Privacy Notice (Indirect)

Company Name: Bell Cornwall Recruitment (‘the Company’)

Company Contact Details: Jeremy Cornwall, c/o Bell Cornwall Recruitment, Lancaster House, 67 Newhall Street, Birmingham, B3 1NQ.

Document DP5B: Privacy Notice (when personal data is obtained from a 3rd party)

Topic: Data Protection

Date: 19th May 2018

Version: 001


The Company is a recruitment business which provides work-finding services to its clients and work-seekers. The Company must process personal data (including sensitive personal data) so that it can provide these services – in doing so, the Company acts as a data controller.

You may give your personal details to the Company 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. The Company 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.

1. Collection and use of personal data

a. Purpose of processing and legal basis

The Company has collected 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. This includes for example, contacting you about job opportunities, assessing your suitability for those opportunities, updating our databases, putting you forward for job opportunities, arranging payments to you and developing and managing our services and relationship with you and our clients.

In some cases we may be required to use your data for the purpose of investigating, reporting and detecting crime and also to comply with laws that apply to us. We may also use your information during the course of internal audits to demonstrate our compliance with certain industry standards.

The legal bases we rely upon to offer these services to you are:

  • Your  consent
  • Where we have a legitimate interest
  • To comply with a legal obligation that we have
  • To fulfil a contractual obligation that we have with you

b. Categories of data

The Company has collected the following personal data on you:

Personal data:

  • Name
  • Address
  • Contact Details
  • Any other data included within your CV
  • Right to work documentation in line with current legislation

Sensitive personal data:

  • Any data included within your CV (we reserve the right to remove all sensitive personal data and inform you that we have done this).

c. Legitimate interest

This is where the Company has a legitimate reason to process your data provided it is reasonable and does not go against what you would reasonably expect from us.  Where the Company has relied on a legitimate interest to process your personal data our legitimate interests is/are as follows:

  • Providing you with work finding services, including sending your information to clients when you have demonstrated an interest in doing that particular type of work but not expressly consented to the Company passing on your CV
  • Managing our database and keeping your work seeking records up to date
  • Contacting you with information about similar products or services that you have used previously

d. Recipient/s of data

The Company will process your personal data and/or sensitive personal data with the following recipients:

  • Clients of the Company who have engaged the Company for the purpose of finding employees or Clients of the Company who we believe may have legitimate opportunities in line with your work seeking criteria.
  • Former employers who we contact to obtain a reference or Prospective new employers who we contact to provide references.
  • The Recruitment and Employment Confederation (REC) and The Employment Agencies Movement (TEAM). Trade bodies with whom we engage to ensure that our internal processes comply with the highest standards possible in recruitment.
  • Brookes Stephens Chartered Accountants.
  • HIVE 360 – Our Payroll Service Provider who manage payroll services on behalf of the Company and who process payroll payments.
  • NOW Pensions who manage the Company auto-enrolment pension scheme.
  • Other recruitment agencies when a supply chain demands that we liaise via a master vendor.
  • Southall Harries Insurance Brokers who manage all of the Companies Commercial insurance needs.
  • ·Legal Advisors who may be appointed on a case by case basis and Irwin Mitchell Solicitors who provide HR and Employment Law advice to the Company.
  • CSCM IT Solutions who manage and support the IT infrastructure of the Company including provision of Hosted Desktops.
  • Troy Software who supply and support the Company recruitment database (CRM System).
  • Klick Design who manage the Company website.
  • Social Networks – via the Company Twitter, Linked in and Facebook Pages.
  • online who are our online testing company.
  • who are our online testing company.
  • Any public information sources and third party organisations which we use to carry out suitability checks on work-seekers. E.g. the Disclosure and Barring Service and credit referencing agencies.
  • Government and Law Enforcement agencies. HMRC, the Police, the Home Office.
  • Any other organisations that you as a work seeker ask the Company to share your data with.

2. Overseas Transfers

The Company will not transfer the information you provide to us to countries outside the European Economic Area (‘EEA’) for the purposes of providing you with work-finding services. The EEA comprises the EU member states plus Norway, Iceland and Liechtenstein.

3.  Data retention

The Company will retain your personal data only for as long as is necessary for the purpose we collect it. Different laws may also require us to keep different data for different periods of time.

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 the Company has obtained your consent to process your personal data, we will do so in line with our retention policy (a copy of which is attached). Upon expiry of that period the Company will seek further consent from you. Where consent is not granted the Company will cease to process your personal data.

4.  Your rights

Please be aware that you have the following data protection rights:

  • The right to be informed about the personal data the Company processes on you;
  • The right of access to the personal data the Company 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 the Company processing your personal data you have the right to withdraw that consent at any time by contacting Jeremy Cornwall at the address listed above or by following the ‘Remove Consent & Personal Data’ link here

There may be circumstances where the Company will still need to process your data for legal or official reasons. We will inform you if this is the case. Where this is the case, we will restrict the data to only what is necessary for the purpose of meeting those specific reasons.

If you believe that any of your data that the Company processes is incorrect or incomplete, please contact us using the details above and we will take reasonable steps to check its accuracy and correct it where necessary.

You can also contact us using the above details if you want us to restrict the type or amount of data we process for you, access your personal data or exercise any of the other rights listed above.

5.  Source of the personal data

The Company sourced your personal data/sensitive personal data by the following means:

  • Download from Job Boards that hold your CV
  • Social Media including Linked In
  • Third parties such as other Recruitment Agencies or Clients
  • Any other publicly accessible source

6.  Complaints or queries

If you wish to complain about this privacy notice or any of the procedures set out in it please contact: Jeremy Cornwall at the address listed above.

You also have the right to raise concerns with Information Commissioner’s Office on 0303 123 1113 or at, 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.