1. Collection and use of personal data
a. Purpose of processing and legal basis
Harrison Holgate will collect your personal data (which may include special categories and 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.
If you have opted-in we may also send you marketing information and news via email/text. You can opt-out from receiving these at any time by clicking “unsubscribe” when you receive these communications from us.
On some occasions 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.
The legal bases we rely upon to offer these services to you are:
- Your consent
- Where we have a legitimate interest
- To comply with a legal obligation that we have with you
- To fulfil a contractual obligation that we have with you
b. Legitimate interest
This is where the Company 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 Harrison Holgate has relied on a legitimate interest to process your personal data, our legitimate interests is as follows:
- Managing our database and keeping work-seeker records up to date;
- Providing work finding services to both candidates and clients;
- Contacting you to seek your consent where we need it;
- Giving you information about similar services to those that you will have used from us recently;
c. Statutory/contractual requirements
Harrison Holgate 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 require this personal data, and 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 In order to comply with our statutory and legal requirements, we may not be able to continue to provide work-finding services to you.
d. Recipients of data
Harrison Holgate will process your personal data and/or sensitive personal data with the following recipients:
- Our clients;
- Your former employers who we may seek references from
- Psychometric/skills testing providers, as required for certain roles;
- HMRC;
- Umbrella companies providing payroll services in respect of temporary workers only;
- The Company’s accountant for the purposes of financial accounting;
- The Company’s recruitment software provider.
e. Categories of data
Harrison Holgate collects personal data from you which includes (but is not limited to):
- Name, address mobile number and email address
- Work and education history
- References
- National insurance no.
- Nationality (through right to work check)
Special categories of personal data:
- Health information including whether you have a disability (if you require reasonable adjustments to be made in respect of an application for a role).
2. Overseas Transfers
Harrison Holgate may transfer only the information you provide to us to countries outside the European Economic Area (‘EEA’) for the purposes of providing you with work-finding services. We will take steps to ensure adequate protections are in place to ensure the security of your information. The EEA comprises the EU member states plus Norway, Iceland and Liechtenstein.
3. Data retention
Harrison Holgate will retain your personal data only for as long as is necessary. Different laws require us to keep different data for different periods of time.
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 are required to keep your records relating to the right to work in the UK 2 years after employment or the engagement has ended alterable and working time records including your 48 hour opt out notice annual leave/holiday records 2 years from the time they were created.
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 Harrison Holgate has obtained your consent to process your personal/special categories of personal data, we will do so in line with our retention policy. Upon expiry of that period Harrison Holgate will seek further consent from you. Where consent is not granted Harrison Holgate will cease to process your personal data/sensitive personal data.
Given the nature of recruitment we will likely need to store specific data for certain time periods for the purposes of the Conduct Regulations and tax legislation etc.
4. Your rights
Please be aware that you have the following data protection rights:
- The right to be informed about the personal data the Company processes on you;
- The right of access to the personal data the Company 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 Harrison Holgate processing your personal/sensitive data you have the right to withdraw that consent at any time by contacting Marie Heddle on 020 7702 0200 (mheddle@harrisonholgate.com). 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 the Company 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 the purpose of meeting those specific reasons.
If you believe that any of your data that the Company 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.
5. Complaints or queries
If you wish to complain about this privacy notice or any of the procedures set out in it please contact: Matthew Waters on 020 7702 0200 (mwaters@harrisonholgate.com).
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
This website is owned and operated by The Holgate Partnership Ltd
We are registered in England and Wales under registration number 7440848, and our registered office is at 457 Southchurch Road, Southend-on-Sea, Essex, SS1 2PH
Our principal place of business is at 34 Lime Street, London, EC3M 7AT
You can contact us:
- By post, to [the postal address given above];
- Using our website contact form;
- By telephone, on the contact number published on our website;
Data protection officer
Our data protection officer’s contact details are: Matthew Waters, 020 7702 0200.
Last updated: January 2023
Version: 2
