Candidate Privacy Notice

Candidate Privacy Notice

This notice was last updated on the 25 January 2024.

The notice will be reviewed on an annual basis, as a minimum, or in line with changes in data protection legislation and/or in the context of changes in business practices, or standards and requirements associated with recruitment services or other appropriate and applicable legislations.

We recommend that you regularly check for changes and review this notice when visiting our websites.

  1. INTRODUCTION

CSG Recruitment Solutions is a trading style of Commercial Services Kent Ltd, part of Commercial Services Group (CSG), and is committed to protecting your privacy.  We take your privacy seriously and will only use the personal information that we collect from you or that you provide relating to the recruitment services you have requested from us or whereby you make an enquiry about our services.

If you have any concerns or questions relating to this notice, including how to update or access your personal information or to make a complaint, you will find our contact details in the Contact Us section below. 

We are providing this privacy notice so you know who we are and what we do with any personal information we may collect.

This Privacy Notice explains:

  • Who the Commercial Services Group are
  • What personal information we collect from you when you visit any of our websites, contact us or make an enquiry about any of our services or products
  • How we collect, store and share personal information
  • How we keep your personal information secure
  • Your rights in relation to your personal information
  • How you can make a Subject Access Request
  • How you can make a complaint to the Information Commissioners Office (ICO)

 1.1 WHO WE ARE

Commercial Services Group (CSG) is one of the largest, local authority owned, trading organisations of its kind in the UK.

Since its inception over 90 years ago as the supplies division of Kent County Council, it has grown organically to become one of the leading suppliers of products and services to the education and public sector, serving over 15,000 customers in 85+ countries.

CSG is the umbrella for all its trading brands, it provides the support, dependability, and security to allow all brands to thrive independently. CSG are committed to providing an excellent customer and user experience underpinned by social value and a committed and empowered workforce.

CSG Recruitment Solutions is a trading style of Commercial Services Kent Ltd (Reg No. 5858177), part of Commercial Services Group, a company wholly owned by Kent County Council and registered in England and Wales.

CSG Recruitment Solutions provides a Managed Service Provision and Contingent Workforce solutions to Kent County Council.

We aim to maintain the highest possible standards and seek to adopt best practice with regards to the way in which we manage and process data in the course of our recruitment services and business.

C2K collects, uses, and processes personal information about you. When we do we are regulated under the UK Data Protection Act 2018 (DPA 2018) and the UK General Data Protection Regulation (GDPR). Depending on the service provided we are responsible as either a ‘controller’ or ‘processor’ of that personal information for the purposes of those laws.

If you have any questions, suggestions, or complaints about the processing of your personal information please contact our Data Protection Officer (DPO) via email at dpo@csltd.org.uk.

We understand that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of all our candidates, clients, and other people with whom we interact in the course of undertaking our services. 

This Privacy Notice offers all user with meaningful and accessible guidance on our approach to handling personal data.

Our head office address is:

Commercial Services Group

1 Abbey Wood Road

Kings Hill

West Malling

ME19 4YT

 

Contact Us

If you have any questions, suggestions, or complaints about the processing of your personal information please contact our Data Protection Officer (DPO) via email at dpo@csltd.org.uk or in writing by using the address below; 

 

Data Protection Officer

Commercial Services Group

1 Abbey Wood Road

Kings Hill

West Malling

ME19 4YT

 

  1. HOW WE COLLECT PERSONAL INFORMATION

When you visit our websites or social media pages your personal information may be automatically collected by our web servers and/or cookies.  This information could include your IP address, the date, and the pages that you visit. 

For more details about cookies and how we use them, please read our Cookie Notice 

We collect this data in a variety of ways when you contact us directly via email, phone or face2face, through a job application via a jobs board, or when you create a job seekers account on our website www.csg-executive.co.uk

We may also collect data about you from third parties, including when you register as a candidate on a jobs board and make your profile searchable to recruiters.  As a subscriber to some of these jobs boards, we will be able to view and download your personal details but will only do so in relation to recruitment services.

We may approach previous employers in relation to employment references; we will inform you who we are approaching and when.

  1. WHAT PERSONAL INFORMATION ARE WE COLLECTING

As part of our recruitment process, we may collect and process personal data relating to job seeking candidates.

This includes:

  • your name, address and contact details, including email address and phone number
  • Age, date of birth and gender, marital status, nationality, and photo
  • information likely to be included on your CV including details of your qualifications, skills, experience, and employment/reference details
  • details about your current employment, including salary and any additional benefits
  • information pertaining to your rights to work in the UK, passport/driving licence or ID card
  • information in relation to the Rehabilitation of Offenders Act (1974) and Criminal Records check
  • bank details, national insurance number and statutory tax details

 

 

  1. WHY WE ARE COLLECTING THIS INFORMATION

We collect your personal information in order to provide you with advice and an employment/job opportunities.

We operate both temporary/contract and permanent recruitment services.

Temporary/contract recruitment – an assignment of temporary work placements with various clients across diverse industries and sectors.

Under the provision of temporary/contract recruitment that we may offer, we collect personal information and retain data to enable us to match you to suitable temporary/contract positions.  If you are successful and receive an offer for temporary/contract work, we will process and retain your bank details, national insurance number and statutory tax details in order to fulfil the legal requirement under the HM Revenue and Customs (HMRC) Real Time Information (RTI) regulations.

Permanent recruitment – the provision of promoting and sharing candidate’s personal details with clients, resulting in interviews and job offers/employment with those clients’ organisation. 

Under the provision of permanent recruitment that we may offer, we collect & retain personal data to enable us to match you to suitable permanent positions.  If you are successful and receive an offer for permanent work, we will retain your data to fulfil our statutory legal requirements (Conduct of Employment Agencies and Employment Businesses Regulations 2003 (Conduct Regulations)).

  1. OUR LEGAL BASES TO PROCESSING YOUR PERSONAL INFORMATION

There are a number of different legal bases that we may use in order to collect and/or process your personal information. These are listed below;

Legitimate Interest

We believe it is reasonable to expect that if you are looking for an employment opportunity and have applied via a jobs board, either directly through our website or via any other means then we have a legitimate interest to collect, use and process your data to offer or provide you with advice and employment services.

Where you have posted your CV on various jobs boards and made your personal data publicly accessible, then we may contact you in relation to either a specific vacancy or speculatively for future employment opportunities.  In this instance, we will contact you and gain your consent to further process and retain your personal data.

 

Consent

We will collect and process your personal information with your consent.  Examples of this are when you tick a box to receive job alerts on our website.

You may withdraw your consent at any time by contacting us at dpo@csltd.org.uk or by using the unsubscribe links in our direct marketing emails.

Contractual Obligation

When we have a contract with you we will collect and process your personal information in order to fulfil our contractual obligations. An example of this is where we have a contract for services with you.  We will process your personal details to fulfil and manage the recruitment process.

Legal Obligation

We will use your personal information to comply with our legal obligations.  This may mean that we need to provide your personal information to HMRC, DVLA and any other public authority. If requested we will provide the police with personal information to assist them with investigations.

  1. RIGHTS OF ACCESS TO YOUR PERSONAL INFORMATION

Under current data protection law, you as an individual, have a number of rights in relation to the personal information we hold on you.

We may ask you to verify your identity or request more information about you in order for us to fulfil your request. 

6.1 Your right to correcting and updating your personal information

If any of the information we hold about you, is inaccurate or out of date please contact us by emailing us at csgexecutive@csltd.org.uk

6.2 Your right to erase your personal information

You may ask for your personal information to be erased from our systems by emailing us at the following email address dpo@csltd.org.uk or by post to Data Protection Officer, Commercial Services Group, 1 Abbey Wood Road, Kings Hill, West Malling, ME19 4YT.

We will comply with your request unless there is a lawful reason for us to continue to use and process your personal information.

 

 

6.3 Your right to restrict processing of your personal information

You have the right to restrict the processing of your personal information in the following circumstances 

  • Where you contest the accuracy of the personal information we hold on you
  • Where you believe your personal information has been unlawfully processed
  • Where you believe we no longer require your personal information for processing purposes or you require us to retain the information in order to establish, exercise or defend a legal claim

6.4 Your rights to the portability of your personal information

Your right to data portability allows you to obtain and re-use the personal information we hold on you for your own purposes.  This will be provided to you in a structured, commonly used. and machine-readable format (eg a CSV file).  Machine-readable means that software can extract the data for other organisations to use.  You can ask us to transfer your personal information directly to another service provider where technically feasible.

6.5 Your right to object to the processing of your personal information

You have a right to object about how we process your personal information on the following grounds;

  • Processing based on legitimate interest
  • Processing based on performing a task in the public interest including profiling
  • Direct marketing

You can exercise your right to object by emailing or writing to us at the following email address dpo@csltd.org.uk or by post to Data Protection Officer, Commercial Services Group, 1 Abbey Wood Road, Kings Hill, West Malling, ME19 4YT.

You can also withdraw your consent and opt-out from direct marketing by using the unsubscribe link at the bottom of our marketing emails.

Suppression lists will be maintained to screen against direct marketing information being sent to people who have already exercised their right to object to direct marketing.  These lists will be held for compliance purposes only, and this does not affect your rights to be erased.

 6.6 Your rights relating to automated decision making (including profiling)

You have a right to understand and object to any automated decision making and/or profiling that is being carried out on your personal information (a decision made by automated means and without any human intervention).

Please refer to section 12 in this notices to find out more about how we use your information to make automated decisions, including profiling.

You will need to make your request in writing to us and send your request to dpo@csltd.org.uk

  1. RIGHT TO LODGE A COMPLAINT

You have a right to make a complaint with the supervisory authority if you have any concerns about the collection or processing of your personal information. The supervisory authority is the Information Commissioners Office (ICO) whose contact details can be found on their website Make a complaint | ICO

  1. HOW WE PROTECT YOUR PERSONAL INFORMATION

We take the protection of your personal information seriously and will treat it with care and take appropriate steps to protect it.

What we do to protect your personal information.

  • Our systems, services, software, and equipment meet acceptable security standards (such as CyberEssentials)
  • Our scanning security hardware and software are regularly checked to ensure they are functioning correctly
  • Our computers are password protected and passwords are changed regularly
  • Our systems are monitored for attacks, and we carry out penetration tests to strengthen their security
  • We store printed documents that contain personal information securely and ensure that they are only accessed by authorised personnel
  • We securely dispose of any personal information that is no longer required
  • We verify the identity of anyone requesting access to personal information prior to providing it.
  • We also have procedures in place to deal with any suspected data security breach, and we will notify you and the ICO of any suspected breach where we are legally required to do so.
  1. DATA STORED OR HANDLED OUTSIDE OF THE UK / EUROPEAN UNION (EU)

Information may be retained at our offices and those of our service providers, our representatives, agents, and clients as described above.

Some of the personal information you provide to us may be transferred to countries outside of the UK, or the EU/EEA. Where this occurs, CSG will make restricted transfer under UK “adequacy regulations” to protect individuals rights and freedoms for their personal data.  Where the UK has no “adequacy regulations” then the restricted transfer will be subject to appropriate safeguards whereby standard contractual clauses have been entered into with the organisation receiving the data.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data outside of the UK or the European Economic Area (EEA). 

  1. SPECIAL CATEGORY DATA

In some instances, we may process special category data, such as information in relation to your ethnic origin, sexual preferences, or religion on behalf of our clients, in this instances we will be acting as a data processor.

The special categories of personal information we collect, or process may include information about your; 

  • Race
  • Ethnic origin
  • Politics
  • Religion
  • Trade union membership
  • Genetics
  • Biometrics
  • Health
  • Sexual orientation

We may also collect information about disabilities in order to make adjustments throughout the recruitment process, in order to carry out our obligations and exercise specific rights in relation to employment.  In any event, we will notify and gain your consent to collect and process this information.

  1. WE SHARE YOUR PERSONAL INFORMATION

Your data may be shared internally to enable us to manage the recruitment process.  However, we will never share your data with our clients, without your permission; if we deem your application suitable for a role, we will inform you of the organisation and only with your consent will we share your personal data with the hiring client.

The personal data of temporary applicants who receive and accept an assignment may be shared with previous employers to obtain references and employment background checks where required.

We may also share your personal information with trusted third parties that are under contract with us and where it is necessary to administer our working relationship with you or where we have another legitimate interest in doing so (providing this is not overridden by your interests).

Our trusted third parties may include service providers who supply us with processing services or functions, including our contracted IT suppliers, Access to data is only granted where authorised and specifically required in line with our contracts with them.

Management information may be shared within Commercial Services Group, under a Data Sharing Agreement held by its operating company Global Commercial Services Group Ltd, a company registered in England and Wales (Reg No. 11735631).  This Agreement reflects the requirements of the UK GDPR and DPA2018.

We may also need to share some of the categories of personal information with other parties where a transfer of the business takes place. Usually, information will be anonymised or pseudonymised, but this may not always be possible. The recipient of the information will be bound by confidentiality obligations and legally binding data sharing agreements.

  1. HOW WE USE YOUR INFORMATION TO MAKE AUTOMATED DECISIONS (INCLUDING PROFILING)

On some occasions, we may collect or process your personal information using automated decision-making systems (a decision made by automated means and without any human intervention). We do this because we want to provide you with recruitment information, employment services and opportunities that are of interest and are most relevant to you.

For CSG Recruitment Solutions, this could mean utilising machine learning technology to match candidates CV information and experience to various job opportunities based on the selection criteria outlined in job descriptions/specifications, as provided by the client, to create shortlists for reviewing against client vacancies.

Or used to create a candidate profile using publicly accessible information from other online sources (e.g. job boards, LinkedIn etc.). Where profiles are created, we will contact you and gain your consent to further process and retain your personal data for job seeking opportunities and recruitment services.

If you consent to receive Job and Blog alerts, we will use automated profiling based on your requirements, we do this because we want to provide you with information, products and services that are of interest and are most relevant to you. 

The use of this type of technology helps us to make quicker and more consistent decisions, particularly in cases where large volume of data needs to be analysed and decisions made efficiently and effectively.  These automated decisions can affect the services we may offer you now or in the future.

If you have any questions or concerns about how we use your data to make automated decisions please contact our Data Protection Officer (DPO) via email at dpo@csltd.org.uk, or how to exercise your individual rights please refer to section 6 in this privacy notice.

 

 

  1. OUR RETENTION POLICY

We do not retain your personal information for longer than is necessary.  If your application is unsuccessful, and with your consent, Commercial Services Group may retain your personal data on our secure database, in order to assist you with any future job opportunities which you may be suitable for.  You are free to withdraw your consent at any time.

The length of time we retain your personal information for will be determined by the type of information we collect and the purpose that it has been processed for and/or our obligations under other laws. 

  • personal information processed under contractual obligations will be retained for 12 months beyond the date of your temporary last assignment or last permanent placement
  • the personal information of temporary workers will be retained for 7 years to fulfil our HMRC obligations
  • jobseeker personal information (e.g. CV) will only be retained for 24 months unless you have exercised your right for your personal information to be erased or you have objected to your information being processed
  • we will hold your personal information for marketing purposes unless you have opted out or unsubscribed from receiving marketing information.

 If you have any concerns about our retention period please contact the dpo@csltd.org.uk

  1. LINKS TO OTHER WEBSITES

Our privacy notice only applies to the CSG Recruitment Solutions website.

Our website may contain links to other organisations’ websites, which we do not control. These websites are owned and operated by a third party, and they are responsible for processing personal data in accordance with their own privacy policies.