SILVER CLOUD HR LIMITED
Silver Cloud HR Limited respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data which you provide to us, or which we obtain, when you are a client, candidate or supplier of ours (excluding our associates), when you use our website (www.silvercloudhr.co.uk), or when we deal with you in the course of our business.
1. IMPORTANT INFORMATION
Silver Cloud HR Limited (a company with company number 07042483) is the controller and responsible for your personal data (collectively referred to as “Silver Cloud”, “we”, “us” or “our” in this privacy notice).
We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below.
Our full contact details are as follows:
Address: 20-22 Wenlock Road, London, England, N1 7GU
Telephone Number: +44 (0) 203 818 5807
Email address: firstname.lastname@example.org
Our website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
2. THE DATA WE COLLECT AND HOW WE COLLECT IT
The data we collect
We collect, use, store and transfer:
• Identity and Contact Data: personal and identity data, including your name, date of birth, copies of ID, post address, email address, telephone numbers and information relating to a candidate’s immigration status and right to work;
• Recruitment Data: references and other information included in a CV, covering letter;
• Financial Data: bank account details, information regarding remuneration packages offered to candidates by our clients including information regarding salary, fee rates, bonus, expenses and benefits in kind;
• Technical Data: information we collect automatically when you visit our website or interact with us by email, including your IP address, browser details, and device details;
• Transaction Data: details of services we provide to you;
• Marketing and Communications Data: includes your preferences in receiving marketing from us and your communication preferences.
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with our services).
Where we collect your data from
We collect your data from different sources:
• We collect all of the types data listed above directly from you when you interact with us;
• We collect Identity and Contact Data from LinkedIn and online job boards;
• We collect name and contact details from professional contacts or third parties who send us your details as prospective clients, candidates, associates or business partners.
• We collect Technical Data automatically when you interact with our website or email us or unsubscribe from our mailing list, by using cookies and other similar technologies.
3. HOW WE USE YOUR PERSONAL DATA
We will only use your personal data when the law allows us to.
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us using the details above if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
|Purpose/Activity||Lawful basis for processing including basis of legitimate interest|
|To register you as a new client, candidate, or supplier||(a) Performance of a contract with you
(b) Necessary for our legitimate interests (in the case of candidates, to build our database where you have requested to be included or made your details available for inclusion).
|To provide services to you and carry out your instructions in connection with our services.||Performance of a contract with you|
|To accept services from you as our supplier.||Performance of a contract with you|
|To carry out administration in connection with the provision of services to you, including:
(a) Managing payments, fees and charges
(b) Collect and recover money owed to us
(c) Making payments that are due to you.
|a) Performance of a contract with you
(b) Necessary for our legitimate interests (to recover debts due to us)
|To manage queries relating to services we have provided to you historically||(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to be able to respond to queries about our services)
|To manage our relationship with you as a client, candidate, supplier or professional contact, which will include:
(b) Asking you to leave a review or take a survey
|(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our records updated and to study how clients and candidates use our products/services)
|To enable you to partake in a competition or complete a survey||(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to study how Clients and Candidates use our products/services, to develop them and grow our business)
|To administer and protect our business and our website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)||(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
(b) Necessary to comply with a legal obligation
|To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you||Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)|
|To use data analytics to improve our website, products/services, marketing,customer relationships and experiences||Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)|
|To send updates to candidates about vacancies that may be of interest to them||(a) Consent (where you have provided positive consent)
(b) Necessary for our legitimate interests (to develop our products/services and grow our business)
|To invite you to networking and professional events, and to inform you about developments in our business, HR payroll and systems, and recruitment more generally||(a) Consent (where you have provided positive consent)
(b) Necessary for our legitimate interests (to develop our products/services and grow our business).
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.
In addition, we may process your personal data without your knowledge or consent, where this is required or permitted by law.
We may use your personal data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which of our services and vacancies may be relevant for you.
You will receive marketing communications from us in respect of our business and our services/vacancies if you have requested information from us or enlisted with us and, in each case, you have not opted out of receiving that marketing. You will also receive information if you have opted to receive this when completing a form on our website.
You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting use using the details above at any time.
Cookies when using our website
4. DISCLOSURES OF YOUR PERSONAL INFORMATION
We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 3 above:
• Third parties who we interact with on your behalf including clients’ employees and staff and candidates. This includes us sending your details and CV to potential employers.
• Service providers based within the UK, wider EEA or outside the EEA who provide IT and system administration services.
• Event Partners who assist us with organising events and marketing those events.
• Our professional advisers including lawyers, bankers, auditors and insurers based in the UK or EEA who provide consultancy, banking, legal, insurance and accounting services.
• HM Revenue & Customs regulators and other authorities based in the UK who require reporting of our processing activities in certain circumstances.
• Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
5. INTERNATIONAL TRANSFERS
We may transfer your personal data to third parties providing services to us who are based outside of the European Economic Area (EEA). This includes parties providing IT administration services and hosting services.
Whenever we transfer your personal data outside of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
• you have expressly consented to the transfer of data;
• transferring data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission;
• using specific contracts approved by the European Commission which give personal data the same protection it has in Europe; or
• for providers based in the US, we may transfer data to them if they are part of the Privacy Shield.
6. DATA RETENTION
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
For more details of our specific retention periods, please contact our Data Privacy Manager.
7. YOUR LEGAL RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your personal data. These rights are set out below. If you wish to exercise any of the rights set out above, please contact our Data Privacy Manager.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
Complaint to the ICO
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
Your legal rights
Your legal rights are as follows:
• Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
• Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected.
• Request erasure of your personal data. This enables you to ask us to delete or remove personal data 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 data where you have successfully exercised your right to object to processing (see below).
• Object to processing of your personal data where we 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 as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. .
• Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in certain circumstances, for example, if you want us to establish its accuracy or the reason for processing it.
• Request the transfer of your personal data to you or to a third party.
• Withdraw consent at any time where we are relying on consent to process your personal data. If you withdraw your consent, we may not be able to provide certain information to you.