Our approach to your privacy explained
Seymour John Limited respects your privacy and is committed to protecting your personal data.
This privacy notice tells you what to expect in relation to personal information about you, which is collected, handled, and processed by Seymour John Limited (registered company no. 8114826) and its associated and group companies (refer to glossary and definitions at the end of this Privacy Notice).
This privacy notice not only provides information on how Seymour John Limited and its associated and group companies collects and processes your personal data, it also tells you about your privacy rights and how the law protects you.
This notice does not form part of any contract of employment, a contract to provide services or any other contract.
Changes to this Notice
We may amend or update this Notice at any time. Where appropriate, we will notify you of any changes by email.
Seymour John Limited is the controller and responsible for your personal data (collectively referred to as Seymour John Limited, “we”, “us” or “our” in this privacy notice).
If you have any questions about this privacy notice, please contact:
Mark Seymour or Emlyn John
Seymour John Limited
Suite 2, Canterbury Business Centre
18 Ashchurch Road
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.
How do we collect personal data?
We obtain information about you:
- When you use our website
- When you register with us via telephone or email or from online/offline media
- Via a third party we work with, such as a job board or LinkedIn
- By reference or word of mouth.
- For example, you may be recommended by a friend, a former employer, a former colleague
- Through administering and managing our consultancy or managed services to our clients
The personal information we may collect, hold and process:
- Your name
- Your address
- Your email address
- Your telephone number
- CV/work history
- Job preferences including role, geographical areas
- Details about your current remuneration, pensions and benefits arrangements
- Any other work-related information you provide, for example, education, professional qualifications
- Extra information you choose to tell us
- Eligibility to work in the UK – passport, permits and visas
- DOBHealth and safety/medical conditions
- National Insurance number
- Details of criminal convictions
- A log of our communications with you by email and telephone
- Payroll information
- Information relevant for the purposes of day-to-day people management and people and change consultancy servicesInformation relevant for the purposes of providing our managed services
The legal basis for processing your data
For the Processing of your data to be lawful, at least one of the following conditions must be met:
- You have given your consent to the processing
- The processing is necessary for the performance of a contract with you, or for taking steps with a view towards entering into a contract
- The Processing is required under a legal obligation other than a contract
- The Processing is necessary to pursue our Legitimate Interests or of third parties, and does not prejudice your rights, freedoms or Legitimate Interests
- The Processing is necessary to protect your Vital Interests
- The Processing is necessary in the public interest
We envisage that much of our lawful processing of your data will fall within condition 4, listed above. This is because:
- Our processing of your data is necessary to be able to assess suitability for potential roles, to find potential candidates and to contact clients and referees.
- Our processing of your data is necessary to be able to administer, manage and develop our business, consultancy and managed services for our client
When we first establish a relationship with a client, we will seek consent to process personal data before we proceed any further. We retain evidence of the consent which has been provided. We do believe that this storage and use of your personal information will unduly prejudice your rights or freedoms.
Examples of our Legitimate Interest
An individual uploads their CV to a jobs board website. We access the CV and think that the individual may have the skills that two of our clients are looking for and want to pass the CV to those companies. The individual has made their CV available on a job board website for the express reason of us being able to access this data. They have not given specific consent for identified data controllers, but they would clearly expect that recruitment agencies would access the CV and share it with their clients. Indeed, this is likely to be the individual’s intention. As such, our legitimate interest (and that of our clients’) to fill vacancies would not be overridden by any interests or rights of the individual. In fact, those legitimate interests are likely to align with the interests of the individual because they wish to find a job.
A client requests that we carry out a salary benchmarking exercise for a group of employees at their company and make recommendations for any uplifts required against market data. This requires us to review individual salaries plus check individuals’ professional qualifications to determine how their current pay rate compares to others. As our legitimate interest (and that of our clients') is to ensure the individual receives a fair rate of pay for their work, this exercise would not override the rights of the individual.
In certain circumstances, we are required to obtain your explicit consent to the processing of your personal data in relation to certain activities. Depending on exactly what we are doing with your information, this consent will be opt-in consent or soft opt-in consent.
Where we are processing data based on your consent, you have the right to withdraw that consent at any time. If you do decide to withdraw your consent, we will advise you of the impact of that decision as it may mean we will not be able to fulfil a contract we have with you or we may be prevented from complying with our legal obligations.
We use your information:
- To provide our services to you
- To contact you via email, SMS or phone, about vacancies that we believe you may be interested in
- To answer your enquiries
- To keep you informed of new vacancies/services we offer
- Maintain a client or candidate business relationship with you
- To match your skill sets with job vacancies when finding you the positions that most suit you and to send your personal information (including sensitive personal information) to clients when applying for jobs (we will obtain verbal or written consent before presenting your details to a client)
- To directly market products and services, and advise you of any updates to our services, where you have consented. Where we do so, you will be able to unsubscribe at any time from receiving any further communications from us
- To fulfil contractual obligations with our clients in ensuring effective people and change consultancy, business administration and managed services
- We will also disclose your personal information where we are permitted and requested to do so by law
- If Seymour John Limited merges with or is acquired by another business or company, we may share personal information with the new owners of the business or company and their advisors. If this happens, we will let you know.
- If Seymour John are providing consultancy support or managed services to a client through a merger, acquisition or because of a TUPE (Transfer of Undertakings (Protection of Employment) Regulation), we may share personal information with the new owners of the business about you as a contact of our client.
Special Categories of Sensitive Personal Data
Processing of Special Categories of Personal Data (Sensitive Personal Data) is subject to more stringent restrictions. The processing of such data will only be carried out if at least one of the above conditions, applicable to personal data, has been met and one of the following conditions can also be met:
- You have given your explicit consent
- The Processing is required by law in connection with employment
- The Processing is necessary to protect your vital interests or those of another person
- The information has been made public by you
- The Processing is necessary for legal proceedings, obtaining legal advice, or establishing or defending legal rights
- The Processing is required for the administration of justice, the exercise of functions under an enactment, or the exercise of functions of the Crown or a government department
- The Processing is necessary for medical purposes, and is carried out by a health professional or a person with an equivalent duty of confidentiality
- The Processing is necessary to review the equality of opportunity between people of different racial or ethnic backgrounds, different religious beliefs, or different states of physical or mental health
- The Processing is in the substantial public interest because it is necessary for the provision of confidential counselling, advice, support or other service and consent cannot be given by you or we cannot reasonably be expected to obtain your explicit consent, or the Processing must be carried out without consent so as not to prejudice the provision of that counselling, advice, support or other service
- The Processing is in the substantial public interest, and is necessary for research purposes and will not cause substantial damage or distress to you or any other person
How we use special categories of personal data
We may use special categories (sensitive data) about you as follows:
- If you are shortlisted as a candidate, then this may involve the processing of more detailed personal data, including sensitive data such as health information, which you provide or others provide about you. In this case we always ask for your consent before undertaking such processing.
- We may use information about your disability status to ensure your health and safety in the recruitment activity, to assess your fitness to work in certain job roles or to communicate workplace adjustments that may be required.
- We may use information relating to racial or ethnic origin, political opinions, religious beliefs, trade union membership, physical or mental health, and sexual life to ensure meaningful equal-opportunity monitoring and reporting.
- We may use information provided by a client related to your sensitive personal data to ensure legal compliance and in promoting employment regulation and best practice
Where we hold your information
All the personal data we hold on our database is hosted within the European Economic Area (EEA).
Who has access to your information?
Your CV and related information will be shared or sent to prospective employers and our clients.
For our consultancy and managed services, we will only share, access, or process personal data provided by clients, for the purpose it was collected for.
Personal data shall not be transferred to a country or territory outside the EEA unless that country or territory ensures an adequate level of protection, or the appropriate safeguards are in place for your rights and freedoms. We will inform you of any such transfer before it takes place.
Retention of your data
For both candidates and clients, we will ensure that personal data is not kept for longer than is required by the purpose or purposes for which the data was gathered.
As we work with you for the duration of your professional working life in respect of our recruitment service, we will retain personal data until such time that we are advised that you have left a business that is a client of Seymour John or that the business is no longer trading.
In respect of our consultancy and managed services, we will retain personal data for the contract duration and for up to two years after the end of the contract termination date.
We ensure that personal data is securely destroyed once the purpose or purposes for processing have come to an end and there is no legal requirement or valid operational reason for its continued retention.
It is important that the personal data we hold about you is accurate and current, and we will complete regular audits of the data we hold. However, please also keep us informed if your personal data changes during your relationship with us.
Your legal rights
You have the right to:
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. 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. We may also refuse to comply with your request in such circumstances.
We may need to ask you for specific information to help us confirm your identity and ensure your right to access the requested 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 for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it may take us longer 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.
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.
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. These 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 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 you, or a third party you have chosen, with 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 products or services to you. We will advise you if this is the case at the time you withdraw your consent.
Personal Data will be safeguarded in accordance with our Information Security Policy, which outlines our security measures to prevent your personal data from being lost, used, or accessed in an unauthorised way. In addition, we limit access to your personal data to those employees and third parties who have a legitimate business need to access, use, and process it. Any incident, or potential incident, likely to result in unauthorised disclosure, damage, destruction, or loss of Personal Data must be reported immediately to the Data Controller.
Non-sensitive details (your email address etc.) are transmitted normally over the Internet, and this can never be guaranteed to be 100% secure. As a result, while we strive to protect your personal information provided through our recruitment, consultancy, or managed services, we cannot guarantee the security of any information you transmit to us, and you do so at your own risk.
Sharing of your personal data
Where required by law, where it is necessary to administer the relationship with you or where we or the third party have a legitimate interest in doing so, we may have to share your personal data with the third parties set out in the Glossary & Definitions section of 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.
Use of ‘cookies’
Cookies are small files saved to the user’s computer’s hard drive. They track, save and store information about the user’s interactions and usage of the website. This allows the website, through its server, to provide a tailored user-experience.
Users are advised that if they wish to deny the use and saving of cookies from this website on to their computer’s hard drive they should take necessary steps within their web browsers security settings to block all cookies from this website and its external serving vendors.
Other cookies may be stored to your computer’s hard drive by external vendors when this website uses referral programs, sponsored links or adverts. Such cookies are used for conversion and referral tracking and typically expire after 30 days, though some may take longer. No personal information is stored, saved or collected.
Social media platforms
Communication, engagement, and actions taken through external social media platforms, which this website and its owners participate on, are custom to the terms and conditions as well as the privacy policies held with each social media platform respectively.
Users are advised to use social media platforms wisely and communicate/engage on them with due care and caution in regard to their own privacy and personal details. This website nor its owners will ever ask for personal or sensitive information through social media platforms and encourage users wishing to discuss sensitive details to contact them through primary communication channels, such as by telephone or email.
This website may use social sharing buttons which help share web content directly from web pages to the social media platform in question. Users are advised, before using these buttons, that they do so at their own discretion and to note that the social media platform may track and save the request to share a web page respectively through the individual’s social media platform account.
Shortened links in social media
This website and its owners may share web links to relevant web pages through their social media platforms. By default, some social media platforms shorten lengthy urls (web addresses, of which this is an example: http://bit.ly/2pIEq7v). Users are advised to take caution and good judgement before clicking any shortened urls published on social media platforms by this website and its owners. Despite the best efforts to ensure only genuine urls are published, many social media platforms are prone to spam and hacking and therefore this website and its owners cannot be held liable for any damages or implications caused by visiting any shortened links.
Glossary and Definitions
Comply with a legal or regulatory obligation: The processing of your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
Data Controller: A person or organisation who makes decisions regarding Personal Data, including decisions about the purposes for which and the manner in which Personal Data may be processed.
Information Commissioner: The regulator appointed by the Crown to promote public access to official information and protect personal information. Compliance with the General Data Protection Regulations is enforced by the Information Commissioner.
Legitimate Interest: The interest in conducting and managing our business in a way that enables us to give you the best service/product 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: email@example.com or firstname.lastname@example.org
Personal Data: Information relating to a living individual who can be identified from the data, or from the data and other information which is in our possession (or likely to come into our possession). Personal data include information such as an individual’s name, home address, educational background, images and photographs (including CCTV footage), expressions of opinion about the individual, and our intentions in regard to the individual.
Performance of Contract: The processing of your data where it is necessary for the performance of a contract to which you are a party (or the precursor to entering into such a contract).
Processing: Any operation on Personal Data, including obtaining, recording, holding, organising, adapting, combining, altering, retrieving, consulting, disclosing, disseminating, deleting, destroying and otherwise using the data.
Seymour John Ltd associated and group companies: Seymour John Limited (registered company no. 8114826), Seymour John (Cardiff) Limited (registered company no. 9637428), Seymour John (Shropshire) Limited (registered company no. 9637394), Seymour John (West Midlands) Limited (registered company no. 10792708), Seymour John Public Services (Midlands) Limited (registered company no. 10283467), Seymour John Public Services (North) Limited (registered company no. 12052666), Seymour John People & Change Limited (registered company no. 11051337) or Seymour John (Cheshire) Limited (registered company no. 11768275), all with their registered office at 1 Aston Court, Bromsgrove Technology Park, Bromsgrove, Worcestershire, B60 3AL.
Third Parties: Some of the third parties with whom we may share your personal data:
- Vincere Software – CRM database
- Sage – Accountancy software
- Eden – Timesheet and payroll bureau
- BPE Solicitors – Legal advisors
- Harrison Clark Rickerbys – Legal advisors
- 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
Vital Interests: Relating to life and death situations e.g., the disclosure of a Data Subject’s medical details to a paramedic after a serious accident.
This Privacy Notice was last updated on 19th October 2022.