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Our Privacy Policy

Introduction


This Privacy Policy explains what we do with your personal data, whether we are in the process of finding you a job, continuing our relationship with you post placement, providing you with a service, receiving a service from you, using your data to ask for your assistance in relation to one of our candidates, or you are visiting this site.

Oscar is committed to protecting and respecting your privacy.

This policy sets out the basis of personal data we collect from you, that you provide to us, and how that data will be processed by us in line with our legal obligations to you.

For the purpose of the General Data Protection Regulation (Regulation (EU) 2016/679) (the GDPR), the data controller is

Oscar Associates (UK) Ltd
Freetrade Exchange
Peter Street
Manchester
M2 5GB

 

This Privacy Policy applies to the personal data of our Candidates, Clients, Suppliers and Website Users. If you are a member of Oscar staff you should refer to the Oscar Employee Guide that is available on an internal Shared Drive.

From time to time we may need to amend this Privacy Policy. Please visit this page to stay up to date, as any changes made will be posted here.


What do Oscar Associates (UK) Ltd do?

Oscar provides recruitment related services to candidates and clients and we will, therefore, use your personal data in order for us to be able to deliver these services to you whether you be a; candidate, client or website user.


What kind of personal information do we collect?
Candidate

Depending on the relevant circumstances in line with local laws and obligations we will most likely collect some or all of the information detailed below in order for us to offer you employment options in line with your circumstances and interests:

  • Name
  • Photograph
  • Contact Details
  • Education Details
  • Employment History
  • Emergency Contact Details
  • Referee Details
  • Your right to work status
  • Nationality
  • A copy of your driving licence/passport /identity card (if requested by a client to fulfil our obligations with them on your behalf)
  • Financial Information (where we need to carry out financial background checks if requested by a client to fulfil our obligations with them on your behalf)
  • National Insurance Number (if requested by a client to fulfil our obligations with them on your behalf)
  • Details of Criminal Convictions if this is requested for a role that you are interested in applying for
  • Details about your current and expected salary, pensions & benefits arrangements
  • Information on your interests and needs regarding future job opportunities
  • Any additional information you choose to disclose to us
  • Any additional information your referees disclose to us
  • Any additional information our clients disclose to us or that we find from a third party such as a job board
  • IP address (not actively monitored but the capability to do so does exist)
  • The dates, times and frequency with which you access our services

A lot of the above data will only be collected as part of a pre-screening call with one of our consultants. Upon initial contact, we will process the data that you have made available on your CV or third-party profiles such as profiles filled out on a job board or networking site.

Client

The client data we collect is fairly minimal. In line with the information we require to operate our business as a provider of recruitment services, but will incorporate the following:

  • Company name
  • Company address
  • Company phone number
  • Contact Name
  • Contact Details
  • Any information you have chosen to disclose as part of our business dealings
Supplier Data

Supplier data we collect simply relates to the information we need to enable our relationship to run smoothly. It will incorporate the following:

  • Company Name
  • Company Address
  • Contact Details
  • Any information you have chosen to disclose as part of our business dealings
Website Users

We collect limited information that is purely focussed on helping us to improve your experience whilst using our website. This includes how you use our website, how often you access our website, your location and any contact details you provide by filling in a contact form.


Collection of your personal data
Candidate Data

The personal data we collect from candidates is collected in the following ways:

  • Personal Data that you provide to us as a candidate
  • Personal Data we receive from other sources
  • Personal data we collect automatically

Data you give us

To enable us to support you in your search for employment we need to know certain information. This allows us to present the best opportunities whilst saving you time by avoiding you having to wade through information about irrelevant jobs and services.

You can share your details with us in many ways and are likely to include:

  • Entering your details onto our website via a “contact us” form or via an application form as part of a registration process
  • Emailing your CV to an Oscar consultant
  • Leaving a hard copy of your CV with us at an event we are either attending or running.
  • Applying for a job via an online job search aggregator that then redirects to the Oscar website
  • Applying for a job advertised on our website
  • Entering a competition via any of our social media channels such as Facebook, Twitter or Instagram

Data we receive from other sources

  • Where you apply for a job that we have advertised via a third party such as an online job board
  • Via an online job board CV Database that you have signed up to and we have access to in line with the terms agreed by both parties
  • Your referees may share personal information about you with us
  • Our clients may share personal information about you with us
  • We will most likely also process your data when searching for Candidates through third-party applications such as job boards and social networking sites such as LinkedIn
  • If you like or share anything from our social media pages that will automatically provide us with the details you make available on your social media profiles
  • If you are referred to us

Data we collect automatically

  • By using our website or clicking or reading an email from us in line with any local laws and requirements we may also collect data automatically. More information can be found HERE
Client Data

Client personal data is collected in three ways:

  • Data we receive directly from you
  • Data we receive from other sources
  • Personal data we collect automatically

Data we collect from you

We want to find the best staff for you and your organisation. We will collect data in two main ways:

  • Where you contact us directly by phone or email
  • Where we contact you by either phone or email, or through our consultants wider business development activities

Data from other sources

We may collect your data from other sources where your details are available in the wider public domain by way of due diligence or market intelligence including:

  • From reviewing market & business trends through the analysis of online and offline media
  • From delegate lists at events

Data we collect automatically

  • By using our website or clicking or reading an email from us in line with any local laws and requirements we may also collect data automatically. More information can be found HERE

Use of your personal data
Candidate Data

Your data is used in the following ways:

  • For Recruitment Services
  • For Marketing Purposes
  • For any legal purposes

Recruitment Services

Oscar is a recruitment company that provides recruitment services to candidates by connecting them with suitable opportunities. We are most likely to use your personal details in line with this reasoning in the following ways:

  • Collecting data from you and other sources such as LinkedIn
  • Storing your details on our database so that we can get in touch with regard to recruitment
  • Providing you with our recruitment services and to progress you through the recruitment process
  • Assessing your data against vacancies that could be of interest and suitable to you
  • Sending your information to clients in order to apply for the job we have discussed with you and therefore assess your eligibility for the jobs in question
  • Enable us to upload your CV to any client online portals in order to introduce you to opportunities
  • Carrying out contractual agreements entered into
  • Carrying out contractual agreements on your behalf with third parties and clients in relation to recruitment
  • Processing payment through payroll or invoice processes
  • Carrying out customer satisfaction questionnaires
  • Processing your data to update you with relevant job opportunities in line with your expectations
  • To comply with the law

Marketing Activities

Where we process your data because you supplied it to us by applying for a job or submitting your CV to us and where you have made your CV available via a third-party online job board we feel it is legitimate to keep you informed about similar opportunities in line with the one we gathered your details for.

We are contacting you through the use of a Soft Opt-In where you have had a previous engagement with us and we are marketing recruitment related services. It is likely we will only contact you by email to suggest other jobs that could be of interest in line with the original role we processed your details for increasing your likelihood of us finding you a new position. For any other types of e-marketing, we are required to obtain your specific consent.

You have the right to object to us processing your data for the purposes of direct marketing and you can do so by clicking this Unsubscribe link. If you would prefer Oscar to no longer retain your details please click Remove Details and Oscar will completely remove you from our system.

Please be advised that once you have been deleted we have no way of knowing you existed on our CRM system and therefore if your details are available in the public domain you may end up back on our system. If you are happy for us to maintain a small amount of information about you on our system we can ensure we don’t end up repeatedly processing your details. Please state in your Unsubscribe email if you are happy for us to do this. If your email only states unsubscribe we will completely delete you from our CRM system.

Client Data

We use client information in the following ways:

  • Recruitment Activities
  • Marketing Activities
  • For legal purposes

Further detail on this is here:

Recruitment Activities

Recruitment as a service is what our business is focussed on. The main purpose of processing client data is therefore centred on the provision of candidates. We will use your data in the following ways to assist this:

  • Storing your details on our database so that we can contact you about recruitment services
  • Keeping records of conversations and meetings so that we can tailor our services to you
  • Undertaking client satisfaction questionnaires
  • Processing your data for the purpose of targeting appropriate marketing campaigns

We will use these details where we deem it necessary in line with our legitimate interest which is our legal basis for processing your data. For more information, please refer to Our legal bases for processing your data below. 

Marketing Activities

We will not seek consent when sending business to business emails as the rules on consent do not apply to business to business emails. However, where your personal data is processed to send business to business emails you have the right to object to direct marketing.

You have the right to object to us processing your data for the purposes of direct marketing and you can do so by clicking this Unsubscribe link. We will then ensure we no longer contact you by email for direct marketing, however, we will keep your data in line with our data retention policy unless you specifically request that we delete you from our CRM.

If you would prefer Oscar to no longer retain your details please click Remove Details and Oscar will completely remove you from our system.

Supplier Data

We will only use the data provided for intended purposes:

  • To store your details on our database in order to be able to contact you in line with the services you are providing to us
  • To obtain support and services from you
  • Where necessary to deal with any legal claims or legal obligations
Data we receive from candidates & staff
  • If Candidates or Oscar employees identify you as an emergency contact or referee we will contact you where necessary with regard to these purposes
  • From a reference taking perspective, this could be integral to a candidate securing or not securing an opportunity
  • If your data was processed for reference purposes we may on occasion use your details to discuss recruitment services with you where we think it may be of interest to you at which point we will use your data for the same purpose we do as a client.

Who we share your personal data with

In line with all local laws and requirements your data may be shared for any of the reasons outlined below:

  • Individuals & companies that hold information relating to your reference or application to work with Oscar. This could include current, past or potential employers, education bodies, examination bodies and employment & recruitment agencies
  • Tax, audit or government bodies relating where we are requested to do so by law
  • Third-party service providers carrying out work on our behalf under our instruction whether that be professional advisers such as lawyers, auditors or accountants, IT service providers carrying out work relating to our technology or services
  • Third-party outsourced IT & document storage providers where we have a processing agreement (or similar protection) in place
  • Marketing technology platforms
  • For candidates potential employers to in order to process your application for roles
  • For candidates with third parties relating to technical testing or clients that use online talent management systems

How we safeguard your personal data

We will do what we reasonably can to protect the personal data we hold from misuse, loss or unauthorised access.

If you suspect any misuse, loss or unauthorised access of your personal data please let us know immediately HERE


Data Retention Period

We will retain candidate and client data for a period of 4 years.

If we have not had meaningful contact by the end of those 4 years we will delete you from our CRM.

If we have not had meaningful contact that has involved you updating us about your circumstances in relation to looking for work within that period of time we will delete your data from our systems.

For a candidate meaningful contact refers to interaction between both parties, be it written or verbal, where you actively engage with our online services, where you submit an updated CV to us whether it be through an application to a job or direct to an Oscar consultant, if you communicate with us about potential roles via written or verbal communication, or you take part in any of our marketing campaigns including any social media marketing. We will not consider contact to be where you have received, opened and read any communication we have sent to you without actually responding to it.

For a client, meaningful contact refers to an interaction between both parties, be it written or verbal, where you actively engage with our online services or where you request services from us relating to recruitment. We will not consider contact to be where you have received, opened and read any communication we have sent to you without actually responding to it.

From a supplier perspective, we will maintain your data in line with the duration of any contractual agreements that we have in place.

This data retention policy will only be superseded in situations where we are legally obliged to maintain your data for a longer period than the period stated.


How to access and control the data we hold

Once we have processed your data you have rights over it.

It is likely that we will keep a record of communication with you to help resolve any issues raised.


Right to Object

You have the right to object to certain types of processing such as; direct marketing or where we have processed your details under legitimate interests.

We can refuse your right to object where we have processed your data to aid in dealing with any legal claim or legal matter.

If your process relates to direct marketing we must act on your objection by ceasing this activity.


Right to withdraw consent

Where we have obtained consent as the legal basis for processing your data you can withdraw consent at anytime. Where there is a requirement by law for us to retain data for a certain period of time we will be legally unable to delete or remove this data.


Data Subject Access Requests (DSAR)

You can ask us to confirm what information we hold about you at any time as well as requesting us to modify, update or delete such information. We will ask you to verify your identity and for more information about your request. You will not be charged for this request unless the request is “unfounded” or excessive. If you make multiple requests for the same data whilst we can’t charge you every time we may charge an administration fee if we constantly get the same request from you. If we refuse the request for any reason we will confirm in writing with the reason as to why.

Click DSAR to make this request and confirm what it is within this email that you are requesting.


Right to erasure

You have the right to request that we erase your personal details. The only reason we wouldn’t do this is where we are required to keep the information we hold by law for a certain period of time. Where this is the case we will inform you in writing.

If you are a candidate it is likely that we have processed you from a job board or wider public entity. If you do not remove your details from where we originally processed your data it is possible we may end up processing it again with no knowledge of it having previously existed. Where this is the case we do offer an alternative that allows us to know that you have previously requested this but would mean Oscar retaining minimal information for us to identify who you are and that you have previously requested removal.


Our legal bases for processing your data

Legitimate Interests


Article 6-1-f of the GDPR states that we can process your data where “processing is necessary for the purposes of the legitimate interests pursued by the controller [Oscar] or by a third party except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data.”

As already established, Oscar is a company that provides recruitment services to candidates and clients.

From a candidate perspective where you as an individual apply directly to a role advertised by Oscar on behalf of a client, send your CV to specific Oscar consultants, or make your CV or profile available to view online or download from a job board or professional networking site, you're happy for us to collect and process your data in order to provide you with our recruitment services and provide you similar jobs suitable to you in line with our expectations.

Where you have made your personal data available within these circumstances we will also provide you with updates on similar positions on email based around a soft opt-in that is you have made your data available to us for the purposes of recruitment services including receiving updates about job opportunities that could be suitable to you.

You have the right to object to us processing your data on this basis and you can do so by clicking HERE

Where requested by the client once we have introduced you for a role we will also likely need to process further information as requested on their behalf to fulfil a contract with them. That is to provide them with reference details, criminal record and financial background checks. The collection of such personal information will be requested from you and each consultant will explain why.

From a client perspective, we will think it is reasonable to collect data relating to individual contacts of an organisation as well as keeping records of conversations (email & phone calls) meetings, jobs registered and placed with you. As a business that provides recruitment services to clients and candidates, we deem it legitimate to collect this information in order to fulfil our requirements as a profit-making business.

Contract as a legal basis for processing data


For Oscar members of staff or contractors working on client site for Oscar, we will work on the basis Contract.

The ICO states that Article 6(1)(b) gives you a lawful basis for processing where:

“processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract."

Legal Obligation as the legal basis for processing data


There may be times where Oscar has to exercise or defend a legal claim and in doing so may need to process your details for this purpose.

Article 6(1)(c) provides a lawful basis for processing where:

“processing is necessary for compliance with a legal obligation to which the controller is subject.”


How to contact us

You can get in contact with us anytime in order to discuss any of the following:

  • To access, amend or request a delete of your personal data
  • If you suspect any misuse or loss of or unauthorised access to your personal information
  • To exercise the right for you to object to the processing of your data
  • To make any suggestions or comments to us regarding this privacy policy

You can write to us at the following address:

Freetrade Exchange, Peter Street, Manchester, M2 5GB

Alternatively, you can email us:

gdpr@oscar-recruit.com

Or you can speak to us on the phone: 

0161 828 8140


How to contact your local supervisory authority

Information Commissioner's Office

Contact details:

Information Commissioner's Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

ICO Helpline: 0303 123 1113

ICO email: casework@ico.org.uk