.
8.9 You have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
8.10 To the extent that the legal basis for our processing of your personal data is:
(a) consent; or
(b) that the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract,
and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.
8.11 If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.
8.12 To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
8.13 You may exercise any of your rights in relation to your personal data by written notice to us by email to email@example.com , in addition to the other methods specified in this Section 8.
9.1 A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
9.2 Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
9.3 Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.
Cookies that we use
Cookies used by our service providers
12.1 Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:
(a) https://support.google.com/chrome/answer/95647?hl=en (Chrome);
(b) https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences (Firefox);
(c) http://www.opera.com/help/tutorials/security/cookies/ (Opera);
(d) https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);
(e) https://support.apple.com/kb/PH21411 (Safari); and
(f) https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy (Edge).
12.2 Blocking all cookies will have a negative impact upon the usability of many websites.
12.3 If you block cookies, you will not be able to use all the features on our website.
13.1 This website is owned and operated by Manchester Staff Ltd
13.2 We are registered in England and Wales under registration number 10292477, and our registered office is at Deanway Technology Building 2, Wilmslow Road, Handforth, Wilmslow, SK9 3HW
13.3 Our principal place of business is at Manchester Staff Ltd, Deanway Technology Building 2, Wilmslow Road, Handforth, Wilmslow, SK9 3HW
13.4 You can contact us:
(a) by post, to Manchester Staff Ltd, Deanway Technology Building 2, Wilmslow Road, Handforth, Wilmslow, SK9 3HW
(b) using our website contact form;
(c) by telephone, on the contact number published on our website from time to time]]; or
(d) by email, using firstname.lastname@example.org
Data protection officer
14.1 Manchester Staff Limited is a registered Data Controller with the ICO, registration reference: ZA197797