Kingpin International Privacy Notice
Kingpin International Limited (Kingpin International) (“We”) are committed to protecting and respecting your privacy.
Our Group means our subsidiaries, our ultimate holding company and its subsidiaries, our associated companies as defined in section 1159 of the UK Companies Act 2006 (our Group).
This notice (together with our Terms and Conditions document and any other documents referred to on them) sets out the basis on which any personal data that you provide to us, will be processed by us.
What is covered by this policy?
Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.
For the purpose of the General Data Protection Regulation (GDPR) 2016/679, the data controller is Kingpin International, a company incorporated in Scotland (company number SC289486) and who can be contacted at the Head Office address, 6 New Street, Paisley, PA1 1XY, Scotland or by telephone 0141 887 1155.
Who we are and what we do
We are a recruitment agency and recruitment business as defined in the Employment Agencies and Employment Businesses Regulations 2003 (our business). We also provide the following other services training, outsourcing, consultancy. We collect the personal data of the following types of people to allow us to undertake our business;
- Prospective and placed candidates for permanent roles;
- Prospective and live client contacts;
- Supplier contacts to support our services;
- Employees, consultants;
We collect information about you to carry out our core business and ancillary activities.
Information you give to us or we collect about you.
This is information about you that you give us by filling in forms on our site www.kingpininternational.com (our site) or by corresponding with us by phone, e-mail or otherwise. It includes information you provide when you register to use our site, to enter our database, subscribe to our services, attend our events, participate in discussion boards or other social media functions on our site, enter a competition, promotion or survey and when you report a problem with our site.
The information you give us or we collect about you may include your name, address, private and corporate e-mail address and phone number, financial information, compliance documentation and references verifying your qualifications and experience and your right to work in the United Kingdom, curriculum vitae and photograph, links to your professional profiles available in the public domain e.g. LinkedIn, Xing, Twitter, business Facebook, Google Plus, corporate websites, job board websites and online CV libraries.
Candidates: the information we collect and how we use it.
To enable us to assist you in finding an appropriate job, we will gather personal information about you from your CV and our registration process. This includes, but is not limited to:
- Your name;
- Your contact details including your personal email address;
- Your career history;
- On occasions we may also record sensitive information such as details of unspent convictions;
We hold and use this information in order to:
- Assist you in finding an appropriate job;
- Communicate with you regarding job opportunities and the progress of any applications you make;
- To provide your details to appropriate prospective employers. We will only share your information with named prospective employers with your permission;
- Provide you with help and advice to assist in your job search;
- Provide you with information about general trends in the world of work;
- Seek your feedback on our services;
- Fulfil our obligations to our clients when you are offered employment;
You have the right to withdraw your consent or amend your communications preferences at any time. You can request access to your details by contacting the Head Office address, 6 New Street, Paisley, PA1 1XY or emailing email@example.com.
We may share your personal information with the following:
- Other Kingpin International offices, including those outside the European Union (EU) and the European Economic Area (EEA), when you tell us you would like to be considered for jobs in other countries
- Regulatory or law enforcement agencies, when required by law to do so.
- We do not share your personal information with third parties who wish to use it for marketing purposes.
Clients: the information we collect and how we use it.
When you ask us to work with you we will record information about you, including but not limited to:
- Your name;
- Your job title;
- Your business contact information including your business email address;
- Your mobile telephone number
- Your occupation;
We hold and use this information in order to:
- Provide the service you have asked us to provide;
- Provide you with reports on the work we are undertaking on your behalf;
- Advise you of relevant services and products;
- Provide you with information about general trends in the world of work;
- Seek your feedback on our services;
You have the right to amend your communications preferences at any time. You can request access to your details here;
Head Office address, 6 New Street, Paisley, PA1 1XY or emailing firstname.lastname@example.org.
Information we collect about you when you visit our website.
With regard to each of your visits to our site we will automatically collect the following information:
- technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information if applicable, browser type and version, browser plug-in types and versions, operating system and platform;
- information about your visit, including the full Uniform Resource Locators (URL), clickstream to, through and from our site (including date and time), products you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page and any phone number used to call our customer service number.
It is possible to switch off cookies by setting your browser preferences. For more information on how to switch off cookies on your computer, visit our full cookies policy. Turning cookies off may result in a loss of functionality when using our website.
Information we obtain from other sources.
This is information we obtain about you from other sources such as business Facebook, Twitter, LinkedIn, Xing and Google Plus, corporate websites, job board websites, online CV libraries, your business card and personal recommendations. In this case we direct you to our privacy notice and always inform you 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.
We are working closely with third parties including companies within our Group, business partners, sub-contractors in technical, professional, payment and other services, advertising networks, analytics providers, search information providers, credit reference agencies and professional advisors. We may receive information about you from them for the purposes of our recruitment services and ancillary support services.
When you fill out a web-form to apply for a job, register with us, sign up to newsletters, we may ask you to provide certain personal information, including your:
- Email address
- Telephone number
By completing the form and ticking the relevant boxes you are providing your consent for Kingpin International to process your personal data, and this is the legal basis we are relying on to do so.
We will use the information that you give us to send you relevant emails containing Kingpin International news & marketing communications. Your information will be stored by a third party data processor; Mercurytide, whose servers are located in the UK, you can read their privacy information: here.
In addition, if you have enquired about a product or service we will use the information you have given to update our customer relationship management system so one of our consultants or advisors can contact you. This information will also be stored by Mercurytide.
We regularly review your interactions with the emails we send you and remove any subscribers who have shown an extended period of inactivity. You can withdraw your consent and unsubscribe at any time by clicking the link at the bottom of our email communications or by emailing email@example.com.
If you continue to interact with our emails or website, we will retain your data indefinitely, so we can continue to send you emails.
Purposes of the processing and the legal basis for the processing
We use information held about you in the following ways:
To carry out our obligations arising from any contracts we intend to enter into or have entered into between you and us and to provide you with the information, products and services that you request from us or we think will be of interest to you because it is relevant to your career or to your organisation.
To provide you with information about other goods and services we offer that are similar to those that you have already purchased, been provided with or enquired about.
The core service we offer to our candidates and clients is the introduction of candidates to our clients for the purpose of permanent engagement. However, our service expands to supporting individuals throughout their career and to supporting businesses’ resourcing needs and strategies.
Our legal basis for the processing of personal data is our legitimate business interests, described in more detail below, although we will also rely on contract, legal obligation and consent for specific uses of data.
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 required 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. Examples of when consent may be the lawful basis for processing include permission to introduce you to a client (if you are a candidate).
Our Legitimate Business Interests
Our legitimate interests in collecting and retaining your personal data is described below:
As a recruitment business and recruitment agency we introduce candidates to clients for permanent employment, independent professional contracts. The exchange of personal data of our candidates and our client contacts is a fundamental, essential part of this process.
In order to support our candidates’ career aspirations and our clients’ resourcing needs we require a database of candidate and client personal data containing historical information as well as current resourcing requirements.
To maintain, expand and develop our business we need to record the personal data of prospective candidates, client contacts and other people whom we may contact in order to find out more about our candidates.
Candidates - In order to deliver valuable employment opportunities that fit with your requirements, we need to process set information about you. We adhere to strict rules where we only ask for details to assist us in our employment service to you, including your name, age, contact details, education details, work history, right to work status, financial information and national insurance number and additional information that you opt to share with us to assist in your job search. In individual circumstances and in accordance with local laws and requirements, we may also gather details related to your health, diversity information or details of any unspent convictions.
Clients - We will retain the personal data we process when representing our Clients for as long as required to offer value added assistance to our Client. This covers using information about you, or individuals at your organisation, whilst offering service to you on: (i) finding Candidates who are the best match for you or your organisation; and/or (ii) alerting you to recently published content by Kingpin International which may be of value to you.
For people whose data we receive from our own employees and candidates, specifically referees - unless you explicitly state to the contrary, we may share your information with any of our group companies and associated third parties such as our service providers and organisations to whom we provide 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:
- Use of our website;
- to notify you about changes to our service;
- to ensure that content from our site is presented in the most effective manner for you and for your computer;
We will use this information:
- to administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
- to improve our site to ensure that content is presented in the most effective manner for you and for your computer;
- to allow you to participate in interactive features of our service, when you choose to do so;
- as part of our efforts to keep our site safe and secure;
- to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you;
- to make suggestions and recommendations to you and other users of our site about goods or services that may interest you or them;
We do not undertake automated decision making or profiling. We do use our computer systems 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.
Disclosure of your information inside and outside of the EEA
We will share your personal information with:
- Any member of our group both in the EEA and outside of the EEA.
Selected third parties including:
- clients for the purpose of introducing candidates to them;
- candidates for the purpose of arranging interviews and engagements;
- clients, business partners, suppliers and sub-contractors for the performance and compliance obligations of any contract we enter into with them or you;
- subcontractors including, event organisers, payment and other financial service providers;
- advertisers and advertising networks that require the data to select and serve relevant adverts to you and others. We do not disclose information about identifiable individuals to our advertisers, but we will provide them with aggregate information about our users (for example, we may inform them that 500 men aged under 30 have clicked on their advertisement on any given day). We may also use such aggregate information to help advertisers reach the kind of audience they want to target (for example, women in SW1). We may make use of the personal data we have collected from you to enable us to comply with our advertisers’ wishes by displaying their advertisement to that target audience;
- analytics and search engine providers that assist us in the improvement and optimisation of our site;
- credit reference agencies, our insurance broker, compliance partners and other sub-contractors for the purpose of assessing your suitability for a role where this is a condition of us entering into a contract with you.
We will disclose your personal information to third parties:
- In the event that we sell or buy any business or assets, in which case we will disclose your personal data to the prospective seller or buyer of such business or assets.
- If Kingpin International or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
- If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms and conditions of supply of services and other agreements; or to protect the rights, property, or safety of Kingpin International, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
Where we store and process your personal data
The data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (”EEA”). It may be transferred to third parties outside of the EEA for the purpose of our recruitment services. It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers. This includes staff engaged in, among other things, our recruitment services and the provision of support services. By submitting your personal data, you agree to this transfer, storing or processing. Kingpin International will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy notice.
All information you provide to us is stored on our secure servers. Any payment transactions will be encrypted using SSL technology. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, 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 following the end of our legitimate contact, or as long as we need it for our legitimate business interests and legal obligations. Accordingly, we have a data retention notice and run data routines to remove data that we no longer have a legitimate business interest and legal obligation in maintaining. If however you believe that we should delete your personal data at an earlier date, please inform us in writing of your reasons.
We do the following to try to ensure our data is accurate:
- prior to making an introduction we check that we have accurate information about you
- we keep in touch with you so you can let us know of changes to your personal data
- We segregate our data so that we keep different types of data for different time periods. The criteria we use to determine whether we should retain your personal data includes:
- the nature of the personal data;
- its perceived accuracy;
- our legal obligations;
- whether an interview or placement has been arranged; and
- our recruitment expertise and knowledge of the industry by country, sector and job role.
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.
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 forms we use to collect your data. You can also exercise the right at any time by contacting us at firstname.lastname@example.org.
You can find more information about your rights through this link:
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.
The GDPR provides you with the following rights. To:
- Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
- Request erasure of your personal information. This enables you to ask us to delete or remove personal information 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 information where you have exercised your right to object to processing (see below).
- Object to processing of your personal information 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. You also have the right to object where we are processing your personal information for direct marketing purposes.
- Request the restriction of processing of 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 in certain formats, if practicable.
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/
Access to information
The Data Protection Act 1998 and the GDPR give you the right to access information held about you. We also encourage you to contact us to ensure your data is accurate and complete.
Your right of access can be exercised in accordance with the Act (and the GDPR once it is in force). Prior to 25th May 2018 any access request under the Data Protection Act will be subject to a fee of £10 to meet our costs in providing you with details of the information we hold about you.
A subject access request should be submitted to email@example.com.
No fee will apply once the GDPR comes into force.
Changes to our privacy notice
Any changes we make to our privacy notice in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our privacy notice. This policy was last updated in May 2018.
For whatever reason, should you wish to lodge a complaint with the Information Commissioner’s office, as is your right, you can do by contacting the ICO directly via one of the options on their website https://ico.org.uk/global/contact-us/