Privacy Policy

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

You may give your personal details to Forte Recruitment Solutions Ltd 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. Forte Recruitment Solutions Ltd 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 this privacy statement. At all times we will comply with current data protection laws.

Contents

1. Collection and use of personal data

a. Purpose of processing and legal basis

b. Legitimate interest

c. Statutory/contractual requirement

d. Recipients of data

2. Information to be provided when data is not collected directly from the data subject

a. Categories of data

b. Sources of data

3. Overseas transfers

4. Data retention

5. Your rights

6. Automated decision making

7. Cookies

8. Login files

9. Links to external sites

10. Sale of the business

11. Data security

12. Changes to this privacy statement

13. Complaints or queries

1. Collection and use of personal data

a. Purpose of processing and legal basis

Forte Recruitment Solutions Ltd will collect 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.

We must have a legal basis to process your personal data. The legal bases we rely upon to offer our work-finding 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. Legitimate interest

This is where Forte Recruitment Solutions Ltd 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 Forte Recruitment Solutions Ltd has relied on a legitimate interest to process your personal data our legitimate interests is/are as follows:

• Managing our database and keeping work-seeker records up to date;

• Providing work-finding services to you and our clients;

• Contacting you to seek your consent where we need it;

• Giving you information about similar products or services that you have used from us recently;

c. Statutory/contractual requirement

The Forte Recruitment Solutions Ltd has certain legal and contractual requirements to collect personal data (e.g. to comply with the Conduct of Employment Agencies and Employment Businesses Regulations 2003, immigration and tax legislation, and in some circumstances safeguarding requirements.) Our clients may also require this personal data, and/or we may need your data to enter into a contract with you. If you do not give us the personal data we need to collect we may not be able to continue to provide work- finding services to you.

d. Recipient/s of data

Forte Recruitment Solutions Ltd will process your personal data and/or sensitive personal data with the following recipients:

• Clients (whom we may introduce or supply you to)

• Former employers whom we may seek references from

• Payroll service providers who manage payroll on our behalf or other payment intermediaries whom we may introduce you to

• Other recruitment agencies in the supply chain

2. Information to be provided when data collected not from the data subject Categories of data: Forte Recruitment Solutions Ltd has collected the following personal data on you:

Personal data:

• Name, address, mobile no, email

• National insurance no.

• Nationality

• ID

• Work History

Sensitive personal data:

• Health information including whether you have a disability

• Criminal conviction

Source of the personal data: Forte Recruitment Solutions Ltd sourced your personal data/sensitive personal data:

• From Our own website, CV Library & Indeed jobs boards, LinkedIn, Facebook

• A referee whose details you previously provided to us

• Cookies listed in section 7

This information came from a publicly accessible source.

3. Overseas Transfers

Forte Recruitment Solutions Ltd 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.

4. Data retention

Forte Recruitment Solutions Ltd 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. For example, 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. This is currently 3 to 6 years.

Where Forte Recruitment Solutions Ltd has obtained your consent to process your personal and sensitive data, we will do so in line with our retention policy. Upon expiry of that period Forte Recruitment Solutions Ltd will seek further consent from you. Where consent is not granted Forte Recruitment Solutions Ltd will cease to process your personal and sensitive data.

5. Your rights

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

• The right to be informed about the personal data Forte Recruitment Solutions Ltd processes on you;

• The right of access to the personal data Forte Recruitment Solutions Ltd 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 Forte Recruitment Solutions Ltd processing your personal and sensitive data you have the right to withdraw that consent at any time by contacting; Claire O’Connor, Forte Recruitment Solutions Ltd, Devonshire House, Aviary Court, Wade Road, Basingstoke, Hants, RG24 8PE. 01256 975000 info@forte-recruitment.co.uk. Please note that if you withdraw your consent to further processing that does not affect any processing done prior to the withdrawal of that consent, or which is done according to another legal basis.

There may be circumstances where Forte Recruitment Solutions Ltd will still need to process your data for legal or official reasons. Where this is the case, we will tell you and we will restrict the data to only what is necessary for those specific reasons.

If you believe that any of your data that Forte Recruitment Solutions Ltd 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.

6. Cookies

We may obtain data about you from cookies. These are are small text files that are placed on your computer by websites that you visit. They are widely used in order to make websites work, or work more efficiently, as well as to provide information to the owners of the site. Cookies also enable us to deliver more personalised content.

Most web browsers allow some control of most cookies through the browser settings. To find out more about cookies. Please note that in a few cases some of our website features may not function if you remove cookies from your browser.

7. Log Files

We use IP addresses to analyse trends, administer the site, track users’ movements, and to gather broad demographic information for aggregate use. IP addresses are not linked to personally identifiable information.

8. Links to external websites

Forte Recruitment Solutions Ltd website may contains links to other external websites. Please be aware that Forte Recruitment Solutions Ltd is not responsible for the privacy practices of such other sites. When you leave our site we encourage you to read the privacy statements of each and every website that collects personally identifiable information. This privacy statement applies solely to information collected by Forte Recruitment Solutions Ltd's website.

9. Sale of business

If Forte Recruitment Solutions Ltd business is sold or integrated with another business your details may be disclosed to our advisers and any prospective purchasers and their advisers and will be passed on to the new owners of the business.

10. Data Security

Forte Recruitment Solutions Ltd takes every precaution to protect our users’ information. Security measures in place in relation to the personal data processed; firewalls, browser certification technology, encryption, limited access, use of passwords.

Only employees who need the information to perform a specific job (for example, consultants, our accounts clerk or a marketing assistant) are granted access to your information.

Forte Recruitment Solutions Ltd uses all reasonable efforts to safeguard your personal information. However, you should be aware that the use of email/ the Internet is not entirely secure and for this reason Forte Recruitment Solutions Ltd cannot guarantee the security or integrity of any personal information which is transferred from you or to you via email/ the Internet.

If you share a device with others we recommend that you do not select the “remember my details” function when that option is offered.

If you have any questions about the security at our website, you can email Claire O’Connor at info@forte-recruitment.co.uk.

11. Changes to this privacy statement

We will update this privacy statement from time to time. We will post any changes on the statement with revision dates. If we make any material changes, we will notify you.

12. Complaints or queries

If you wish to complain about this privacy notice or any of the procedures set out in it please contact: Claire O’Connor, Forte Recruitment Solutions Ltd, Devonshire House, Aviary Court, Wade Road, Basingstoke, Hants, RG24 8PE. 01256 975000 info@forte-recruitment.co.uk.

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. Our privacy policy will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.

Please read this privacy policy carefully and ensure that you understand it. Your acceptance of this privacy policy is deemed to occur upon your first use of our site. If you do not accept and agree with this privacy policy, you must stop using our site immediately. 

1. IMPORTANT INFORMATION AND WHO WE ARE PURPOSE OF THIS PRIVACY POLICY

This privacy policy aims to give you information on how Forte Recruitment Solutions Ltd collects and processes your personal data through your use of this website, including any data you may provide through this website when you contact us, subscribe, apply for a vacancy, or take part in a competition.

This website is not intended for children and we do not knowingly collect data relating to children. It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.

CONTROLLER

Forte Recruitment Solutions Ltd is the controller and responsible for your personal data (collectively referred to as, “we”, “us” or “our” in this privacy policy).

If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact Forte Recruitment Solutions Ltd using the details set out below.

CONTACT DETAILS

If you have any questions about this privacy policy or our privacy practices, please contact our data privacy manager in the following ways:

FULL NAME OF LEGAL ENTITY: Forte Recruitment Solutions Ltd, 

Company registration: 13010518, registered in England and Wales. 

Postal address: Forte Recruitment Solutions Ltd, Devonshire House, Aviary Court, Wade Road, Basingstoke, Hants, RG24 8PE

Email address: info@forte-recruitment.co.uk 

Telephone number: +44 (0)1256 975000 

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

CHANGES TO THE PRIVACY POLICY AND YOUR DUTY TO INFORM US OF CHANGES

We keep our privacy policy under regular review. This version was last updated Dec 2020. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

THIRD-PARTY LINKS

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

2. THE DATA WE COLLECT ABOUT YOU

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows.

• Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
• Contact Data includes billing address, delivery address, email address and telephone numbers.
• Financial Data includes bank account and payment card details.
• Transaction Data includes details about payments to you.
• Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
• Usage Data includes information about how you use our website, products and services.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

We will be required to collect Special Categories of Personal Data about you (this includes, but is not exclusive too) details about your race or ethnicity, religious or philosophical beliefs, union membership, information about your health, and genetic and biometric data, and criminal convictions and/or offences.

IF YOU FAIL TO PROVIDE PERSONAL DATA

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you. In this case, we may have to cancel role or placement you have with us but we will notify you if this is the case at the time.

3. HOW IS YOUR PERSONAL DATA COLLECTED?

We use different methods to collect data from and about you including through:

• Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by interview, post, phone, email or otherwise. This includes personal data you provide when you: 
  • apply for our services;
  • subscribe to our service or publications;
  • enter a competition, promotion or survey; or 
  • give us feedback or contact us.
• Automated technologies or interactions. We currently utilise Google Analytics which as you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We use this information to create reports and to help us to constantly improve our site.
• Third parties or publicly available sources. We will receive personal data about you from various third parties as set out below.
  • Technical Data from analytics providers such as Google based outside the EU;
  • Referrals from Microsoft or other partners; or
  • Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register based inside the EU.

4. HOW WE USE YOUR PERSONAL DATA

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances.

• Where we need to perform the contract we are about to enter into or have entered into with you
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal obligation.

Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA

We have set out below a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

OPTING OUT

You can ask us or third parties to stop sending you marketing messages at any time by contacting us using the contacts details provided under paragraph 1 at any time.

COOKIES

Our website may place and access certain first-party Cookies on your computer or device. First-party Cookies are those placed directly by us and are used only by us. We use Cookies to facilitate and improve your experience of our website and to provide and improve our services. We have carefully chosen these Cookies and have taken steps to ensure that your privacy and personal data is protected and respected at all times.

By using our website, you may also receive certain third-party Cookies on your computer or device. 

Third-party Cookies are those placed by websites, services, and/or parties other than us. Third-party Cookies are used on our website for collecting data on where videos are being viewed from. For more details, please refer to the table below. These Cookies are not integral to the functioning of our website and your use and experience of our website will not be impaired by refusing consent to them.

All Cookies used by and on our website are used in accordance with current Cookie Law. Certain features of our website depend on Cookies to function. Cookie Law deems these Cookies to be “strictly necessary”. These Cookies are shown in the table below. Your consent will not be sought to place these Cookies, but it is still important that you are aware of them. You may still block these Cookies by changing your internet browser’s settings as detailed below, but please be aware that our website may not work properly if you do so. We have taken great care to ensure that your privacy is not at risk by allowing them.

Our website uses analytics services provided by Google Analytics. Website analytics refers to a set of tools used to collect and analyse anonymous usage information, enabling us to better understand how our website is used. This, in turn, enables us to improve our website and the services offered through it.

The analytics service used by our website use(s) Cookies to gather required information. You do not have to allow us to use these Cookies, however whilst our use of them does not pose any risk to your privacy or your safe use of our website, it does enable us to continually improve our website, making it a better and more useful experience for you. Please see first-party Cookies table above for specific Cookies utilised by the analytics service. 

In addition to the controls that we provide, you can choose to enable or disable Cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all Cookies or only third-party Cookies. By default, most internet browsers accept Cookies, but this can be changed. For further details, please consult the help menu in your internet browser or the documentation that came with your device. 

You can choose to delete Cookies on your computer or device at any time, however you may lose any information that enables you to access Our Site more quickly and efficiently including, but not limited to, login and personalisation settings.

It is recommended that you keep your internet browser and operating system up-to-date and that you consult the help and guidance provided by the developer of your internet browser and manufacturer of your computer or device if you are unsure about adjusting your privacy settings.

CHANGE OF PURPOSE

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact Forte Recruitment Solutions Ltd using the details provided under paragraph 1.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

5. DISCLOSURES OF YOUR PERSONAL DATA

We may share your personal data with the parties set out below, for the purposes set out in in this policy, for which we will use your personal data above.

• Internal Third Parties as set out in the Glossary.
• External Third Parties as set out in the Glossary.
• Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

6. INTERNATIONAL TRANSFERS

We do not transfer your personal data outside the European Economic Area (EEA).

7. DATA SECURITY

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

8. DATA RETENTION

HOW LONG WILL YOU USE MY PERSONAL DATA FOR?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.

In some circumstances you can ask us to delete your data: see your legal rights below for further information.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

9. YOUR LEGAL RIGHTS

Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please see glossary for further guidance.

• Request access to your personal data.
• Request correction of your personal data.
• Request erasure of your personal data.
• Object to processing of your personal data.
• Request restriction of processing your personal data.
• Request transfer of your personal data.
• Right to withdraw consent.

If you wish to exercise any of the rights set out above, please contact us.

NO FEE USUALLY REQUIRED

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

WHAT WE MAY NEED FROM YOU

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

TIME LIMIT TO RESPOND

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

10. GLOSSARY

LAWFUL BASIS

• Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us under paragraph 1.
• Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
• Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

11. THIRD PARTIES

INTERNAL THIRD PARTIES

Other companies in Forte Recruitment Solutions Ltd Group acting as joint controllers or processors and who are based in the European Economic Area (EEA).

EXTERNAL THIRD PARTIES

• Hiring company, firm or corporate body to whom Forte Recruitment Solutions Ltd is providing recruitment services.
• Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the EEA who provide consultancy, banking, legal, insurance and accounting services.
• HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.

YOUR LEGAL RIGHTS

• Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it. 
• Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us. 
• Request erasure of your personal data. This enables you to ask us to delete or  remove personal data 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 data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request. 
• Object to processing of your personal data 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 as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms. 
• Request restriction of  processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios.
  • If you want us to establish the data’s accuracy.
  • Where our use of the data is unlawful but you do not want us to erase it.
  • Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
  • You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
• Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you. 
• Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw  your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.