(Last updated 21st April 2023)
We are Orbis Consultants LTD (“Orbis”), Company Registration No. 09749682, VAT No. 171647009, Registered Office: 77 Leadenhall Street, London, United Kingdom, EC3A 3DE.
Our Group means our subsidiaries, our ultimate holding company and its subsidiaries, and our associated companies as defined in section 1159 of the UK Companies Act 2006 (our “Group”).
We are the Data Controller for the purposes of UK General Data Protection Regulation (UK GDPR) (Regulation (EU) 2016/679) or any successor legislation or applicable data protection and privacy legislation in force from time to time which apply to a party relating to the use of personal data.
We are a recruitment agency and recruitment business (our “Services”).
We collect the personal data of the following categories of data subjects to allow us to undertake our business activities:
We will collect and process the following data about you:
We use cookies to distinguish you from other users of our Site. This helps us to provide you with a personalised experience when you browse our Site and also allows us to improve the Site. For detailed information on the cookies we use and the purposes for which we use them, see our Cookie Policy.
We use information held about you in the following ways:
We may associate any category of information with any other category of information and will treat the combined information as personal data in accordance with this policy for as long as it is combined.
We may also collect the following “special categories” of more sensitive personal information:
Please note that phone calls may be recorded from time to time solely for internal quality and training purposes. Recorded phone calls will be stored for a maximum period of sixty days and only limited staff members have authorization to listen to the recordings for quality and training purposes.
This is information we obtain about you from other sources such as:
In this case you will be informed (unless an exemption applies under GDPR which means that sending the privacy notice will be impossible or disproportionate) of the fact that 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 work closely with third parties including companies within our Group and companies under common ownership, 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.
Purposes of the processing and the legal basis for the processing
We use information held about you in the following circumstances:
Our legal basis for the processing of personal data is our legitimate business interests (or those of a third party), although we may also rely on contract, legal obligation and consent, for specific uses of data.
We will rely on the contract ground if we are discussing, or negotiating, or have entered into a placement or an agreement with you or your organisation or any other contract of service or contract for services, contract to provide services to you or receive services from you or your organisation.
We will rely on the legal obligation ground if we are legally required to hold information on you to fulfil our legal obligations. For example, for reasons related to HMRC or employment law.
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 obtaining your permission before introducing you to a client for a vacancy (if you are a candidate).
Our legitimate interests in collecting and retaining your personal data are described below:
As a recruitment business and recruitment agency we introduce candidates to clients for permanent employment, temporary placements or independent contractor services. The exchange of personal data of our candidates and our client contacts is an 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, employees and client contacts. If we discover your CV on a job board, CV database or other location in the public domain, we will rely on legitimate interests when adding your information to our database. We will also consider the use of your personal data in this manner to be within your reasonable expectations.
Once we have added your personal information to our database, we may contact you from time to time via phone or email with details of vacancies which we believe may be of interest/suitable to you. If you have applied for a specific role which was unsuccessful, we may also contact you from time to time with alternative roles. You have the right to inform us at any time should you not wish to receive this kind of communication (see the section on Your Rights below).
To deliver our services we may need to use your data for the following purposes:
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.
You agree that we have the right to disclose your personal information to any member of our Group, which means our subsidiaries, our ultimate holding company and its subsidiaries, or any affiliated companies of Orbis as defined in section 1159 of the Companies Act 2006.
We may also disclose your personal information to third parties:
The lawful basis for the third party processing will include:
The data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (EEA). It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers. These staff may be engaged in the fulfilment of your request, order or reservation, the processing of your payment details and the provision of support services. By submitting your personal data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy.
All information you provide to us is stored on our secure servers. Any payment transactions carried out by us or our chosen third-party provider of payment processing services will be encrypted using industry leading encryption technology. Where we have given you (or where you have chosen) a password that enables you to access certain parts of our Sites, you are responsible for keeping this password confidential. We strongly recommend you not to share your 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 and will always make sure that security measures are in place to protect your personal data. Measures are also in place to discover any breaches and to enable us to notify the ICO.
Under data protection legislation, you have the right to request access to information about you that we hold (this is called a “Data Subject Access Request” or “DSAR”). To make a request for your personal information see the Contact section below.
We will always inform you (before collecting your personal information) of how we plan to use that personal information. You can exercise your right to prevent such processing by checking certain boxes on the Site when you submit your information. You can also exercise the right at any time by contacting us via email to gdpr@weareorbis.com.
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 and any services that may be accessible through them have their own privacy policies and that we do not accept any responsibility or liability for these policies or for any personal data that may be collected through these websites or services, such as contact and location data. Please check these policies before you submit any personal data to these websites or use these services.
This data will be retained in our records for no longer than is necessary to:
Details of retention periods are available on request. See Contact section below.
If we change our Privacy Policy, we will post the changes on this page. If we decide to, we may also email you. We recommend that you check this page regularly to keep up-to-date.
Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to Orbis, 77 Leadenhall Street, London, United Kingdom, EC3A 3DEor emailed to gdpr@weareorbis.com.
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