Privacy Policy

Last updated 24 July 2020

This privacy notice explains how we, Silver Swan Recruitment Limited of The Ministry, 79-81 Borough Rd, London, SE1 1DN with company number 8367729 (we, us, our) process your personal data (you, your) when you use our website, apps or platforms (services).

Please do not use our services unless you are 16 years old or over.

1. Who does this privacy notice apply to?

This notice applies to:

users of our services;
candidates who use our services;
clients who rely on our service; and
persons who interact with us, when you call us, email us or visit our offices.

This notice applies to you whether you act in your personal capacity or as employee or agent of an organisation.

2. What personal data is processed about you?

Generally, “personal data” refers to any information that identifies you or relates to you. We will process personal data including:

your user details such as user ID and name;
contact details such as your address, email and image;
application details such as your curriculum vitae including education and employment history and immigration status;
information from your public social media accounts such as LinkedIn, Twitter, business Facebook or corporate website;
salary and other employment details if you participate in our market surveys;
information required for background checks such as financial information;
details of third parties such as your referees and emergency contact;
information for voluntary diversity monitoring;
details of criminal convictions and health information if required for the role applied for;
when accessing our services, your device & browser will automatically provide unique information such as mobile device ID, internet protocol (IP) address, cookie ID, online identifiers, geolocation data, operating system, browser type and time zone setting;
our systems may generate usage data about how you navigate and engage with our services and download materials, security logs, and online activity data such as clickstream data, page interaction information (such as scrolling, clicks, and mouse-overs), your preferences (including country and language), and methods used to browse away from our content or services and other interests known, observed or inferred;
information from third parties, such as your referees, social media platforms, job boards and other websites. For example, we may receive your business card if you contact us through social media channels, or if you ‘like’ our page on Facebook or ‘follow’ us on Twitter we will receive your personal information from those sites. We may also receive information from our suppliers and partners, such as payment, analytics, advertising, credit reference and other background checking providers;
when we send you emails, we may collect technical email interaction information, such as open rates and if you clicked on any content; and
when you interact with our services, contact or visit us, we may process your image, professional details, relationship history, complaint details and details of your request, communications, opinions or other interaction data.

3. How do we process your personal data and why?

The type of personal data we collect about you will depend on the circumstances and the services you are using.

Generally, we will use your personal data as “controller” to (i) provide our services; (ii) respond to your queries; (iii) develop and promote our organisation and services; (iv) ensure the security and technical availability of our services; and (v) as further described in this notice.

We will update you about any new purposes of processing of your personal data from time to time, and we will obtain your prior consent for such new purposes where we are required to do so at law.

It will be required for you to share information about others, such as your referees, emergency contacts or others within your organisation. You should not provide to us information about others unless you have their permission to do so.

We will likely be unable to assist unless you provide the relevant personal data, and some personal data will be mandatory for our compliance with the law. Nevertheless, you should only provide the necessary personal data to us.

4. Data Accuracy

We and our clients will rely on the information provided by you as accurate, complete and up to date, and we shall be grateful if you would inform us of any changes without delay.

5. What data we collect and why?

5.1 Data about the users of our services

Purpose	Personal Data	Legal ground for processing
To provide our services such as our website, app and platform and features	user details contact details usage data device & browser data	Necessary for our legitimate interest in delivering our services to our users and, where applicable, the performance of our contract with you.
To send you information which you have requested about our services and to send you notifications about matters relevant to your use of our services and your engagement with us, such as events, surveys, changes in our terms, etc.	user details contact details usage data email interaction data	Service notifications are necessary for the performance of our contract with you. Other notifications are necessary for our legitimate interest in satisfying your requests, providing help and guidance and organising related business activities.
To send you promotional information through various marketing channels including email, social media, telephone, sms, push notification, etc. about our services and our organisation, registering and reviewing campaign performance and profiling your information for direct marketing purposes. For example, we may send you our alert or update email or use your contact details to display relevant ads on Facebook or Instagram and other social media platforms.	user details contact details usage data interests known, observed or inferred email interaction data device & browser data	Where you signed up for our services or marketing, we will send you relevant information based on your consent. Where consent is not required, we may send you marketing communications based on our legitimate interest in promoting our business, satisfy your requests, to understand your interests based on the information available to us and to provide you with offers of relevant services. We may use cookies and similar technologies if you provided consent, and combine information with your user details, usage data and interests known, observed or inferred for direct marketing purposes.
We will use anonymised information including role, sex, age, salary and other information to create market survey reports and similar materials for statistical and commercial purposes.	anonymised data market survey data	Necessary for our legitimate interest in understanding the market, informing business decisions, exploring business opportunities and developing and sharing knowledge.
To improve and develop our service functionality, including to: obtain user feedback; conduct statistical analysis on usage data, device & browser and other data; make services and features more relevant; use data to develop algorithms, software and other technologies; improve user experience; and work with third parties and evaluate data to improve and develop our services.	anonymised data	Necessary for our legitimate interest in delivering our services properly, efficiently and improving our business. We will use cookies and similar technologies if you provided your consent.
To ensure proper administration of our business, including to: keep appropriate records; resolve complaints; conduct troubleshooting; manage our business relationships and identify opportunities; register interactions with our communications, such as emails; and debt collection.	user details contact details interaction data usage data device & browser data	Necessary for our legitimate interest in the proper administration of our business, dispute resolution, ensuring technical operation of our services and debt collection and as is necessary for compliance with a legal obligation to which we are subject. We will use cookies and similar technologies if you provided your consent.
To share your information with our third party providers who facilitate the provision of our services and the fulfilment of essential service functions, such as web hosting, cloud storage, analytics, engagement tools, marketing, payment, plugin, communications providers, accounting or security tools and others.	all information necessary to enable the relevant service	Some are necessary for the performance of our contract with you, others are necessary for our legitimate interest in ensuring proper operation of our services.
To monitor our networks, systems and services for suspicious activities, fraud prevention, detection and prevention of crime, testing, audit and deployment of security measures, including information from third parties who may alert us about suspicious activities.	user details usage data device & browser data interaction data	Necessary for our legitimate interest to ensure the security of our organisation, people and services and in detecting and preventing fraud and illegal conduct and as is necessary for compliance with a legal obligation to which we are subject.
To share information within our offices and our group companies.	any necessary information on a proportionate and lawful basis	Necessary for our legitimate interest in using our group’s resources to organise, develop and deliver our services, run our organisation and decide on future strategies.
To share data with a successor or partner legal entity in compliance with the law for the purposes of a joint venture, collaboration, financing, sale, merger, reorganisation or similar event relating to our business.	data necessary in connection with the event	Necessary for our legitimate interest in acting in the best interest of our shareholders and investors and complying with our legal obligations.
To process information as is required for our compliance with the law or to establish, exercise or defend legal claims. To process and share information with other third parties where required by law, such as regulators, law enforcement agencies or where mandatory under a court order.	data necessary in connection with the legal requirement, proceedings or request	Where processing or sharing your data is necessary for compliance with a legal obligation to which we are subject, to establish, exercise or defend legal claims or, where appropriate and proportionate, in order to satisfy our legitimate interest in complying with best practice or applicable laws.

5.2 Data about candidates

Purpose	Personal Data	Legal ground for processing
See above for information processed about a candidate as a user.	As above.	As above.
To provide our recruitment services including collecting your information posted on job boards or provided to us, storing your details in our database, assessing your information to find suitable vacancies, facilitating the recruitment process and providing references about you.	user details contact details application details usage data device & browser data interaction data third party data	Necessary for our legitimate interest in delivering our services to our users and, where applicable, the performance of our contract with you.
To verify information provided by you, including through third party background screening providers.	user details contact details public and social media acoounts data background check data application details data from third parties	Necessary for our legitimate interest in maintaining accuracy of information and good standard of service and for fraud prevention or necessary for compliance with a legal obligation to which we are subject. We will generally seek your consent before engaging third party background checking services.
To keep a record about career needs and progression while you are our user to offer you relevant services. However, we do not engage in automated decision-making that would significantly affect you.	user details contact details usage data device & browser data	Necessary for the performance of our contract with you, where applicable, and as is necessary for our legitimate interest in providing meaningful functionalities and services.
To share information about you with our clients for consideration in connection with vacancies.	contact details application details criminal conviction health data data from third parties	We will generally share your information on the basis of your consent or, where applicable, for the performance of our contract with you.
To assess your career needs and send you notifications about suitable vacancies.	user details contact details usage data device & browser data	Service notifications are necessary for the performance of our contract with you and other notifications are necessary for our legitimate interest in providing meaningful functionalities and services.
To process information as is required for our compliance with the law, such as diversity monitoring.	data necessary in connection with the legal requirement, proceedings or request diversity monitoring data	Where processing or sharing your data is necessary for compliance with a legal obligation to which we are subject, to establish, exercise or defend legal claims or, where appropriate and proportionate, in order to satisfy our legitimate interest in complying with best practice or applicable laws.

5.3 Data about our clients, suppliers, contacts and visitors

Purpose	Personal Data	Legal ground for processing
See above for processing for the administration of our business.	As above.	As above.
To assist and contact you in relation to your enquiry.	contact details interaction data	Necessary for our legitimate interest in responding to queries, maintaining business relationships and administering our business.

6. Sharing your data

We will generally not share your information except with (i) our clients as explained above, (ii) with our third party service providers, commercial partners and group companies for the purposes set out above, (iii) where we are compelled by law, and (iv) other third parties where you have provided your consent.

Although we ask our clients to commit to confidentiality, we cannot be responsible for our clients processing or sharing or your information by other means outside our services.

7. Third parties may process your data

Our services may contain links to other websites, third party services and plugins. You should check the privacy statements of these third party providers before you use them as we are not responsible for how they may process your personal data.

8. How long is your personal data kept?

We will keep your personal data for as long as is necessary for the purposes listed above or longer, as may be required by law. Generally, the retention periods below will apply. You may contact us for further details or request deletion of your personal data at any time.

Category of personal data	Retention period
user details	1 year following account closure
usage data, device & browser data, interaction data	6 years from collection or 1 year following account closure or end of underlying relationship
application data	Generally, 1 month following successful placement, unless otherwise instructed by you. However, basic education and employment history will be retained same as interaction data.
all other personal data	6 years from collection, unless no longer needed.

After the retention period, your personal data will either be securely deleted or anonymised and it may be used for analytical purposes. You must back up your data if you wish to keep it for longer.

9. How we secure your personal data?

We maintain appropriate organisational and technological safeguards to help protect against unauthorised use, access to or accidental loss, alteration or destruction of personal data. We also seek to ensure our service providers do the same.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a personal data breach where required by law.

We will endeavour to use the least amount of personal data as is required for each purpose. We will employ pseudonymisation and anonymisation, where appropriate.

Our staff will access your personal data on a need to know basis.

10. Where is your personal data processed?

We may transfer your personal data to our clients, group companies, suppliers and other third parties in countries different to your country of residence. Generally, our data is held in the United Kingdom.

Where we transfer your personal data outside the European Economic Area (EEA) or the UK, we will only do so, where we are satisfied that your data protection rights are adequately protected by appropriate technical, organisational and contractual safeguards in accordance with data protection laws.

We will transfer your information to clients on the basis of performance of contract, where applicable, or your consent. In respect of other third party recipients, we adopt safeguards such as the standard contractual clauses issued by the European Commission or the Information Commissioner’s Office or similar transfer mechanism.

You may request further information on the measures used for the international transfers or access to your personal data from outside the EEA or the UK.

11. Your right to opt-out

If you would like us to stop sending you marketing communications and to process your personal data for direct marketing purposes, please let us know.

You can stop our communications at any time by clicking on the unsubscribe link at the bottom of the message.

12. Your data protection rights

Subject to certain exemptions, limitations and appropriate proof of identity, you will generally have numerous rights in relation to your personal data, including the following:

Right to information about matters set out in this notice.
Right to make an access request to receive copies of personal data.
Right to rectification of any inaccurate or incomplete personal data.
Right to withdraw consent previously provided.
Right to object to our processing of personal data based on our legitimate interests, and any automated processing and profiling.
Right to erasure of personal data, within limited circumstances.
Restriction on the processing of personal data.
Right to data portability from one service provider to another, where applicable.
Right to lodge a complaint with your country’s data protection authority, such as the Information Commissioner’s Office.

All requests will be processed in a timely manner, generally within one month. If we cannot process your request within this period we shall explain why and process it as soon as possible thereafter.

13. Contact us

Please contact us if you have any queries or concerns about how we use your personal data. You can contact us using the details below. We will try to resolve your query as quickly as we possibly can.

Philippa Smith, Data Protection Representative
The Ministry, 79-81 Borough Rd, London, SE1 1DN
philippa@silverswanrecruitment.com

14. Updates

If we make any changes to our notice you will be able to see them on this page. You should regularly check for updates, as indicated by the “Last updated” date at the top.

If you do not agree to the changes, please do not continue to use our content or services. Of course, if any such changes significantly affect you, we will ask for your prior consent where required by law.