Our Data Policy
Spark Opportunities Ltd is committed to protecting the privacy and security of your personal information.
This privacy notice describes how we collect and use personal information about you during and after your working relationship with us, in accordance with the General Data Protection Regulation of 2018 (GDPR).
It applies to our directors, employees, associates, contractors, candidates and individuals at clients or potential clients of ours.
Spark Opportunities Ltd is a Data Controller. By this, we mean we are responsible for deciding how we hold and use personal information about you. We are required under the new data protection legislation to notify you of the information contained in this privacy notice.
This notice applies to directors, employees, associates, contractors, candidates and individuals at clients or potential clients of ours in respect of whom we hold personal data. This policy does not form part of any contract of employment, a contract to provide services or any other contract. We may update this notice at any time.
It is important that you read this notice, together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal information about you, so that you are aware of how and why we are using such information.
Data Protection Principles
We will comply with data protection law. This says that the personal information we hold about you must be –
1 – Used lawfully, fairly and in a transparent way.
2 – Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
3 – Relevant to the purposes we have told you about and limited only to those purposes.
4 – Accurate and kept up-to-date.
5 – Kept only as long as necessary for the purposes we have told you about.
6 – Kept securely
The kind of information we may collect, hold and process 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).
There are specific categories of more sensitive personal data which require a higher level of protection –
A – Information collected and processed for finding you a suitable role is as follows –
- Your name
- Your address
- Your email address
- Your telephone number
- CV/Work History
- Job preferences including role, location & salary
- Current contract details, for example current salary, annual leave, notice period, benefits/pension information
- Any other relevant work-related information, education and training details, etc.
- Passport or visa or Right to Work permit
- Portrait photographs (occasionally, if a candidate submits this on their CV).
B – Other specific information sometimes requested -
- Date of birth
- Full details of job offers and placements
- Ltd company information (where applicable)
- A log of communications with you by phone and email
This information will have been provided, or will be provided, by you or a third party who we work with, such as a Job Board Company or another employment business or agency. In the case of references, these will be from your previous employers. We may also work with data made publicly available by candidates themselves, posted on such sites as LinkedIn and Campaign Jobs.
We do not currently pay candidates directly so do not hold financial information.
How we use the information
The information listed above is used to provide our services to you in our capacity as an employment agency to find you suitable work whether on a temporary or permanent basis, based on your requirements as set out below.
The information under A above may be used as follows –
- To establish that you have the right to work
- Checking you are legally entitled to work in the UK
- To assess qualifications for a particular job or task
- To prevent fraud
- To match your skills with job vacancies at your request to assist in finding you the best position
- To put forward your details to our clients and prospective clients for you to be considered for employment
- Where we need to comply with a legal obligation
- To place you with our clients and prospective clients
- To keep you informed of available opportunities as they arise
- To keep you informed of the services offered by us
The information under B above may be used as follows –
- To put in place contractual arrangements and documentation once a role has been secured
- To ensure you are paid by your new employer
How we hold the information
All information is held securely on our system which is password protected and security-accredited.
Disclosure of your information
Your CV and related information will be shared or sent to prospective employers. Once you have secured a placement to proceed, personal data shall not be transferred to a country or territory outside the EEA unless that country or territory ensures an adequate level of protection or the appropriate safeguards are in place for your rights and freedoms. Before such a transfer takes place outside of the EEA, we will provide you with further information concerning this.
We do not currently pay candidates directly so do not need to share information with – HM Revenue and Customs, pension scheme providers, legal advisors or other companies in this regard.
We may share your data with third parties as agreed with you in the first instance, including clients and companies who are recruiting. We may also share your information with a very select number of recruiters in our network when they have a job opportunity that may be of interest to you. We have strict rules in this regard –
- Our clients and select recruitment partners are required to take appropriate security measures to protect your personal information in line with our policies.
- We always request your approval before sharing any of your personal data with any clients or recruitment partners
- We may share your personal information when required to by law
- We do not allow our clients and recruitment partners to use your personal data for their own purposes. We only allow them to process your personal data for specified purposes and in accordance with our instructions.
What is the legal basis for processing the information?
We will rely on your consent to process the information as detailed above which is collected at the outset of the recruitment process.
Information and documentation to establish your right to work is processed by us as we are legally obliged to do so.
Once a position has been found for you, we will process your personal data, for the purpose of you entering into a contract to fulfil your role and to ensure you are paid by your employer (if you are a contractor), depending on specific contractual arrangements and circumstances.
If you fail to provide personal information
If you fail to provide certain information when requested, we may not be able to perform the contract we have entered into with you (such as putting you forward for a particular job vacancy).
We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including the purposes of satisfying any legal, accounting or reporting requirements. We will confirm on a 12 monthly basis that you are happy for us to retain your data.
Your duty to inform us of changes
It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your working relationship with us.
Your rights in connection with personal information
You currently have the right at any time to ask for a copy of the information about you that we hold.
Under certain circumstances, by law you have the right to –
- Request access to your personal information
- Request correction of the personal information that we hold about you
- Request erasure of your personal information
- Object to processing of your personal information when there is something you wish to object to. You also have the right to object when we are processing your personal information for direct marketing purposes
- Request the restriction of processing your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
- Request the transfer of your personal information to another party.
If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please write to us. We may need to request specific information from you to help us confirm your identity and ensure your right to access the information. This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.