Privacy and Consent Information

Legal basis for processing and consent

The GDPR changes the current legal bases which are used to justify collecting and processing personal data, and require additional transparency in informing individuals about when (and why) their data is collected, processed and transferred. Traditionally, Forward Assist Recruitment has relied on an individual’s consent to justify the processing of their data. However, under the GDPR, there are stricter requirements for consent – it must be clearly distinguishable from other matters, in an intelligible and easily accessible form and must be capable of being withdrawn. Separate consent must be sought for separate processing activities (such as, for example, when a candidate has put his or her details forward for one vacancy and these are then used for an unrelated purpose).

Forward Assist Recruitment will only submit your details once the name of the client has been divulged, you have been briefed on their activities and the role available – and your acceptance to relay your details on agreed. We will retain your data securely for a maximum period of 5 years.

At any time, you are able request the removal of any data held on your behalf, and this can be done via email to datacontroller@ forwardassistrecruitment.com. Confirmation will be sent to you to confirm any requests and will be actioned within 5 working days. The complete Forward Assist Recruitment Ltd privacy document can be found on the website forwardassistrecruitment.co.uk. There will be no negative or detrimental impact on you – the data subject – if a request for the removal of your data is requested at any time – and in doing so, you will no longer receive communication from Forward Assist Recruitment. You will of course be invited to re-apply for other positions via the job boards that we utilise and your application treated as any other would be – with previous removal having no impact whatsoever on any business conducted in the future.

A legal basis is our justification for why we are processing personal data in a particular way. The GDPR sets out legal bases in Article 6 of the regulation. During our data mapping process, we have identified that the legal basis that justifies how and why we collect, process and store your personal data in our organisation is under “legitimate interests pursued by the Controller”.

Regarding consent, we ask you to "positively opt-in" via our e-consent form, and ensure that you understand the terms detailed in our terms of business and privacy policy. As you will have read, we use your data wholly for legitimate business interests – in securing candidates new employment opportunities and clients suitable candidates. No data will ever be sold nor made available to any external party save for the normal activities of a recruitment business – ie cv submission to a client with authorisation from the data subject.

 
Data sharing
Under the GDPR, the relationship between parties who share data between themselves will become much more heavily regulated. Policy on using data from job boards will, in particular, need to be reviewed carefully and as a candidate, you are entitled and indeed encouraged to ensure that the data held by a job board on your behalf is both accurate and relevant ie up to date – but also what their terms are for the onward transmission of this data to agencies and clients who subscribe to their services. Consequently, you should review, and possibly amend, your relationships with all those with whom you share data to ensure that they meet these new requirements.
 
Data processing
Forward Assist Recruitment act as a data processor (We collect and process an individual’s personal data on behalf of other companies). Under previous data protection legislation (prior to 25th May 2018), there were few direct obligations. However, under the GDPR, Forward Assist Recruitment has direct responsibility for our own compliance with the GDPR and all of our staff have been trained and undertaken examinations to ensure compliance both individually and as an organisation.
 
Rights of individuals
The GDPR builds on existing rights of individuals (such as the right to object to the processing of data for profiling) and contains numerous new rights. Individuals will have wider rights of access and information and any inaccuracies must be rectified without undue delay. There is a new right to have your personal data erased where the data is no longer required, where consent is withdrawn or if the processing is unlawful. This accompanies a similar right to restrict processing where the accuracy of the data is contested or the processing is unlawful. There is also a new right of data portability that allows individuals to move their data to another controller (or recruiter) in a structured, commonly used and machine-readable format.
 
Security
Under the GDPR, Forward Assist Recruitment have a duty to implement measures to ensure a level of security which is appropriate to the level of risk. Appropriate measures may include:
  • pseudonymisation and encryption of personal data;
  • the ability to ensure on-going confidentiality, integrity, availability and resilience of data processing systems;
  • the ability to restore data in a timely manner in the event of an incident; and
  • a process for regularly testing, assessing and evaluating the effectiveness of security measures.
  • Data protection and security has always been important to us and we adhere to all current data protection laws. We use industry best practice security including site-wide encryption (HTTPS), browser verification and two factor authentication to protect against the unauthorised access of any data we hold.
 
General Information
The EU General Data Protection Regulation (GDPR) replaces the 1995 EU Data Protection Directive (European Directive 95/46/EC), with effect from 25th May 2018. The new regulation will strengthen and unify data protection for all individuals within the European Union and be enforced by the Information Commissioner's Office (ICO).


Forward Assist Recruitment strives to provide our clients and candidates with a simple and effective recruitment service – identifying relevant candidates for the needs of employers via various subscription job board platforms where we both post jobs and search for CVs. This has earnt us the trust of thousands of candidates and direct employers from across the UK over many years. We will continue to make the necessary changes to our service offering to ensure we are compliant with the new legislation, and we will keep our clients informed.

 
Working with Forward Assist Recruitment Ltd
The new regulations will not affect your ability - to register jobs with us as a client - nor your CV data as a candidate seeking a new position - in line with our terms and conditions, which are kept up to date in line with all data regulations. As subscribers to the job boards, we are responsible for protecting the data that we control and process under the new GDPR principles but we recommend that you familiarise yourself with the core principles to ensure you are aware of any legislation that may be of concern to you.
 
This document is provided as of 22nd Febuary 2018 and updated regularly in accordance with ICO guidelines. It is for information purposes only and not to be relied upon for legal purposes as the terms of GDPR legislation are still being finalised, and it is subject to change or removal without notice.