This Data Processing Notice applies to you if you are looking for a job (permanent or contractor role) and if you reside within the UK or the European Union. It is drafted in accordance with the General Data Protection Regulation (EU) 2016/679 (‘GDPR’) and any associated legislation e.g., the Data Protection, Privacy and Electronic Communications (Amendments etc) (EU Exit) Regulations 2019 and the 2018 UK Data Protection Act. In this Data Processing Notice, any references to GDPR also relate to associated legislation.

‍What is outlined in this data processing notice?

‍This Data Processing will outline:

1. What do we do with your personal data?
2. What type of personal data do we collect?
3. How do we collect your personal data?
4. Why do we process your personal data?
5. What legal basis do we use for processing your personal data?
6. Will your personal data go outside the EEA?
7. How long will we store your personal data for?
8. What are your rights?
9. Will my personal data be used to make automated decisions?
10. How can I lodge a complaint?
11. Will I be informed if changes are made to this Data Processing Notice?
12. Who can I speak to if I have any further queries? 

1. What do we do with your personal data?

‍Our legal entity is called Numi Consulting Ltd (‘Numi’), a company incorporated in England and Wales with registered number 12988247 whose registered office is at 21 Ham Island, Old Windsor, Berkshire, SL42JY, United Kingdom.

We are passionate recruiters who introduce candidates to our clients for both permanent and interim roles. We therefore act as data controller as we determine the purpose and means by which your personal data is processed.

We may share your personal data with our client(s) for the purpose of introducing you and arranging interviews with them. We will always ask you for permission before introducing you to our client and we will be transparent on the details that will be forwarded. We may also need your personal data in order to pay you or your business if you will be working as a contractor through Numi.

Furthermore, we may disclose your personal information to third parties in the event that we sell or buy any business or assets, in which case we will have to disclose your personal data to the prospective seller or buyer of such business or assets.

We may also be under a duty to disclose or share your personal data in order to comply with any legal obligation, to defend our business against a legal claim, to enforce or apply our standard terms of business or other agreements or to protect the rights, property or safety of Numi, our clients or other parties.We will always use an appropriate legal basis for processing your personal data.

All information you provide to us is stored on our secure servers. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; 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.

2. What type of personal data do we collect?
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When recruiting candidates, we typically collect the following personal data:

⦁ Your full name
⦁ Your registered address
⦁ Your date of birth
⦁ Your email addresses
⦁ Your (mobile) telephone number
⦁ Your website
⦁ Professional profiles available in the public domain, e.g. LinkedIn, Twitter or Facebook
⦁ Your CV
⦁ Skillset/portfolio (if not already covered in your CV)
⦁ Job preferences (if not already covered in your CV)
⦁ Current employer/client
⦁ Your ID & right to work
⦁ Current rate/salary/employment conditions
⦁ Desired rate/ salary/employment conditions
⦁ Other documentation, if requested by our clients (e.g. references)

3. How do we collect your personal data?
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We may collect your personal data in the following ways:

1. You apply for a job in response to a job ad posted by Numi
2. You complete a ‘Contact us’ form or register with us on our website
3. We reach out to you after having located your profile on a database/ job board you have subscribed to (e.g. Linkedin, Reed).
4. We have received your details from another third party. For example, a business contact, a client or professional advisors.
5. You have spoken with one of our recruitment consultants and you have provided us with your CV.We will always be willing to clarify how we located your details.

4. Why do we process your personal data?
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We are a recruitment business, and we collect your information to help you finding a job that matches your skillset.
More specifically, we process your personal data for the following purposes:
Introducing you to (potential) clients;
Keeping your personal data on file for current and future opportunities that may arise;
Keeping your personal data on file for transactional purposes (e.g., if we pay your business)
Evaluating your experience with numi and our recruitment process;
Verifying your identity and/ or the right to work.
Inviting you to events.

5. What legal basis do we use for processing your data?

‍Numi may have different legal bases for processing your personal data. This would typically be consent, legal obligation, performance of contract or legitimate interest. In the ordinary process of recruiting candidates and keeping their resume on file, we are of the view that we have legitimate interests to do so.As a recruitment business, we introduce candidates to clients for permanent employment and temporary worker placements. We need to satisfy our client’s resourcing needs and therefore require an up-to-date database of candidate data. We will only use your personal data to introduce you to our client and do not share more data with our client than necessary. We usually process data that is already available online (e.g., a CV downloaded from a job board) and ask for additional information that is relevant to your application. 

6. Will your personal data go outside the EEA?
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Your personal information will be stored and processed in the United Kingdom. If we engage with clients based outside the UK, then your personal data may be processed outside the UK/ EEA. However, we take all steps reasonably necessary to ensure that your data is treated securely and in accordance with relevant data privacy laws. Please note that if the hirer uses your personal data, they are also responsible for processing it safely and legitimately and they will have their own policies and processes in place.

7. How long will we store your data for?
‍
Your personal data will be stored in our system for six consecutive years. As long as you are working with our recruitment consultants on your next career step, we will keep your data on file, so we are able to match your profile with new opportunities. Your data will be removed from our systems if we have not heard from you during this six-year period.

Different retention periods may apply if:
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a) if you are hired by one of our clients, in which case we need to keep records of the relevant transaction in accordance with the relevant statutory retention periods.
b) there is a direct statutory requirement (that comes into force) under which we are obligated to keep your data stored in our internal databases for a longer period of time.

Also, under the Conduct of Employment Agencies and Employment Businesses Regulations 2003, we must retain evidence of an introduction or supply for at least one year from the last activity e.g., interview, introduction, or engagement.

8. What are your rights?
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You are entitled to various rights under the relevant data protection legislation:

• You can request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected. This means when working with our recruitment consultants, ensure that you notify us of any changes or update your information like email, phone number etc. when they change.
• You can request the erasure of your personal information. This enables you to ask us to delete or remove personal information 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 information where you have exercised your right to object to processing (see below).
• You can object to the 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 situation which makes you want to object to processing on this ground. Feel free to contact us if you want to be removed from our system.
• You can request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example, if you want us to establish its accuracy or the reason for processing it.• You can request the transfer of your personal information to another party in certain formats, if practicable.

The fact that you lodge a request does not necessarily mean that we will grant your request in every instance especially if we have a legal basis to retain your data. We will always give reasons if we decline your request.

We will, however, provide information without undue delay and in any event within one month (this can be extended to 2 months in exceptional circumstances) of the receipt of the request. However, where requests are manifestly unfounded or excessive in particular because of its repetitive character, we may refuse to act upon your request. If this happens then we will inform you within one month of the request about the possibility of lodging a complaint with a supervisory authority (in the UK this will be the ICO) or seeking a judicial remedy.

9. Will my personal data be used to make automated decisions?
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We will not conduct any forms of automated processing of your personal data consisting of the use of personal data to evaluate certain personal aspects relating to you. Furthermore we will not analyse or predict aspects concerning your performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements. Also, we will not make decisions that are based solely on automated processing which produces legal effects or similarly significantly affects your rights.

10. How can I lodge a complaint?
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If you feel that your rights have been violated, you are entitled to lodge a complaint with the supervisory authority of your country of residence. If you are based in the UK you can contact the Information Commissioner’s Office. Alternatively, you can seek a legal remedy. 
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However, before escalating the case to the supervisory authority, we always recommend you contact us by emailing hello@wearenumi.com. We will then deal with it and get back to you as soon as possible.

11. Will I be informed if changes to this Data Processing Notice are made?
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We will post any changes to this Data Processing Notice on this website and where appropriate (if we make any significant changes that may affect your rights as a data subject), you will be notified by email. 

12. Who can I speak to if I have any further queries?
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If you have any questions, comments or requests regarding your personal data or this Data Processing Notice, please email hello@wearenumi.com. 

Last updated on 7 April 2021.