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.
We 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 UK General Data Protection Regulation (UK GDPR) (Regulation (EU) 2016/679) is a 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.
The Brexit transition period ended on 31 December 2020 and the UK has now officially left the EU. The UK GDPR has been directly incorporated into UK law sitting alongside 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 & Compliance Manager – email@example.com
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.
Who we are and what we do
We are a recruitment agency and recruitment business as defined in the Employment Agencies and Employment Businesses Regulations 2003 (our business). We also provide the following other services; training, outsourcing and consultancy. We 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 client contacts;
- Supplier contacts to support our services;
- Employees, consultants, temporary workers;
Collection and use of personal data
Information you give to us or we collect about you.
This is information about you that you give us by filling in forms on our site www.revoco-talent.co.uk (our site) or by corresponding with us by phone, e-mail or otherwise. It includes information you provide when you register to use our site, enter our database, subscribe to our services, attend our events (online or virtually), 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.
The information you give us or we collect about you may include your name, address, private and corporate e-mail address, phone number, financial information, compliance documentation and references verifying your qualifications and experience and your right to work in the United Kingdom, curriculum vitae and photograph, links to your professional profiles available in the public domain e.g. LinkedIn, Twitter, business Facebook or corporate website.
Information we collect about you when you visit our website.
With regard to each of your visits to our site we will automatically collect the following information:
technical information including the Internet protocol (IP) address used to connect your computer to the Internet, your login information if applicable, browser type and version, information about your visit, including [the full Uniform Resource Locators (URL), clickstream to, through and from our site (including date and time), page response times, download errors, length of visits to certain pages and page interaction information (such as scrolling, clicks, and mouse-overs)
Information we obtain from other sources.
This is information we 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 we will inform you, by sending you this privacy notice, within a maximum of 90 days of collecting the data of the fact we hold personal data about you, the source the personal data originates from and whether it came from publicly accessible sources, and for what purpose we intend to retain and process your personal data.
We are working closely with third parties including sub-contractors in technical, professional, payment and other services, advertising networks, analytics providers, credit reference agencies and professional advisors. We may receive information about you from them for the purposes of our recruitment services and ancillary support services.
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 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 or to your organisation. To provide you with information about other goods and services we offer that are similar to those that you have already purchased, been provided with or enquired about and to improve our service. The core service we offer to our candidates and clients is the introduction of candidates to our clients for the purpose of temporary or permanent engagement. However, our service expands to supporting individuals throughout their career and to supporting businesses’ resourcing needs and strategies.
Our legal bases we rely upon to offer these services and for processing your personal data are:
- Legitimate interest (described in more detail below)
- Consent (Where we rely on consent, you will be asked for your express consent)
- Legal obligation (in some cases, where we are required by law or regulation to process your data.)
- Contractual obligation (if we 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)
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 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 contact details is a fundamental part of this process.
In order to offer this service and support our candidates’ career aspirations and our clients’ resourcing needs Revoco requires a database of current and prospective client and candidate data containing both historical and current information and current resourcing requirements.
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. Where consent is the lawful basis for our processing you have the right to withdraw your consent to this particular processing at any time.
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)
- To store on the system video interviews specific clients in order to provide you with work-finding services for a period of 2 years
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).
Other Uses we will make of your data
We will also use your data:
- To administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
- To improve our site to ensure that content is presented in the most effective manner for you when you are using your computer or other devices;
- To notify you about changes to our service;
- To allow you to participate in interactive features of our service, when you choose to do so;
- As part of our efforts to keep our site safe and secure;
- To measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you;
- To make suggestions and recommendations to you and other users of our site about goods or services that may interest you or them.
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:
Do you have to provide us with personal data?
You may refuse to give us your personal and sensitive personal data. Furthermore, you have the right to ask us to delete, change or stop processing your data that we have already received or collected. If you do not provide us with personal or sensitive personal data, or if you request a restriction of processing however, we may not be able to provide you with the services that you have requested and that are stated in this policy.
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 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 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.
We use the following types of cookies:
Strictly necessary cookies: These are cookies that are required for the operation of our website and under our terms with you. They include, for example, cookies that enable you to log into secure areas of our website.
Analytical/performance cookies: They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us for our legitimate purposes to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
Functionality cookies: These are used to recognise you when you return to our website. This enables us, subject to your choices and preferences, to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
Targeting cookies: These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information subject to your choices and preferences to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third
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 understand our legal duty to retain accurate data and only retain personal data for as long as we need it for our legitimate interests and that you are happy for us to do so. Accordingly, we have a data retention notice [and run data routines to remove data that we no longer have a legitimate interest in maintaining. 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
You have the right to ask us not to process your personal data for marketing purposes. We will usually inform you (before collecting your data) if we intend to use your data for marketing purposes or if we intend to disclose your information to any third party for marketing purposes. We will collect express consent from you, if legally required, prior to using your personal data for marketing purposes.
You can exercise your right to accept or prevent processing for marketing purposes by checking the boxes on the forms we provide you when we collect your data. You can also exercise the right to not have your data used for marketing purposes at any time by contacting us at https://www.revoco-talent.co.uk/login.aspx or contacting Sian Wills: Operations & Compliance Manager – firstname.lastname@example.org
Our site may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliate. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
The UK GDPR provides you with the right to:
Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we 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 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. You also have the right to object where we 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. The ICO can be contacted through this link: https://ico.org.uk/concerns/
Access to information
The Data Protection Act 2018 and the UK GDPR give you the right to access information held about you. We also encourage you to contact us to ensure your data is accurate and complete. Your right of access can be exercised in accordance with the Act and the UK GDPR.
A subject access request should be submitted to email@example.com . No fee will apply (unless the requests from a data subject are manifestly unfounded or excessive, in particular because of their repetitive character). In such circumstances, we may charge a fee or refuse to act on the request.
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: Sian Wills: 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