Updated: April 2018
Thomson Legal Recruitment Company Limited is committed to protecting and respecting your privacy. This policy sets out the basis on which any data we collect from you (or that you provide directly to us) will be processed.
In this policy the following terms have the following meanings:
Data Protection Principles Explained
The Data Protection Laws require Thomson Legal Recruitment Company acting as either data controller or data processor to process data in accordance with the principles of data protection under GDPR. These require that personal data is:
All organisations that process personal data are required to comply with data protection legislation. This includes in particular the Data Protection Act 1998 (or its successor) and the EU General Data Protection Regulation (together the ‘Data Protection Laws’). The Data Protection Laws give individuals (known as ‘data subjects’) certain rights over their personal data whilst imposing certain obligations on the organisations that process their data.
The General Data Protection Regulation (GDPR) (Regulation (EU) 2016/679) replaces the Data Protection Regulation (Directive 95/46/EC) The Regulation covers data protection legislation across the EU and priorities privacy rights for individuals via a strict framework.
About Thomson Legal Recruitment Company Limited
Thomson Legal Recruitment Company Limited (company registration SC483816) is a specialist legal recruitment agency/business as defined in the Employment Agencies and Employment Businesses Regulations 2003. We are a data controller for the purposes of the Data Protection Laws. Thomson Legal Recruitment Company Limited takes privacy very seriously and we are registered with the Information Commissioner’s Office.
We collect personal data of the following types of individuals to allow us to undertake our core recruitment business activities.
Information We Collect on You
We collect data that you have provided us via correspondence with us. This may be by telephone, email, social media or registering/ signing up for our newsletter on our website: www.thomsonlrc.com.
This information you provide to us or we collect about you may include:
When you visit our website we automatically collect the following information:
Information Obtained from Other Sources
This is information we obtain about you from other sources such as social media websites such as LinkedIn, corporate websites, job board websites, online CV libraries, your business card, presentations and recommendations. In this case we will inform you, by sending you this privacy notice, within a month of collecting the data of the fact we hold personal data about you, the source the personal data originates from and whether it came from publicly accessible sources, and for what purpose we intend to retain and process your personal data.
Thomson Legal Recruitment Company Limited has implemented measures with the aim of adequately protect the privacy of individuals and ensures that data protection is integral to all processing activities. This includes:
Purposes of the Processing/ Legal Basis for the Processing
The core service we offer to our candidates and clients is the introduction of candidates to our clients for the purpose of permanent or fixed-term recruitment engagement. However, our services also include advising on strategy, advising candidates on career development and providing up to date and relevant market information (such as remuneration, rankings and structure) on the legal sector to both candidates and clients.
Our legal basis for the processing of personal data is our legitimate business interests, described in more detail below. However, we will also rely on contract, legal obligation and consent for specific uses of data as detailed below:
We will rely on contract if we are negotiating or have entered into a placement agreement with you or your organisation or any other contract to provide services to you or receive services from you or your organisation.
We will rely on legal obligation if we are legally requires to hold information on to you to fulfil our legal obligations.
We will in some circumstances rely on consent for particular uses of your data and you will be asked for your express consent, if legally required. Consent may be the lawful basis for processing when we request your permission as a candidate to introduce you to a client.
Legitimate Business Interests
As a legal recruitment agency or core business function is introducing candidates to clients for permanent or fixed-term employment. The exchange of personal data (such as your CV or your profile) of our candidates and our client contacts is a fundamental, essential part of our process and services.
Should we want or need to rely on consent to lawfully process your data we will request your consent orally, by email or by an online process for the specific activity we require consent for and record your response on our system. Where consent is the lawful basis for our processing you have the right to withdraw your consent to this particular processing at any time.
Other Uses we will Make of Your Data:
Disclosure of Your Information Inside and Outside of the EEA
As part of our core recruitment business function we may disclose your information to selected third parties which may include:
The lawful basis for the third-party processing will include:
Where we Store and Process Your Personal Data
All information you provide to us is stored on our secure servers. Where we have given you (or where you have chosen) a password which enables you to access our candidate portal, you are responsible for keeping this password confidential.
Thomson Legal Recruitment Company Limited aims to always protect your personal data, however we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
Retention of Your Data
We understand our legal duty to retain accurate data and only retain personal data for as long as we need it for our legitimate business interests and that you are happy for us to do so. Accordingly, we have a data retention notice and run data routines to remove data that we no longer have a legitimate business interest in maintaining.
We do the following to try to ensure our data is accurate:
The criteria we use to determine whether we should retain your personal data includes:
We may archive part or all of your personal data or retain it on our financial systems only, deleting all or part of it from our main Customer Relationship Manager (CRM) system. We may pseudonymise parts of your data, particularly following a request for suppression or deletion of your data, to ensure that we do not re-enter your personal data on to our database, unless requested to do so. For your information, Pseudonymised Data is created by taking identifying fields within a database and replacing them with artificial identifiers, or pseudonyms. Our current retention notice is available upon request.
Thomson Legal Recruitment Company do not subject individuals to decisions based on automated processing that produce a legal effect or a similarly significant effect on the individual, except where the automated decision:
Thomson Legal Recruitment Company Limited use recruitment software to search and identify personal data in accordance with parameters set by a person. A person will always be involved in the decision-making process and we do not use automated selection tools.
You have the right to ask us not to process your personal data for marketing purposes. We will usually inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes and we will collect express consent from you if legally required prior to using your personal data for marketing purposes.
You can exercise your right to accept or prevent such processing by checking certain boxes on the registration forms we use to collect your data. You can also exercise the right at any time by contacting us at: email@example.com calling us on +44 (0) 141 244 0260 or +353 (0) 1 699 1360.
Our site may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
GDPR provides you with the following rights:
If Thomson Legal Recruitment Company Limited has given the personal data to any third parties it will inform those third parties that it has received a request to erase the personal data unless this proves impossible or involves disproportionate effort. Those third parties should also rectify the personal data they hold - however we will not be in a position to audit those third parties to ensure compliance.
All data breaches should be referred to Mary Ann Thomson, Director & Data Protection Officer (firstname.lastname@example.org)
Data breaches where Thomson Legal Recruitment Company is acting as the data controller:
Data breaches where Thomson Legal Recruitment Company Limited is the data processor:
Thomson Legal Recruitment Company Limited will not be required to tell individuals about the personal data breach in circumstances where:
The Human Rights Act 1998
All individuals have the following rights under the Human Rights Act 1998 and in dealing with personal data these should be respected at all times:
To make a complaint to Thomson Legal Recruitment Company Limited you may contact the Data Protection Officer: Mary Ann Thomson, Director and DPO: Telephone +44 (0) 141 244 0260 or email: email@example.com. You can also make a complaint to a supervisory body which in the United Kingdom is the Information Commissioner’s Office. The ICO can be contacted through this link: https://ico.org.uk/concerns/or alternatively you can contact them on: +44 0303 123 1113.
It is Thomson Legal Recruitment Company Limited’s intention to act upon any subject access request or a request relating to rectification, erasure, restriction, data portability or objection or automated decision-making processes or profiling within one month of receipt of the request. We may opt extend this by a reasonable period where necessary, taking into account the investigation complexity and the volume of requests. Where we consider that a request under this section is of an unfounded or excessive nature, we may choose to refuse to act on the request or to charge a reasonable fee taking into account relevant administrative costs involved.
Access to Information
The Data Protection Act 1998 and the GDPR give you the right to access information held about you. A subject access request should be submitted to firstname.lastname@example.org.
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