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. Please read the following notice carefully to understand our views and practices regarding your personal data and how we will treat it.
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 Christine Christodoulou: firstname.lastname@example.org
You may give your personal details to Revoco directly, such as on an application, registration form or via our website, or we may collect them from another source such as a job board. Revoco must have a legal basis for processing your personal data. For the purposes of providing you with work-finding 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;
• Other professional contacts.
We collect information about you to carry out our core business and ancillary activities.
Information you give to us or we collect about you
This is information about you that you give us by 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 that you give to us or that we collect about you may include your name, address, date of birth, private and corporate e-mail address, phone number, financial information such as bank details, national insurance number, compliance documentation and references verifying your qualifications /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 regards 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) and any phone number used to call our service number.
Information we obtain from other sources
This is information we obtain about you from other sources such as LinkedIn, Facebook, social media sites, 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 30 days of collecting the data of the fact that 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.
Who we collect personal data from
To allow us to provide the best possible employment opportunities and tailored solutions we collect personal data from 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; and
Purpose of processing and legal basis
Revoco will collect your personal data (which may include special category personal data) and will process said 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;
• providing 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.
• Improving 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.
The legal bases we rely upon to offer these services and for processing your personal data are:
• Legitimate interest (described in more detail below);
• Consent (an example of when we will rely on consent as the legal basis for processing your data is when we do so for marketing purposes);
• Legal obligation (where we are required by law or regulation to process your data); and/or
• 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).
Our Legitimate Interests
Where Revoco has relied on a legitimate interest to process and retain your personal data, our legitimate interests are as follows:
As a recruitment business and recruitment agency our aim is to introduce candidates to clients for permanent employment, temporary assignments 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 client and candidate data. The database will contain both historical and current candidate information, client contacts and resourcing requirements.
To maintain, expand and develop our business, we also need to record the personal data of prospective candidates and client contacts.
Revoco will provide work finding services through a variety of means including, but not limited to:
• searching on its historical database;
• advertising for applicants;
• searching online job boards such as CV Library, social media platforms and networking sites such as LinkedIn.
Revoco believes that it is reasonable to expect that if a candidate has applied to an advert, registered on our website, put their details on a job board or is “Open to Opportunities” on LinkedIn then they are happy for us to collect and use their personal 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.
Should we seek to rely on consent to lawfully process your data, we will request your consent orally, by email or by an online process for the specific activity that we require consent for 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. Please email email@example.com to request this.
Your consent may be required for some of the following purposes:
• 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);
Revoco will rely on legal/contractual obligation to process your personal data when:
a) it is required by law;
b) it is necessary in order to enter into a contract or agreement to provide services to you or your organisation;
c) and/or where you are providing services to us.
In these circumstances, 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.
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.
Do you have to provide us with personal data?
You may refuse to give us your personal and special category 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 UK, 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. 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 understand our legal duty to retain accurate data and only retain personal data for as long as we need it for our legitimate interests or provided that you are happy for us to do so. Accordingly, we have a data retention notice and run data cleansing 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.
To try and ensure your data is accurate we do the following:
• Our website enables you to access, review and manage your own data and preferences to keep them up to date and accurate;
• Keep in touch with you so you can let us know of changes to your personal data.
• Prior to making an introduction, we will check that we have accurate information about you.
The criteria we use to determine whether we should retain your personal data include:
• The nature of the personal data;
• It’s perceived accuracy;
• Our legal obligations;
• Whether an interview or placement has been arranged;
• Our recruitment expertise and knowledge of the industry by sector and job role;
• Your engagement and communication with us.
We may store and handle your data in the following ways:
• We may archive part or all of your personal data, retain it on our financial systems only or delete all or part of the data from our main Customer Relationship Manager (CRM) system.
• We may pseudonymise parts of your data, particularly following a request for restriction or erasure of your data, to ensure that we do not re-enter your personal data on to our database, unless requested to do so.
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 to 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 Christine Christodoulou at 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 that 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 to our privacy notice.
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 at 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.