Privacy Policy

This Privacy Policy is brought to the attention of individuals who submit information about themselves, usually in the form of CVs, in order to promote themselves to employers and attract possible job offers.

SECTION 1: CANDIDATES

This section applies to individuals wishing to use our Recruitment Services or our training services. The personal data we collect or receive may include the following:

Name
Address
Email and other contact details
Date of birth
Job history (including information relating to placements through us)
Educational history, qualifications & skills
Visa and other right to work or identity information
Passport
Bank details
National insurance and tax (payroll) information
Next of kin and family details
Contact details of referees
Personal information relating to hobbies, interests and pastimes
Information contained in references and pre-employment checks from third parties
Other sensitive personal information such as health records (see "Sensitive Personal Data" section below)
Your marketing preferences

We may obtain your personal data from the following sources (please note that this list is not exhaustive):

You (e.g. a Curriculum Vitae, application or registration form)
A client
Other candidates
Online jobsites
Marketing databases
The public domain
Social Media
At interview
During the provision of training
Conversations on the telephone or video conferencing (which may be recorded)
Notes following a conversation or meeting
Our websites and software applications

Where you are a Candidate and we have obtained your personal data from a third party such as an online job board, it is our policy to advise you of the source when we first communicate with you.

How we will use your personal data:

The processing of your personal information may include:

Collecting and storing your personal data, whether in manual or electronic files
Notifying you of potential roles or opportunities
Assessing and reviewing your suitability for job roles
Introducing you to actual or potential Clients
Updating you on your progress with training
Collating market or sector specific information and providing the same to our Clients
Sending information to third parties with whom we have or intend to enter into arrangements which are related to our Recruitment Services or training provision
Providing information to regulatory authorities or statutory bodies, and our legal or other professional advisers including insurers
To market our Recruitment or Training Services
Retaining a record of our dealings
Establishing quality, training and compliance with our obligations and best practice
For the purposes of backing up information on our computer systems

Why we process your personal data:

In order to provide our Recruitment and/or Training Services we may need certain information, for example your name, address, contact details, qualifications, proof of ID. Provision of our services may also contain obligations on both your part and our part and we shall process your data as is necessary for the purpose of those obligations. For example, in order to process payroll, a national insurance number and bank details will be required.

Compliance with legal obligations (regulatory and statutory obligations):

We must comply with a number of statutory provisions when providing our Recruitment and Training Services, which necessitate the processing of personal data. These include the Conduct of Employment Agencies and Employment Businesses Regulations 2003, which amongst other things requires us to:

Verify your identity
Assess your suitability for an external job role
Maintain records for specific periods

We are also required to comply with statutory and regulatory obligations relating to business generally, for example complying with tax, bribery, fraud/crime prevention and data protection legislation, and co-operating with regulatory authorities.

Our legitimate interests (carrying on the commercial activity of Recruitment and Training Services):

In providing our Recruitment and Training Services, we will carry out some processing of personal data which is necessary for the purpose of our legitimate interests, which include:

Retaining records of our dealings and transactions and where applicable, use such records for the purposes of:
- Establishing compliance with contractual obligations with Clients or suppliers
- Addressing any query or dispute that may arise including establishing, exercising or defending any legal claims
- Protecting our reputation
- Maintaining a backup of our system, solely for the purpose of being able to restore the system to a particular point in the event of a system failure or security breach
- Evaluating quality and compliance including compliance with this Privacy Notice
- Determining staff training and system requirements
- Assessing suitability and contacting you regarding potential opportunities and/or our services
- Collating market information or trends including providing analysis to potential or actual Clients
- Sourcing potential opportunities or roles as part of our Recruitment Services
- Delivering training resources as part of our Training Service
- Personalizing your experience and our offering, whether via our website or otherwise

This means that for our commercial viability and to pursue these legitimate interests, we may continue to process your personal data for as long as we consider necessary for these purposes.

Consent and Data Processing

We may process your personal data on the basis that you have consented to us doing so for a specific purpose, for example, if you apply for a specific role you may have consented to our processing of the data that has been provided for the purpose of progressing your application and considering your suitability for that role. In other cases, you may have provided your written or verbal consent to the use of your data for a specific reason.

You may withdraw your consent to our processing of your personal information for a particular purpose at any stage. However, please note that we may continue to retain, or otherwise use your personal information thereafter where we have a legitimate interest or a legal or contractual obligation to do so. Our processing in that respect will be limited to what is necessary in furtherance of those interests or obligations. Withdrawal of consent will not have any effect on the lawfulness of any processing based on consent before its withdrawal.

Obtaining Personal Data from Third Parties

Part of our business activity involves researching information relating to individuals for the purposes of filling job roles. This may include obtaining personal data from online sources, for example, we may obtain information from social media sites such as LinkedIn and job boards, some information being publicly available but others being from sites or providers to which we subscribe. From time to time, we may also receive personal information about you from hiring organizations, colleagues and former employers, or from persons for whom you have provided services or been otherwise engaged.

Where information from third-party sources is of no use to us, or where you have notified us that you do not want us to provide you with services, we shall discard it. However, we may maintain a limited record in order to avoid the duplication of the process. Where we consider that information may be of use to us in pursuance of the provision of our Recruitment Services, any processing will be in accordance with this Privacy Notice. You do have the right to object to processing, please see Section 4 ‘Your rights’.

Sensitive Personal Data (SPD)

Sensitive personal data is information which is intensely personal to you and is usually irrelevant to our consideration of your suitability for a job role. Examples of SPD include information which reveals your political, religious or philosophical beliefs, sexual orientation, race or ethnic origin, or information relating to your health.

Regardless of the basis for your dealings with us, we request that you do not provide us with any sensitive personal data unless absolutely necessary. However, to the extent that you do provide us with any sensitive personal data, such as data which you choose to share with us in conversation, we shall only use that data for the purposes of our relationship with you or for the provision of our Recruitment Services. This will be for one or more of the following reasons:

You have explicitly consented to the processing
For the purpose of our assessment of your suitability for job roles or working capacity
Where processing is necessary for the purpose of obligations or rights under employment, social security or social protection law
To maintain records of our dealings to address any later dispute, including but not limited to the establishment, exercise or defense of any legal claims

Sharing Personal Data

We shall not share your personal information unless we are entitled to do so. The categories of persons with whom we may share your personal information include:

Individuals, hirers and other third parties necessary for the provision of our Recruitment Services
Individuals, mentors, tutors, coaches, and other third parties necessary for the provision of our Training Services
Any regulatory authority or statutory body pursuant to a request for information or any legal obligation which applies to us
Parties who process data on our behalf, which may include:

IT support
Storage service providers including cloud
Legal and professional advisers
Insurers

Automated Decisions

We do not use any automated decision-making software. Where we use software to assist us with our assessment of your suitability for a particular job role and you consider that any such assessment has been made wrongly or incorrectly, you may ask for an explanation.

SECTION 2: CLIENTS

This section applies where you are an individual working for a third party with whom we have dealings. For example, a hiring client or training client.

We may collect your personal data in the course of our dealings and this may include the following:

Your contact information, which may include your full name, job role, contact telephone number, and email
Your statements and opinions about candidates and/or delegates e.g. a reference
Information relating to our relationship with you or the party for whom you work, including records of any meetings or discussions
Your marketing preferences

We may obtain your personal data from the following sources (please note that this list is not exhaustive):

You, including where you have provided us with your contact details or other information for the purposes of using our Recruitment or Training Services
Staff or other representatives of the organization you represent
Candidates or Delegates
Marketing databases
Social media
The public domain
Conversations, with you or others, on the telephone or video conferencing (which may be recorded) or in meetings
Notes following a conversation, with you or others, or meetings you attend

How We Will Use Your Personal Data

We will process your personal data in the context of our dealings with the third party for whom you work and as part of our Recruitment and Training Services. Processing may include:

Collecting and storing your personal data, whether in manual or electronic files
Using the data to communicate with you
Sending information to third parties with whom we have or intend to enter into arrangements which are related to our Recruitment and Training Services
Actions necessary to further any obligation on us pursuant to a contract between ourselves and the third party you work for
Collating market or sector-specific information and providing the same to our clients
Providing information to regulatory authorities or statutory bodies and our legal or other professional advisers including insurers
Retaining records of our dealings with you and the organization whom you represent
Establishing quality, training and compliance with our obligations and best practice

Why We Process Your Personal Data

We process your personal data for the following reasons:

Compliance with legal obligations (regulatory and statutory obligations): We must comply with a number of statutory provisions when providing our Recruitment and Training Services, which necessitate the processing of personal data. These include the Conduct of Employment Agencies and Employment Businesses Regulations 2003, which, amongst other things, require us to assess the suitability of candidates and obtain information from clients. We are also required to comply with statutory and regulatory obligations relating to business generally, for example, tax, bribery and fraud/crime prevention legislation, and cooperating with regulatory authorities such as HMRC.
Our legitimate interests (carrying on the commercial activity of a Recruitment and Training Provider):In providing our Recruitment and Training Services, we will carry out some processing of personal data which is necessary for the purpose of our legitimate interests, which include using your personal data to:

Contact you regarding our Recruitment and Training Services
Assess suitability of candidates, delegates, and roles, for example, referencing or other feedback
Collate market information or trends, including providing analysis to potential or actual clients
Provide our Recruitment and Training Services and/or meet our obligations towards the party you represent, or other clients or suppliers
Personalize your experience and our offering, whether via our website or otherwise
Retain records of our dealings and transactions and, where applicable, use such records for the purposes of:
- Establishing compliance with contractual obligations with clients or suppliers
- Addressing any query or dispute that may arise, including establishing, exercising, or defending any legal claims
- Protecting our reputation
- Maintaining a backup of our system, solely for the purpose of being able to restore the system to a particular point in the event of a system failure or security breach
- Evaluating quality and compliance, including compliance with this Privacy Notice
- Determining staff training and system requirements

For our commercial viability and to pursue these legitimate interests, we may continue to process your personal information for as long as we consider reasonably appropriate for these purposes.

Consent

We may process your personal data on the basis that you have consented to us doing so for a specific purpose, for example, if you have provided your contact details in order for us to provide you with details of our services, you may have consented to the processing of the data for that purpose. In other cases, you may have provided your written or verbal consent to the use of your data for a specific reason, such as references.

You may withdraw your consent to our processing of your personal data for a particular purpose at any stage. However, please note that we may continue to retain or otherwise use your personal information thereafter where we have a legitimate interest or a legal or contractual obligation to do so. Our processing in that respect will be limited to what is necessary in furtherance of those interests or obligations. Withdrawal of consent will not have any effect on the lawfulness of any processing based on consent before its withdrawal.

Third Party Data

Part of our business activity involves researching information for the purposes of finding new clients and opportunities. This may include obtaining personal data from sources including job boards, advertisements, LinkedIn, or other social media. Some information may be publicly available, while others may come from sites or providers to which we subscribe. From time to time, we may also receive personal data about you from hiring organizations, colleagues, former employers, or persons for whom you have provided services or been otherwise engaged.

Where information from third-party sources is of no use to us, we shall discard it. However, we may maintain a limited record to avoid duplication of the process. If we consider that information may be of use to us in the provision of our Recruitment and Training Services, any processing will be in accordance with this Privacy Notice. You have the right to object to processing; please see Section 4 "Your Rights".

Sensitive Personal Data (SPD)

Sensitive personal data is intensely personal to you and is usually irrelevant to our dealings with you in respect of our Recruitment Services. Examples of SPD include information that reveals your political, religious, or philosophical beliefs, sexual orientation, race or ethnic origin, or information relating to your health.

Regardless of the basis for your dealings with us, we request that you do not provide us with any sensitive personal data unless absolutely necessary. However, to the extent that you do provide us with any sensitive personal data, such as data shared with us in conversation, we shall only use that personal data for the purposes of our relationship with you or for the provision of our Recruitment and Training Services. This will be for one or more of the following reasons:

You have explicitly consented to the processing
Processing is necessary for the purpose of obligations or rights under employment, social security, or social protection law
To maintain records of our dealings to address any later dispute, including but not limited to the establishment, exercise, or defense of any legal claims

Sharing Personal Data

We shall not share your personal data unless we are entitled to do so. The categories of persons with whom we may share your personal information include:

Candidates, Delegates, and other third parties necessary for the provision of our Recruitment and Training Services
Any regulatory authority or statutory body pursuant to a request for information or any legal obligation which applies to us
Parties who process data on our behalf, which may include:
- IT support
- Storage service providers including cloud providers
- Legal and professional advisers
- Insurers

SECTION 3: THIS SECTION APPLIES TO ALL PERSONAL DATA

Transfer of Data to Other Jurisdictions

In the course of the provision of our Recruitment and Training Services, we may transfer data to countries or international organizations outside of the EEA. This may include transferring data to Clients, Candidates, or third parties who provide support services to us. Where information is to be transferred, it may be to a country with an adequacy decision from the EU Commission. However, if this is not the case, it is our policy to take steps to identify risks and, as far as reasonably practicable, ensure that appropriate safeguards are in place. Details relating to specific countries or organizations are available on request from the Data Protection Officer.

Data Provision

There may be circumstances where we require you to provide data that is necessary for us to meet statutory or contractual obligations or perform our Recruitment and Training Services. If you do not wish to provide us with the requested information, please notify us. However, please be aware that as a result, we may be unable to provide you or the party you represent with a Recruitment and Training Service, and in some cases, it may result in a breach of the contract we have with you or a third party you represent.

Group Companies and Transfer

In the event of a sale, merger, liquidation, receivership, or the transfer of all or part of our assets to a third party, we may need to transfer your information to that third party. Any transfer will be subject to the agreement of the third party to this Privacy Notice, and any processing will be carried out in accordance with this Privacy Notice.

Data Security and Confidentiality

It is our policy to ensure, as far as reasonably practicable, that our systems and records are secure and not accessible to unauthorized third parties in line with contemporary practice.

Cookies

A cookie is a small file of letters and numbers that is downloaded onto your computer when you visit a website, enabling the website to tailor its offerings to your preferences when you visit it.

We use cookies to help us deliver a high-quality recruitment and training service and to track browsing behavior on our sites.

Data Retention

In most circumstances, your data will not be retained for more than 5 years from the last point at which we provided any services or otherwise engaged with you. It is our policy to only store your personal data for as long as reasonably necessary to comply with our legal obligations and for our legitimate business interests. However, we may retain data for longer than a 5-year period where we have a legal or contractual obligation to do so or if there is a legitimate interest, such as when your personal information identifies specialist skill sets that may remain in demand, or when we are subject to a longer legal obligation.

If you believe that we should delete your personal data at an earlier date, please inform us in writing, stating your reasons. Please see Section 4 "Your Rights" below.

Changes to this Privacy Notice

This Privacy Notice is regularly reviewed and may be updated from time to time to reflect changes in our business, legal, or commercial practice.

SECTION 4: YOUR RIGHTS

We take the protection of your personal data very seriously, and it is important that you know your rights within that context. These rights include:

Requesting a copy of the personal data that we hold
Objecting to our processing of your data where that processing is based on legitimate interest and there are no compelling grounds for the continued processing
Requesting that we restrict the processing of your data in certain circumstances
Requesting the erasure of your data where the continued use of that data cannot be justified
Objecting to any decision that significantly affects you and is taken solely by automated means
Withdrawing your consent to our processing of your personal data for a particular purpose at any stage. However, please note that we may continue to retain or otherwise use your personal information thereafter if we have a legitimate interest or a legal or contractual obligation to do so. Our processing in that respect will be limited to what is necessary in furtherance of those interests or obligations
Requesting the rectification of inaccurate or incomplete data
Requesting the transfer of data provided directly by you and processed by automated means to you or another controller. This right is applicable only when our processing of your data is based on your consent or in performance of a contract
Making a complaint to the Information Commissioner's Office
Requesting that direct marketing by us to you is stopped

Please note that if you exercise your right to request the erasure of data or cease any processing activity, we may retain a record of this request and the action taken to evidence our compliance and to minimize the prospect of any data being processed in the future should it be received again from a third-party source.

If you have any questions concerning your rights or wish to exercise any of these rights, please contact us at hello@osg.llc.

Complaints

If you are not happy with our privacy policy or have any complaints, please inform us by email. Our address is hello@osg.llc.

If a dispute is not settled, then we hope you will agree to attempt to resolve it by engaging in good faith with us in a process of mediation or arbitration.