Welcome to the Solsbury Training and Development Solutions Limited's privacy notice.
Solsbury Training and Development Solutions Limited respects your privacy and is committed to protecting your personal data. This privacy notice 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 provide it by different means, as well as informing you about your privacy rights and how the law protects you.
Please also use the Glossary at section 10 below to understand the meaning of some of the terms used in this privacy notice.
1. IMPORTANT INFORMATION AND WHO WE ARE
Purpose of this privacy notice
This privacy notice aims to give you information on how Solsbury Training and Development Solutions Limited collects and processes your personal data through your use of this website, including any data you may provide through this website when you register as a candidate, upload your CV or submit an enquiry. This privacy notice will also apply when you share this information to us by email, telephone, mail, in person or otherwise.
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 notice together with any other privacy notice or fair processing notice 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 notice supplements the other notices and is not intended to override them.
Solsbury Training and Development Solutions Limited ('we’, ‘us’ or ‘our) is the controller and responsible for your personal data.
We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights (please see section 9 and 10 below), please contact the data privacy manager using the details set out below.
Full name of legal entity: Solsbury Training and Development Solutions Limited (Company number: 10117067)
Name or title of data privacy manager: Data Privacy Manager
Email address: firstname.lastname@example.org
Postal address: 1st Floor Holdsworth House, 11a Wood Street, Wakefield, WF1 2EL
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 notice and your duty to inform us of changes
This version was last updated on 21st May 2018 and historic versions can be obtained by contacting us.
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.
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 notice 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, last name, username or similar identifier, title, date of birth, gender and national insurance number.
Contact Data includes address, email address and telephone numbers.
Financial Data includes bank account details.
Transaction Data includes details about payments to and from you and other details of services provided to you name, namely recruitment services.
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.
Profile Data includes your username and password, your interests, preferences, feedback and survey responses, employment history, salary, skills and attributes, education details, qualifications
Usage Data includes information about how you use our website and services.
Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
Special Categories of Personal Data includes details about your race or ethnicity, religious beliefs, sexual orientation, information about your health and genetic and biometric data. This data will always be obtained with explicit consent only.
Criminal Convictions and Offences Data includes details about your criminal convictions and 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 for the purposes of recruitment services. In this case, we may be unable to provide the recruitment services you have requested 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, Profile, Special Categories of Personal Data and Financial Data by filling in forms, registering an account with us, uploading your CV or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you
apply for our services;
create an account on our website;
subscribe to our service or publications;
request marketing to be sent to you;
give us some feedback.
Third parties or publicly available sources. We may receive personal data about you from various third parties as set out below:
Technical Data from the following parties:
(a) analytics providers;
(b) advertising networks; and
(c) search information providers.
Contact, Financial and Transaction Data from providers of technical and payment services.
Identity and Contact Data from publicly availably sources.
Identity, Contact, Profile and Financial Data from your current employer, when if you are employed by an umbrella/payroll company or personal service company. Please note: In these circumstances, when you are engaged through such a company, we will be relying on your employer to ensure they have established a legal basis for processing your data with you. Our basis for the ongoing processing of your data will become subject to a contract between us and that company.
Disclosure and Barring Service in respect of criminal convictions.
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 or your employer/prospective employer.
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 or regulatory obligation.
Purposes for which we will use your personal data
We have set out below, in a table format, 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.
Generally, and where possible, we will rely on consent as a legal basis for processing your personal data. However, please 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.
Type of data
Lawful basis for processing including basis of legitimate interest
To register you
(a) Necessary for our legitimate interest to provide our recruitment services to you or your employer/prospective employer.
(b) conducted on the basis of your explicit consent (post 25th May 2018)
To notify you of job opportunities and resource candidates for our business clients
(d) Special categories of
(a) Necessary for our legitimate interest to provide our recruitment services to you or your employer/prospective employer.
(b) conducted on the basis of your explicit consent
To manage our relationship with you which will include:
(b) Asking you to leave a review or take a survey
(d) Marketing and Communications
(a) Necessary to comply with a legal obligation
(b) Necessary for our legitimate interests (to keep our records updated and to study how candidates use our services)
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
(b) Necessary to comply with a legal obligation
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you
(e) Marketing and
Necessary for our legitimate interests (to study how candidates use our services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, services, marketing, customer relationships and experiences
Necessary for our legitimate interests (to define types of candidates for our services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about services that may be of interest to you
Necessary for our legitimate interests (to develop our services and grow our business)
To obtain equal opportunities and diversity information about candidates who engage our services
(d) Special Categories of
(a) Necessary for our legitimate interests (to understand the type of candidates who use our services, to meet aims and objectives of internal equality policies and to identify areas for development and grow our business)
(b) Necessary to comply with a legal obligation (i.e. equal opportunities)
To carry out financial or criminal background checks
(a) Necessary to comply with a legal obligation
(b) Employment exemption (necessary in connection with employment)
(c) on the basis of your explicit consent
To carry out payroll or invoicing activities, as well as reporting to the HMRC and administering pensions
(a) Identity Data;
(b) Contact Data;
(c) Financial Data;
(d) Transaction Data
(a) Performance of a contract with your employer/ prospective employer (please review your employment relationship for information on data processing)
(b) Necessary for our legitimate interests (to recover fees and debts due to us)
To manage our relationships with our clients, provide you with our services and, where applicable, communicate with your employees and personnel
(e) Marketing and
(f) Financial Data
(g) Transaction Data
(a) Performance of a contract
(b) Necessary for our legitimate interests to provide our services to our clients
When you apply for a job with us
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
Promotional offers from us
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which services may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have requested information from us or registered your details with us and, in each case, you have not opted out of receiving that marketing .
We will get your express opt-in consent before we share your personal data with any company outside Solsbury Training and Development Solutions Limited for marketing purposes .
You can ask us or third parties to stop sending you marketing messages at any time.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of registering with us as a candidate for our services.
We do not collect client personal data for our clients, beyond business emails and telephone number of you or your employees, as well as recording a history of contact.
We rely on legitimate interest to store and use this information, because we need to communicate with you in order to provide services and perform our functions, as well as responding to requests for information and placing orders. We believe it is within your reasonable expectations that we will process this minimal contract information and this will not impact the legal rights and freedoms of your and/or your employees. We also provide the opportunity for you to opt out of any communications and you may exercise your data rights (set out below)
What's a cookie?
A "cookie" is a piece of information that is stored on your computer's hard drive and which records your navigation of a website so that, when you revisit that website, it can present tailored options based on the information stored about your last visit. Cookies can also be used to analyse traffic and for advertising and marketing purposes.
Cookies are used by nearly all websites and do not harm your system. If you want to check or change what types of cookies you accept, this can usually be altered within your browser settings.
to track your use of our websites. This enables us to understand how you use the sites and track any patterns that emerge individually or from larger groups. This helps us to develop and improve our websites and services in response to what our visitors want and need; and
to provide information on our services contract, hopefully means less time spent trawling pages and more time on the things that matter.
Cookies are either:
Session cookies: these are only stored on your computer during your web session and are automatically deleted when you close your browser – they usually store an anonymous session ID allowing you to browse a website without having to log in to each page but they do not collect any information from your computer; or
Persistent cookies: a persistent cookie is stored as a file on your computer and it remains there when you close your web browser. The cookie can be read by the websites that created it when you visit that website again. We use persistent cookies for Google Analytics and for personalisation (see below).
Cookies can also be categorised as follows:
Strictly necessary cookies: These cookies are essential to enable you to use the websites effectively, such as when registering on our websites, and therefore cannot be turned off. Without these cookies, the services available to you on our websites cannot be provided. These cookies do not gather information about you that could be used for marketing or remembering where you have been on the internet.
Performance cookies: These cookies enable us to monitor and improve the performance of our websites. For example, they allow us to count visits, identify traffic sources and see which parts of the site are most popular.
Functionality cookies: These cookies allow our websites to remember choices you make (such as your user name, language or the region you are in) and provide enhanced features. For instance, we may be able to provide you with news or updates relevant to the services you use. These cookies can also be used to remember changes you have made to text size, font and other parts of web pages that you can customise. They may also be used to provide services you have requested such as viewing a video or commenting on a blog. The information these cookies collect is usually anonymised.
Personalisation cookies: These cookies help us to provide our services specific to you. These cookies are persistent (for as long as you are registered with us) and mean that when you log in or return to the websites, you may see information similar to that you have previously browsed.
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 us.
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 have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.
Internal third parties such as, our employees or officers who are based in the United Kingdom and provide IT and/or system administration services.
External third parties such as:
specialist IT support, suppliers and sub-contractors for the performance of this site, including QuoStar, Volcanic, JobAdder
other outsourced service providers of [Account, HR, marketing] services, including Access Outsourcing, NOW Pensions,
professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services;
HM Revenue & Customs, regulators and other authorities who require reporting or processing activities in certain circumstances.
OnePay for pre-paid banking services
Our clients, if we place you with them for work roles and assignments.
Your existing employer, when you are engaged through a personal service or umbrella company.
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 notice. 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 necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
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 requirements.
We will usually keep data for the following durations:
Permanent candidate data (placed) – 7 years from commencement of the job
Permanent candidate (not placed) – 3 months
Contractor data (placed) – 7 years from the end of an assignment
Contractor data (not placed) – 3 months
Website user – 12 months
Employees /Personnel of Clients – 2 years
In some circumstances you can ask us to delete your data: see Request erasure below for further information.
In some circumstances we may 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 as follows:
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: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) 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; or (d) 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 services to you. We will advise you if this is the case at the time you withdraw your 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 may 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 may 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.
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.
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 or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.