Octopus Personnel Ltd are committed to protecting and respecting your privacy.
This Privacy Notice tells you what to expect in relation to personal information about you which is collected, handled and processed by Octopus Personnel the Data Controller.
We acknowledge and agree that any personal data of yours that we handle will be processed in accordance with all applicable data protection laws in force from time to time.
The General Data Protection Regulation (“GDPR”) is a new regulation which replaces the Data Protection Regulation. The Regulation aims to harmonise data protection legislation across EU member states, enhancing privacy rights for individuals and providing a strict framework within which commercial organisations can legally operate.
Your rights under GDPR are set out in this notice and apply from 25 May 2018.
Please read the following carefully to understand our views and practices regarding your personal data and how Octopus Personnel will treat it.
Who Octopus Personnel are and what we do
Octopus Personnel are a recruitment agency and recruitment business as defined in the Employment Agencies and Employment Businesses Regulations 2003 (our business). Octopus Personnel collect the personal data of the following types of people to allow us to undertake our business:
• Prospective and placed candidates for permanent or temporary roles
• Prospective and live clients
• Supplier contacts to support our services
• Our employees, consultants, temporary workers
Octopus Personnel collect information about you to carry out our core business and ancillary activities.
Information you give to us or we collect about you
This is information about you that you give us by visiting our website or by corresponding with us by phone, e-mail, SMS or otherwise. It includes information you provide when you:
• Register as a candidate to enter our database
• Register a new vacancy
• Subscribe to receive company news or our jobs-by-email service
• Apply for jobs
• Request a job to be emailed to you
The information you give us or Octopus Personnel collect about you may include your name, address, private and corporate e-mail address and phone number, financial information, compliance documentation and references verifying your qualifications and experience and your right to work in the United Kingdom, curriculum vitae (or career profile) and photograph and data that may be held on your professional profile available in the public domain e.g. LinkedIn, Twitter, business Facebook or corporate website.
Information Octopus Personnel collect about you when you visit our Website
When you visit our Website Octopus Personnel will automatically collect the following information:
Technical information, including the Internet Protocol (IP) address used to connect your computer to the Internet, browser type and version, operating system and platform.
Information about your visit, including the full Uniform Resource Locators (URL) of each page visited, clickstream to and through our Website including date and time, jobs visited and searched for, download errors, length of visits to pages, and any information submitted through forms.
Information Octopus Personnel obtain from other sources
This is information Octopus Personnel obtain about you from other sources such as LinkedIn, corporate websites, job board websites, online CV libraries, your business card and personal recommendations. In this case Octopus Personnel will inform you, by sending you this privacy notice, within a maximum of 30 days of collecting the data of the fact Octopus Personnel hold personal data about you.
Purposes of the processing and the legal basis for the processing
Octopus Personnel use information held about you in the following ways:
To carry out our obligations arising from any contracts Octopus Personnel intend to enter into or have entered into between you and Octopus Personnel to provide you with the information and services that you request from us or Octopus Personnel think will be of interest to you because it is relevant to your career or to your organisation.
To provide you with information about other services or jobs that Octopus Personnel offer that are similar to those that you have already been provided with or enquired about.
The core service Octopus Personnel offer to our candidates and clients is the introduction of candidates to our clients for the purpose of temporary or permanent recruitment. However, our service expands to supporting individuals throughout their career and to supporting businesses’ resourcing needs and strategies.
Our legal basis for the processing of personal data is our legitimate interests, described in more detail below, although Octopus Personnel will also rely on contract, legal obligation and consent for specific uses of data.
Octopus Personnel will rely on any existing contract if Octopus Personnel are negotiating or have entered into a placement agreement with you or your organisation or any other contract to provide services to you or receive services from you or your organisation.
Octopus Personnel will rely on legal obligation if Octopus Personnel are legally required to hold information on to you to fulfil our legal obligations.
Octopus Personnel will rely on your consent for particular uses of your data and you will be asked for your express consent, if legally required e.g. when gaining your permission to introduce you to a client (if you are a candidate).
Our Legitimate Interest
Our legitimate interest in collecting and retaining your personal data is described below:
As a recruitment business and recruitment agency Octopus Personnel introduce candidates to clients for permanent employment, temporary worker placements or independent professional contracts. The exchange of personal data of our candidates and our client contacts is a fundamental and essential part of this process.
In order to support our candidates’ career aspirations and our clients’ resourcing needs Octopus Personnel require a database of candidate and client personal data containing historical information as well as current resourcing requirements.
To maintain, expand and develop our business Octopus Personnel need to record the personal data of prospective candidates and client contacts.
Should Octopus Personnel want or need to rely on consent to lawfully process your data Octopus Personnel will request your consent orally, by email, by SMS or by completing an online process for the specific activity (e.g. when registering a vacancy or as a candidate or when you apply for a job) when Octopus Personnel will require your consent for and to record your response on our system. Where consent is the lawful basis for our processing you have the right to withdraw your consent to this particular processing at any time.
Other Uses Octopus Personnel will make of your data:
• Use of our Website
• To notify you about changes to our service
• To ensure that content from our Website is presented in the most effective manner for you and for your computer.
Octopus Personnel will use this information:
• To administer our Website and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes
• To improve our Website to ensure that content is presented in the most effective manner for you and for your computer
• To allow you to participate in any interactive features of our service, when you choose to do so;
• As part of our efforts to keep our Website safe and secure
• To measure or understand the effectiveness of the information, news and job advertising Octopus Personnel serve to you and others, and to deliver relevant information, news and job advertising to you
• To make suggestions and recommendations to you and other users of our Website about goods or services that may interest you or them.
Octopus Personnel do not undertake automated decision making or profiling. Octopus Personnel do use our computer systems to search and identify personal data in accordance with parameters set by a person. A person will always be involved in the decision-making process.
Disclosure of your information inside and outside of the EEA
Octopus Personnel will share your personal information with:
Selected third parties including:
• Clients (or a nominated party acting on behalf of our clients) for the purpose of introducing candidates to them
• Candidates for the purpose of discussing job opportunities to them, the arranging of interviews and engagements
• Clients, business partners, suppliers and sub-contractors for the performance and compliance obligations of any contract Octopus Personnel enter into with them or you
• Subcontractors including email payment and other financial service providers
• Octopus Personnel may make use of the personal data Octopus Personnel have collected from you to enable us to display our adverts to the correct targeted audience
• Analytics and search engine providers that assist us in the improvement and optimisation of our Website
Octopus Personnel will disclose your personal information to third parties:
The lawful basis for the third-party processing will include:
• Their own legitimate business interests in processing your personal data, in most cases to fulfil their internal resourcing needs
• Satisfaction of their contractual obligations to us as our data processor
• For the purpose of a contract in place or in contemplation
• To fulfil their legal obligations
Where Octopus Personnel store and process your personal data
All information you provide to us is stored on our secure servers in the UK. Email server is based in the EU.
Unfortunately, the transmission of information via the internet is not completely secure. Although Octopus Personnel will do our best to protect your personal data, Octopus Personnel cannot guarantee the security of your data transmitted to our Website; any transmission is at your own risk. Once Octopus Personnel have received your information, Octopus Personnel will use strict procedures and security features to try to prevent unauthorised access.
Retention of your data
Octopus Personnel will retain your personal data for as long as necessary in order to provide the recruitment service to you and for the purposes of satisfying any legal, accounting, regulatory or reporting requirements.
Octopus Personnel do the following to try to ensure our data is accurate:
• Prior to making an introduction Octopus Personnel check that Octopus Personnel have accurate information about you
• Octopus Personnel keep in touch with you so you can let us know of changes to your personal data
• Octopus Personnel make use of external websites (e.g. LinkedIn) to verify the information about you
The criteria Octopus Personnel use to determine whether Octopus Personnel should retain your personal data includes:
• The nature of the personal data
• Its perceived accuracy
• Our legal obligations
• Whether Octopus Personnel have been active with you as part of our general recruitment service (e.g. discussing roles with you, arranging interviews or placing you in a new role)
• Our recruitment expertise and knowledge of the industry by country, sector and job role
Octopus Personnel may archive part or all of your personal data or retain it on our financial systems only, deleting all or part of it from our systems. Octopus Personnel may pseudonymise parts of your data, particularly following a request for suppression or deletion of your data, to ensure that Octopus Personnel do not re-enter your personal data on to our database, unless requested to do so.
For your information, Pseudonymised Data is created by taking identifying fields within a database and replacing them with artificial identifiers, or pseudonyms.
You have the right to ask us not to process your personal data for marketing purposes. Octopus Personnel will usually inform you (before collecting your data) if Octopus Personnel intend to use your data for such purposes or if Octopus Personnel intend to disclose your information to any third party for such purposes and Octopus Personnel will collect express consent from you if legally required prior to using your personal data for marketing purposes.
Our Website may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that Octopus Personnel do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
The GDPR provides you with the following rights
• Request correction of the personal information that Octopus Personnel hold about you. This enables you to have any incomplete or inaccurate information Octopus Personnel hold about you corrected
• Request 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)
• Object to processing of your personal information where Octopus Personnel 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. You also have the right to object where Octopus Personnel are processing your personal information for direct marketing purposes
• 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
• Request the transfer of your personal information to another party in certain formats, if practicable
• Make a complaint to a supervisory body which in the United Kingdom is the Information Commissioner’s Office, however, we appreciate the chance to deal with your concerns before you approach the ICO, so please contact us in the first instance.
Access to information:
GDPR gives you the right to access information held about you. A subject access request should be submitted by email to firstname.lastname@example.org
Changes to our privacy notice
Any changes Octopus Personnel make to our privacy notice in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our privacy notice.
Questions, comments and requests regarding this Privacy Notice are welcomed and should be addressed to Sandra Smart who is our Data Protection officer and can be contacted by email email@example.com
Octopus Personnel Privacy Notice (when personal data is obtained from data subject) – PDF
Octopus Personnel Privacy Notice (when personal data is obtained from a 3rd party) – PDF