Revoco is a recruitment business which provides work-finding services to its clients and work-seekers. Revoco must process personal data (including sensitive personal data) so that it can provide these services – in doing so, Revoco acts as a data controller.
Revoco are committed to protecting and respecting your privacy and this notice sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed
The General Data Protection Regulation (GDPR) (Regulation (EU) 2016/679) is a new regulation which replaces the Data Protection Regulation (Directive 95/46/EC). 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.
Even though the UK has expressed its intention to leave the EU in March 2019, the GDPR is applicable in the UK from 25th May 2018. The Government intends for the GDPR to continue in UK law post Brexit and has therefore enforced the Data Protection Act 2018.
For the purposes of data protection legislation in force from time to time the data controller is Revoco Limited of Soho Studios, 2nd Floor, 49 Merchant Street, Bristol, BS1 3EE.
Our nominated Data Protection Officer is Sian Wills: Operations Manager – firstname.lastname@example.org
You may give your personal details to Revoco directly, such as on an application or registration form or via our website, or we may collect them from another source such as a jobs board. Revoco must have a legal basis for processing your personal data. For the purposes of providing you with work-finding & our wider services and/or information relating to roles relevant to you we will only use your personal data in accordance with the terms of the following statement.
Collection and use of personal data
Purpose of processing and legal basis
Revoco will collect your personal data (which may include sensitive personal data) and will process your personal data for the purposes of providing you with work-finding services, information, products and services that you request from us or we think will be of interest to you (because it is relevant to your career and/or organisation), to improve our service, and in order to carry out our legal obligations arising from any contracts we have entered, or intend to enter, into.
The legal bases we rely upon to offer these services to you are:
- Legitimate interest
- Legal obligation
- Contractual obligation
Where Revoco has relied on a legitimate interest to process your personal data our legitimate interests are as follows:
As a recruitment business our aim is to fill a client’s vacancy, permanent or contract, and help candidates find suitable work. We do so by introducing the candidates to clients and clients to candidates. This exchange of personal data is a fundamental and essential part of the process.
In order to offer this service Revoco requires a database of current and prospective client and candidate data containing both historical and current information.
Revoco will provide work finding services through a variety of means; searching on its historical database, advertising for applicants, searching job boards, social media and networking sites such as LinkedIn.
Revoco think it is reasonable to expect that if a candidate has applied to an advert, put their details on a job board or is “Open to Opportunities” on LinkedIn then you are happy for us to collect and use your data to provide work finding services on the basis of legitimate interest.
To deliver our services we need to contact candidates and clients on a regular basis via email, phone, job alerts and other relevant notifications.
In certain circumstances we may be required to obtain your consent for the processing of your personal data in relation to certain activities. We will request your consent orally, by email or by an online process and record your response on our system.
Your consent may be required for some of the following purposes:
- To transfer your personal data, CV, video interview to specific clients in order to provide you with work-finding services
- Enabling you to submit your CV online and amend your profile, apply via our website for jobs or to subscribe to job alerts & email marketing
- To request information (such as references, qualifications and potentially any criminal convictions, to the extent that this is appropriate and in accordance with local laws)
- Send you details of reports, promotions, offers, networking and client events, and general information about the industry sectors which we think might be of interest to you
- Proactively market excerpts of your details, or snippets of your video interview, to our clients or on our website/social channels, with the purpose of generating interest and suitable jobs on your behalf (only where we have obtained your express consent to do so in advance)
You have a right to withdraw your consent at any time by informing Revoco that you wish to do so.
Revoco will rely on legal/contractual obligation to process your personal data when it is required by law or necessary in order to enter into a contract or agreement to provide services to you or your organisation and/or where you are providing services to us. In these circumstance failure to provide the data could result in Revoco being unable to aid in setting up a contract of employment, completing statutory obligations, or providing services (e.g. timesheets system and payroll).
Who we collect personal data from
To allow us to provide the best possible employment opportunities and tailored solutions we collect personal data of the following types of people:
- Candidates – prospective and placed candidates for permanent and contract roles
- Clients – prospective and current client contacts
- Suppliers – prospective and current to support our processes
- Referees and emergency contacts – for candidates, prospective employees and current employees
Source of personal data
Revoco sources your personal data/sensitive personal data directly from you, the data subject, by:
- Filling in forms on our site www.revoco-talent.co.uk (our site)
- Corresponding with us by phone, e-mail or otherwise
This also includes information you provide when you register to use our site, to enter our database, subscribe to our services, attend our events, participate in discussion boards or other social media functions on our site, enter a competition, promotion or survey and when you report a problem with our site
or by the following means from a publicly accessible 3rd party source:
- Job board & CV databases
- Company websites
- Social Media
- Networking sites like LinkedIn
or by other sources:
Disclosure of your information inside and outside of the EEA
We will share your personal information with:
Any member of our group both in the EEA and outside of the EEA.
Selected third parties including:
- Clients for the purpose of introducing candidates to them;
- Candidates for the purpose of arranging interviews and engagements;
- Clients, business partners, suppliers and sub-contractors for the performance and compliance obligations of any contract we enter into with them or you;
- subcontractors including email marketing specialists, event organisers, payment and other financial service providers
- Advertisers and advertising networks that require the data to select and serve relevant adverts to you and others. We do not disclose information about identifiable individuals to our advertisers, but we will provide them with aggregate information about our users (for example, we may inform them that 500 men aged under 30 have clicked on their advertisement on any given day). We may also use such aggregate information to help advertisers reach the kind of audience they want to target (for example, women in SW1). We may make use of the personal data we have collected from you to enable us to comply with our advertisers’ wishes by displaying their advertisement to that target audience;
- Analytics and search engine providers that assist us in the improvement and optimisation of our site;
- Credit reference agencies, our insurance broker, compliance partners and other sub-contractors for the purpose of assessing your suitability for a role where this is a condition of us entering into a contract with you.
We will disclose your personal information to third parties:
- If Revoco Limited or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
The lawful basis for the third party processing will include:
- Their own legitimate 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 we store and process your personal data
The data that we collect from you may/will be transferred to, and stored at, a destination outside the European Economic Area (”EEA”). It may be transferred to third parties outside of the EEA for the purpose of our recruitment services. It may/will also be processed by staff operating outside the EEA who work for us or for one of our suppliers. This includes staff engaged in, among other things, our recruitment services and the provision of support services. By submitting your personal data, you agree to this processing. Revoco Limited will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy notice.
All information you provide to us is stored on our secure servers. Any payment transactions will be encrypted [using SSL technology].] 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.
Revoco would like to share with you how it collects certain data about you from when you visit the following website: revoco.co.uk and also from when you contact us directly and/or from our own marketing activities.
What we may be collecting from you:
- Search terms you have used to either find our website or used on our website, a record of all browsing behaviour including links clicked. This is done via a cookie which is set on your first arrival to our website and the contents of any form you submit to us.
- Information on engagement with the emails and SMS messages you receive from us.
- The IP address your router freely transmits to our webservers.
- Your browser user agent as freely transmitted by your computer. This includes your browser build information, your device type and your computer’s operating system.
- Data held with help improve the content we display on our website
- Some personal data may also be collected about you from the forms and surveys you complete, from records of our correspondence and phone calls.
- Social media information either in the public domain or you share with us.
We will not be collecting:
- Information about browsing habits outside of our own domains (namely revoco.co.uk)
- Personal sensitive information (special categories of data) relating to you and your private life such as gender and age.
- Identify each session that is open on our site. This cookie holds no personal data. All it stores is an ID number generated by us.
- Notify a user that they are using an outdated version of IE and that they should upgrade. This cookie holds no personal data.
- Track when a user has made a failed login attempt to our portal. This cookie holds no personal data.
- Identify when a user has opened the current job advert page from a link sent to them by email from us e.g. Job Alerts or Mail Marketing.
- Authenticate a logged in user on our site, effectively this is how we keep you logged into our site and able to navigate the site without needing to login every time.
Currently we do not have the technical ability to get your express permission to opt out of our cookies so we encourage you to manage your browser settings if you want to control these.
Categories of data
Revoco has collected the following personal data on you:
- Name, Date of Birth and contact details including phone numbers, address, personal and corporate emails
- Experience, training and qualifications
- CV with details on your employment information and any other personal data you have included
- Financial information
- Compliance documentation and references
- Photographic ID
- National Insurance
- Links to social media and professional networking profiles
Sensitive personal data:
- Disability / health condition relevant to the role
- Criminal convictions
- Eligibility to work in the UK / Visa requirements
In the case we have obtained information about you from a publicly available source we will inform you, by sending you a link to this privacy notice and subscription preferences, within a maximum of 30 days of collecting the data.
Recipients of data
Revoco will process your personal data and/or sensitive personal data with the following recipients:
We may share your personal data with various parties, in various ways and for various reasons. Primarily we will share your information with prospective employers to increase your chances of securing the job you want.
Unless you specify otherwise, we may also share your information with any associated third parties such as our service providers where we feel this will help us to provide you with the best possible service. Where appropriate and in accordance with local laws and requirements, we may also use your personal data for things like marketing, profiling and diversity monitoring. Where appropriate, we will seek your consent to undertake some of these activities.
We will share your data primarily to ensure that we provide you with a suitable pool of Candidates and to provide you with an MSP programme, RPO services or other strategic talent acquisition services (or assist another organisation to do so). Unless you specify otherwise, we may share your information with any associated third parties such as our service providers to help us meet these aims.
Unless you specify otherwise, we may share your information with associated third parties such as our service providers and organisations to whom we provide services.
Referees and Emergency Contacts:
Unless you specify otherwise, we may share your information with any associated third parties such as our service providers and organisations to whom we provide services.
Unless you specify otherwise, we may share your information with any associated third parties such as our service providers and organisations to whom we provide services.
The lawful basis for the third party processing will include their own legitimate business interests in processing your personal data, mainly to fulfil their resourcing needs, satisfaction of their contractual obligations to us as our data processor, for the purpose of a contract or to fulfil their legal obligation.
Other uses of your Data
- To notify you of changes to our service
- To allow you to participate in interactive features of our service, when you choose to do so
- To make suggestions and recommendations to you and other users about services that may be of interest to you or them
We do not undertake automated decision making and profiling. We 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.
All data is stored on our secure servers. Transactions are encrypted using SSL technology. Where you have set, or we have given you, a password which enables you to access our portal or 3rd party portals, you are responsible for keeping this password confidential.
Unfortunately the transmission of any information via the internet is not completely secure. Although we 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 to try and prevent unauthorised access.
Revoco will retain your personal data only for as long as is necessary. Different laws require us to keep different data for different periods of time and we run data cleansing routines to remove data that we no longer have a legitimate business interest in maintaining.
The Conduct of Employment Agencies and Employment Businesses Regulations 2003, require us to keep work-seeker records for at least one year from (a) the date of their creation or (b) after the date on which we last provide you with work-finding services.
We must also keep your payroll records, holiday pay, sick pay and pensions auto-enrolment records for as long as is legally required by HMRC and associated national minimum wage, social security and tax legislation.
Where Revoco has obtained your consent to process your personal and sensitive personal data, we will do so in line with REC retention policy. Upon expiry of that period Revoco will seek further consent from you. Where consent is not granted Revoco will cease to process your personal data and sensitive personal data.
If you have completed a video interview it will be held on our secure video platform, Spotlight, for a maximum of 6 months at which point it will auto delete. Please let us know if you would like it to be deleted sooner.
To try and ensure your data is accurate we do the following:
- Enable you to access, review and manage your own data and preferences to keep them up to date and accurate
- Keeping in touch with you so you can let us know of changes to your personal data
Please be aware that you have the following data protection rights:
- The right to be informed about the personal data Revoco processes on you;
- The right of access to the personal data Revoco processes on you;
- The right to rectification of your personal data;
- The right to erasure of your personal data in certain circumstances;
- The right to restrict processing of your personal data;
- The right to data portability in certain circumstances;
- The right to object to the processing of your personal data that was based on a public or legitimate interest;
- The right not to be subjected to automated decision making and profiling; and
- The right to withdraw consent at any time.
Where you have consented to Revoco processing your personal data/ and sensitive personal data you have the right to withdraw that consent at any time by changing your preferences at https://www.revoco-talent.co.uk/login.aspx or contacting Christine Christodoulou on email@example.com
Changes to our privacy notice
Any changes we make to our privacy notice will be posted on this page and, where appropriate, notified to you by email. Please check back frequently to see any updates or changes.
Complaints or queries
If you wish to complain about this privacy notice or any of the procedures set out in it please contact: Christine Christodoulou firstname.lastname@example.org
You also have the right to raise concerns with Information Commissioner’s Office on 0303 123 1113 or at https://ico.org.uk/concerns/, or any other relevant supervisory authority should your personal data be processed outside of the UK, if you believe that your data protection rights have not been adhered to.