Privacy Policy

Rowlands Group Limited

Privacy Statement

Rowlands Group Limited Privacy Statement Rowlands Group Limited (“Rowlands”, “us”, “we”) take the privacy of our candidates, clients, suppliers, website users, candidate referees and those individuals who have been listed as emergency contacts seriously.

Rowlands is a recruitment business which provides recruitment services to its clients and work-seekers. Rowlands must process personal data (including, at times, a limited amount of sensitive personal data) so that we can provide these services – in doing so, Rowlands acts as a data controller. Where your personal data is shared with other parties, the privacy policies of those parties will also apply to your personal data and the way in which it is processed. Please refer to the individual privacy policies of those parties for further information.

This Privacy Policy explains what kind of personal data we collect about you, how we collect it and use it and how we protect it. It also explains the rights that you have as a data subject. This Privacy Policy covers the personal data of our candidates, clients, suppliers, website users, and people whose data we receive from candidates such as referees and emergency contacts. Rowlands is committed to maintaining a high level of security and confidentiality relating to all personal data that we deal with.

Please note that we may amend this Privacy Policy from time to time. Please continue to visit this web page if you would like to stay up to date, as we will post any changes or updates here. If you have any further questions about our Privacy Policy, please do not hesitate to contact us using the details listed below.

Data processing

Your personal data is protected by The Data Protection (Jersey) Law 2018 (“DPJL”) and the General Data Protection Regulation (Regulation (EU) 2016/679).

Data controller

The Data Controller (as defined in the DPJL) is Rowlands Group Limited, a company registered in the Island of Jersey with the following address: Trinity House, Bath Street, St Helier, Jersey, JE2 4S, which includes:

  • Rowlands Recruitment Limited;
  • Rowlands Graduate;
  • Rowlands Training Services;
  • Rowlands Executive;
  • Rowlands Temporary Resourcing; and
  • cValuate Limited (please click here to view the cValuate privacy policy).

Name: Rowlands Group Limited FAO Jeralie Pallot

Telephone: +44 (0) 1534 626777

E-mail: mydata@rowlands.co.uk

What kind of personal information do we collect

Candidate data

To enable us to provide you with the highest level of service and place you in the job role that you want, we need to collect and process certain information about you, including (but not limited to) your name, address, contact details, age/date of birth, residential qualifications, employment history, other information provided within your CV and your social security number. We may also collect information that relates to any health issues or disabilities to the extent that this information may be relevant to the type of employment you are seeking, in addition to details about any criminal convictions.

Client data

To help you to find and recruit the right candidates for your organisation, we collect information such as contact details of individual contacts at your organisation (including their names, telephone numbers and e-mail addresses). This enables us to engage with you when we have suitable candidates and provide you with a high level of service.

Supplier data

In order for us to engage you to provide us with certain services, we collect information such as contact details of individual contacts at your organisation (including their names, telephone numbers and e-mail addresses) in addition to bank details so that we can pay you for the services that you provide, in accordance with our contractual obligations.

People whose data we receive from candidates such as referees and emergency contacts

In order to provide a high quality recruitment service and also to be fully prepared for any eventuality and prioritise the safety of our candidates and employees, we ask for very basic contact details such as a name and contact number or e-mail address, so that we can get in touch with you if you have been listed as a referee or an emergency contact by one of our candidates or employees.

People who use our website

When you browse our website, we will collect information about how and when you use the website and information that is collected automatically via cookies. We collect this data to improve our website and ultimately enhance your user experience. We may also collect data such as your name and e-mail address if you provide this information through our website.

How do we collect your personal data

Candidates

Where appropriate and in accordance with any local laws and requirements, the main ways that we collect personal data of candidates are:

  1. from information provided directly by you (for example, within your application form and your CV and information that you provide through our website or in other communications you have with us);
  2. from information received from third parties (for example, through referees, interviewers, clients, websites such as LinkedIn, Facebook or Twitter, jobs boards or through third party testing and screening providers); and
  3. from information that we collect automatically when you visit our website or use our chat function (for example your IP address, information relating to your movement throughout our website and information collected automatically via cookies).

Clients

Where appropriate and in accordance with any local laws and requirements, the main ways that we collect personal data of our clients are:

  1. from information provided directly by you (for example, when we are communicating in relation to placing individuals within your organisation); and
  2. from information that we collect automatically when you visit our website or use our chat function (for example your IP address, information relating to your movement throughout the website and information collected automatically via cookies).

Suppliers

Where appropriate and in accordance with any local laws and requirements, the main ways that we collect personal data of our suppliers are:

  1. from information provided directly by you (for example, when you provide us with your contact and payment details); and
  2. from information that we collect automatically when you visit our website or use our chat function (for example your IP address, information relating to your movement throughout the website and information collected automatically via cookies).

People who are listed as referees and emergency contacts

We are provided with your details by candidates or employees who have listed you as either a referee or their emergency contact.

People who use our website

When you visit our website we collect some information automatically through cookies which provide us with information to help us to improve your experience. There is further information in the cookies section below. We also collect information from you through your use of the chat function or any information that you provide through our website such as your name, contact details and CV. We also collect data through our e-mail service provider in relation to whether or not you open the e-mails that we send.

Legal basis and purpose for processing data

Some categories of the personal data that we collect from you are required to enable us to fulfil our contractual duties to you or to others. Some other categories of personal data are required by statute, for example, our requirement to collect candidates’ social security numbers. Our clients may also require this personal data, and/or we may need your data to enter into a contract with you. If you decide not to provide us with your personal data, we may be unable to fulfill our contractual obligations and may be unable to provide you with our recruitment services or engage you to provide us with services.

Other categories of personal data may be required so that we can provide you with an efficient service based on our legitimate interests as a recruitment services provider (further detail is provided below). Where our legal basis for processing your data is based on our legitimate interests, you have the right to object to us processing your data on this basis if you wish. Please see below for more information about your right to object to the processing of your data.

Candidates

The main purpose for which we use your personal data is to help you to find suitable employment options by providing an effective recruitment service which is tailored to your specific requirements. This could include for example, contacting you about job opportunities, assessing your suitability for those opportunities, updating our databases, putting you forward for job opportunities, arranging payments to you and developing and managing our services and relationship with you and our clients. We do not sell personal information collected through this site or use your personal information for any other purposes than those stated above.

In accordance with the DPJL, the main legal basis upon which we use and process your personal data is because such processing is necessary for the purposes of legitimate interests pursued by Rowlands (as the data controller) or by a third party or parties to whom the data are disclosed. Our legitimate interests are to provide recruitment services to both our candidates and clients to help match individuals to the right jobs within the right organisations. In order to rely upon this basis for processing, the processing must not be unwarranted in any particular case by reason of prejudice to the rights and freedoms or legitimate interests of you (as the data subject).

We think it’s reasonable to expect that if you are seeking employment or have provided your CV information and other personal information on a jobs board, professional networking site or directly to us, you are happy for us to collect and otherwise use this personal data to offer or provide our recruitment services to you, share that information with prospective employers and assess your skills against the job positions that we are recruiting for. We also think that it’s reasonable to expect that as the recruitment process progresses, prospective employers may want to verify the information that you have provided to us such as employment history, education and qualifications or may want you to complete various testing processes (to the extent that this is necessary, appropriate and in accordance with local laws) to ensure that they can pursue their legitimate interest to recruit the most appropriate candidate for the role. We need to assist our clients with this so that we can operate successfully as a profit-making recruitment business and continue to successfully place our candidates in roles.

We use your data in a way which we believe you would reasonably expect us to use it, given our legitimate interest as a recruitment services provider. We do not believe that the manner in which we process your personal data prejudices your rights and freedoms or legitimate interests. In fact, the way in which we process your personal data enables us to provide a better service to both our clients and candidates so this is beneficial to all parties.

Some categories of personal data, such as any health data or data relating to any criminal convictions, are processed on the basis that you have provided your explicit consent for us to do so. You can withdraw this consent at any point by contacting us on the contact details provided above. We may also use your personal data to send you vacancy alerts or for marketing purposes such as sending you our newsletter. We will require your explicit consent in order for us to send this to you. Even where you have previously provided your consent for us to circulate our newsletter or to receive vacancy alerts, you can withdraw this consent at any time and you can do this by clicking the unsubscribe button at the bottom of the e-mail.

Clients

The main purpose for which we use information about our clients is to enable us to provide our recruitment services to you, mainly through sourcing appropriate candidates to place within your organisation. We think it’s reasonable to expect that if you are working with us in order to find a candidate to fill a vacancy within your organisation that we would use your data to assist with this process if we identify a potential candidate. We may also use your information to invite you to events that we think may be of interest to you, for example the Recruitment Forum, or to circulate market updates. We use your data in a way which we believe you would reasonably expect us to use it, given our legitimate interest as a recruitment services provider. We believe that the manner in which we process your information is necessary for the purposes of our legitimate interest as an organisation providing you with these recruitment services and does not prejudice your rights and freedoms or legitimate interests.

Suppliers

The main purpose for which we use information about our suppliers is to enable our business relationship to operate effectively, so that we can continue to engage you to provide us with services. We think it’s reasonable to expect that if you are providing us with a service, we will use information such as your contact details and payment details to ensure that we can communicate with you in relation to the services that you provide to us and pay you for them, in accordance with our contractual obligations. We use your data in a way which we believe you would reasonably expect us to use it given our legitimate interests as a recipient of your services. We do not believe that the manner in which we process your personal data prejudices your rights and freedoms or legitimate interests.

People who are listed as referees and emergency contacts

If you have been listed as a referee by a candidate, we will use your personal data to contact you to verify various details, for example relating to their employment history. This is to ensure that we are placing appropriate candidates in appropriate roles. If you have been listed as an emergency contact by a candidate or an employee, we will use your personal data to contact you in the event of an accident or emergency affecting that individual. We use your data in a which we believe you would reasonably expect us to use it given our legitimate interests as a recruitment services provider and an employer. We do not believe that the manner in which we process your personal data prejudices your rights and freedoms or legitimate interests.

People who use our website

The main purpose for which we use your data is to optimise our website and improve your experience. We use your data in a way which we believe you would reasonably expect us to use it given our legitimate interest to improve website performance. We do not believe that the manner in which we process your personal data prejudices your rights and freedoms or legitimate interests. There is more information on this in the cookies section below.

Who do we share your personal data with?

Where your personal data is shared with other parties, the privacy policies of those parties will also apply to your personal data and the way in which it is processed and the period for which it will be retained. This may be different to provisions contained in this Privacy Policy and may continue to apply in the event that our relationship with that party comes to an end. Please refer to the individual privacy policies of those parties for further information. We can provide you with copies of these individual privacy policies upon written request.

Candidates

In order to place you in the job that you want, we may share your personal data with the following categories of people, including but not limited to:

  • prospective employers;
  • individuals and organisations who hold information related to your reference or application to work, such as current, past or prospective employers, educators and examining bodies and employment and recruitment agencies;
  • group companies or trusted third parties such as our service providers (including companies providing testing and screening services, to the extent that these checks are appropriate and in accordance with local laws) client service providers or external consultants (only where you have expressly consented to us doing so) where we feel this will help us to provide you with the best possible service;
  • trusted third parties such as our service providers including IT and software service providers; and
  • government regulatory bodies or law enforcement agencies where considered necessary for us to fulfil any legal obligations applicable to it.

Clients

Unless you specify otherwise, we may share your information with prospective candidates and within our group and associated third parties such as our service providers where we feel this will help us to provide you with the best possible service.

Suppliers

Unless you specify otherwise, we may share your information with any of our group companies and associated third parties such as our service providers and organisations to whom we provide services.

People who are listed as referees and emergency contacts

Unless you specify otherwise, we may share your information with any of our group companies and associated third parties such as our service providers and organisations to whom we provide services.

People who use our website

We may share your information with any of our group companies and associated third parties such as our IT service providers and e-mail service providers.

Transferring your data internationally

We may transfer some of the information you provide to us to countries outside the European Economic Area (‘EEA’) for the purposes of providing our work finding services. In relation to suppliers, your personal data may be held on cloud based systems which are located outside of the EEA. We will take steps to ensure adequate protections are in place to ensure the security of your information. The EEA comprises the EU member states plus Norway, Iceland and Liechtenstein.

How long do we keep your personal data for?

We only retain your personal data for as long as is necessary for us to use your personal data for the purposes described above or to comply with our legal obligations. However, we may need to continue to hold some of your personal data after this period in order to comply with our legal obligations.

When determining the relevant retention periods, we will consider factors such as:

  • our contractual obligations and rights in relation to the relevant personal data;
  • any legal obligation(s) that we have under applicable law to retain data for a certain period of time;
  • our legitimate interests;
  • statute of limitations under applicable law(s);
  • (potential) disputes;
  • any requests that you may have made for your information to be deleted; and
  • guidelines issued by relevant data protection authorities.

Once we have deleted your personal data we will no longer hold this data and you will therefore be unable to exercise your rights of access, erasure, rectification and data portability after this time.

Your rights as a data subject

Under the DPLJ and GDPR, greater rights are afforded to individuals in respect of their personal data and you can exercise these rights even after you have provided us with your personal data. We have set out information regarding these rights below, but if you would like any further information or clarification in respect of any of these rights, please do not hesitate to contact us. We will aim to deal with your request as soon as possible and in any event within 4 weeks (subject to any extensions that we are lawfully entitled to). Please note that any communications which you make in relation to such a request may be recorded in order to enable us to resolve any issues efficiently.

Your right to object to the processing of your personal data

You have the right to object to our processing of your personal data where the processing is carried out for one of the following reasons:

  • our legitimate interests;
  • to enable us to perform a task in the public interest or exercise official authority;
  • for direct marketing purposes; or
  • for scientific, historical, research, or statistical purposes.

The “legitimate interests” and “direct marketing purposes” categories above are the most relevant here.

If you object to us processing your personal data for direct marketing purposes, we are obliged to stop the processing. If you object to us processing your personal data because we deem it necessary for our legitimate interests, we will be obliged to stop the processing unless we can show that we have compelling legitimate grounds for processing which override your interests or that the processing is necessary for the establishment, exercise or defence of a legal claim.

Other rights

Your right to request access (data subject access requests)

You have the right to request confirmation from us as to whether your personal data is being processed by us as the data controller (or on behalf of us) and if so, you have the right to request information regarding certain aspects of the processing and access to your personal data. We will not charge you for providing you with access to the personal data which we hold for you, unless your request is “manifestly unfounded or excessive” or if you are requesting further copies of information that we have already provided to you. In such cases, we may charge you a reasonable administrative cost where legally permissible. We may also request further information from you in order to verify your identity. Where we are legally permitted to do so, we may refuse to act on your request but we will always provide reasons if we do so.

Your right to rectify your personal data

If any of the personal data that we hold for you is inaccurate or incomplete, you have the right to make a written request that we rectify the personal data. If we are satisfied as to the accuracy and completeness of such personal data, we are entitled to take no further action. In order for us to provide you with the best possible service, it is important that the personal information that we hold about you is accurate and complete. Please keep us informed if your personal information changes during the period for which we hold your data.

Your right to be forgotten (the right of erasure)

You have the right to request that we erase the personal data that we hold for you if certain circumstances apply, such as:

  • the personal data are no longer necessary for the purpose for which they were originally collected and/or processed;
  • you have withdrawn your consent to us processing your data, and there is no other valid legal reason for us to continue processing;
  • where the basis on which we process your personal data is because we believe that it’s necessary to do so for our legitimate interests and you object to the processing on that basis and we are unable to demonstrate any overriding legitimate grounds for our continued processing;
  • where you object to the processing of your personal data for direct marketing purposes;
  • the data has been processed unlawfully (i.e. in a manner which is not compliant with the GDPR/DPJL); or
  • it is necessary for the personal data to be erased in order for us to comply with our legal obligations as a data controller.

To the extent that the processing is necessary for any of the following reasons, we are entitled to refuse to comply with the request for erasure:

  • to exercise the right of freedom of expression and information;
  • to comply with legal obligations or for the performance of a public interest task or exercise of official authority;
  • for public health reasons in the public interest;
  • for archival, research or statistical purposes; or
  • to establish, exercise or defend a legal claim.

Your right to restrict processing

You have the right to request that we restrict the processing of your personal data where one of the following circumstances applies:

  • where you contest the accuracy of the personal data that we are processing about you. In this case, our processing of your personal data will be restricted for the period during which the accuracy of the data is verified;
  • where our processing of your data is unlawful, but you would prefer that we restrict our processing of it rather than erasing it;
  • where we have no further need to process your personal data but you require the data to establish, exercise, or defend legal claims; or
  • where you object to our processing of your personal data for our legitimate interests (or public function). In this case, you can request that the data be restricted while we verify our grounds for processing your personal data.

If you obtain a restriction of processing of your data, we will still be able to store your data but we won’t be able to continue to process it unless you consent or the processing is for the purposes of legal proceedings, vital interests (i.e. matters of life or death) or in the public interest. We will, of course, inform you before we lift any such restriction.

In relation to the above rights of rectification, erasure and restriction of processing, if we have shared the personal data with third parties, we will notify them about the rectification or erasure of personal data or restriction of processing, unless this is impossible or involves disproportionate effort. If requested by you, we will also tell you which third parties we have disclosed the personal data to. In the event that we think that it’s reasonable for us not to comply with your request, we will explain our reasons for this decision.

Your right to data portability

You have the right to obtain and transfer your personal data between data controllers, so that you can reuse your personal data for your own purposes across different services on another online platform. This right of data portability applies where the personal data:

  • has been provided to us by you;
  • is processed based on your consent or in order to fulfil a contract; and
  • is processed automatically (i.e. without any human intervention).

We will provide you with your data in a commonly used machine-readable format or alternatively, where technically feasible, we may directly transfer the data for you.

If we have reasonable doubts in relation to the identity of an individual making any of the above requests, we may request further information from you in order to verify your identity.

Where we think that it is reasonable for us not to take any action in relation to one of the above requests, we will explain our reasons for this decision.

Automated individual decision-making

Because our recruitment services require human involvement throughout the process, there won’t be any instances where a decision is made based solely on automated decision making.

Your right to complain to the Data Protection Authority

You have to the right to lodge a complaint with the Data Protection Authority through the Office of the Information Commissioner. The Office of the Information Commissioner can be contacted in the following ways:

Telephone: +44 (0)1534 716530

E-mail: enquiries@OICJersey.org

Address: Office of the Information Commissioner, Brunel House, Old Street, St Helier, Jersey JE2 3RG

Website: https://oicjersey.org

If you would like to exercise any of these rights, or withdraw your consent to the processing of your personal data (where consent is our legal basis for processing your personal data), details of how to contact us can be found above. Please note that we may keep a record of your communications to help us resolve any issues which you raise.

How we protect your data

We have a range of technical and organisational measures in place to ensure that your personal data is appropriately safeguarded including policies and procedures to deal with any suspected data breach.

Where we engage a third party to process your personal data (for example, a testing or screening company), we will seek to enter into an agreement to specify the obligations of each party and we will endeavour to ensure that any such third party has appropriate measures in place to protect your personal data against any unauthorised or accidental use, access, disclosure, damage, loss or destruction.

Information that is gathered from website visitors

In common with other websites, log files are stored on the web server saving details such as the visitor’s IP address, browser type, referring page and time of visit. Cookies may be used to remember visitor preferences when interacting with the website or they may be used to track your return visits to the website.

What are cookies?

Cookies are small digital signature files that are stored by your web browser that allow your preferences to be recorded when visiting the website. You may be able to block cookies via your browser settings but this may prevent you from access to certain features of the website. You can change your cookie settings at any time through your browser settings.

How the information is used

Cookies will track your use of our website and also provide functionality, such as our online chat. This enables us to understand how you use the site and identify any patterns that emerge individually or from larger groups. This helps us to develop and improve our website and services in response to what our visitors want and need and enhance your experience when using the website.

This includes the use of third party cookies. For further information please refer to the individual privacy policies of these parties which are listed below.

Zopim

Zopim cookies help us to provide a live chat functionality to our website visitors.

For more information on Zopim’s Privacy Policy and how they safeguard data visit: https://www.zendesk.com/company/customers-partners/#cookie-policy

Hotjar

We use Hotjar to collect analytics on our website, as well as feedback from our website visitors on their experience of our website.

To read Hotjar’s Privacy Policy visit: https://www.hotjar.com/legal/policies/privacy

Please note: you have the opportunity to opt-out of Hotjar cookies by clicking here: https://www.hotjar.com/legal/compliance/opt-out

Google Analytics

This website also uses Google Analytics, which sets anonymous third-party cookies to collect information about how visitors use the site. They tell us how visitors arrive at, use and move around the website. This information is used for statistical purposes only and helps us improve your experience using the site.

For more information on the Google Analytics Privacy Policy please go to: http://www.google.com/analytics/learn/privacy.html

Please note: you have the opportunity to opt-out of receiving these Google Analytics Cookies anytime by clicking here: http://tools.google.com/dlpage/gaoptout

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