Privacy Policy

At human Capital Recruitment, trading as we respect your privacy and understand that you care about how your data is used. As part of our ongoing commitment to be transparent about how we use your data and keep it safe, we have made some changes to this Privacy Policy. These changes address the new standards introduced by the European data protection law known as GDPR. An example of the changes we are making include how you can exercise your privacy rights and increased transparency around how and why we use your personal data. We will only collect personal data in ways that are described here and in a way that is consistent our obligations and your rights under the law.

Information About Us
We are Human Capital Recruitment, trading as andaluciatechnologyrecruiment.com, a privately-held global recruitment and consulting company registered in the United Kingdom. For further contact details and office locations, please click here. Our clients retain us to identify and place individuals into new employment opportunities. For example, we may hold your personal data as a candidate because we have identified you as an individual who could be of interest to one of our clients or we may wish to inform you of our services.   

Definitions

''Account'' means an account required to access and/or use certain areas and features of our site. Please refer to our Website Terms of Use;
''Cookie'' means a small text file placed on your computer or device by our site when you visit certain parts of our site and/or when you use certain features of our site. Please refer to our Cookie Policy; 
''We/Us/Our'' means all companies that are connected with Andalucia Technology Recruitment including Andalucia Technology Recruitment LLC; 
''Our Site'' means www.Andalucia Technology Recruitment.com
''Personal Data'' means any information about you that enables you to be identified including obvious information such as your name and contact details, but it also covers less obvious information such as electronic location data, and other online identifiers; 
''Client'' means any hiring organisation to which we offer and/or provide recruitment services;
''Candidate'' means a potential or actual candidate for a role;
''Services'' means the permanent employment services provided by Andalucia Technology Recruitment.  

What Does This Policy Cover?
This Privacy Policy explains how we use your personal data: how it is collected, how it is held, and how it is processed. This may be related to us helping you find a job, developing your career, providing you with a service that may be of interest, or as a result of you visiting our website.
We also explain your rights under the law relating to personal data to make it as easy as possible for you to control your data.

What is Personal Data?
Personal data means any information about you that enables you to be identified including obvious information such as your name and contact details, but it also covers less obvious information such as electronic location data, and other online identifiers.

What Personal Data Do We Collect?
We may collect some or all of the following personal data (this may vary according to your relationship with us) including but not limited to:

Name;
IP Address;
Home or Business Address;
Private or Business Email;
Date of Birth; Gender;
Phone Number;
Company Name;
Job Title;
Profession;
Employment / Education History;
Interview Notes;
Client Feedback; 
Salary Details.

We may also store the pertinent details of our relationship such as opportunities we have put you forward for or records of interviews you may have attended. 

Sensitive personal data is a subset of personal data and may include ethnicity, health, trade union membership, philosophical beliefs, sexual orientation, as well as other categories as prescribed by law. We do not seek to obtain and will not collect such data unless legally required for recruitment purposes. We suggest that you do not provide sensitive information of this nature. 

When Do We Collect Your Personal Data?
We usually collect personal data directly from you when you apply for a position or register with us either through our website or by contacting one of our team directly. Some personal data will be collected automatically, for example your IP address, when you use our website. Please refer to our Cookie Policy. Other data will only be collected if you voluntarily submit it, for example, when interviewing with us, registering with us, applying for jobs or sending us your CV.

We may also source your personal data in a different way; perhaps from a job board, a networking event or through LinkedIn, because we think one of our clients may be interested in your background for a specific opportunity. We may also wish to retain your data for future opportunities or because we wish to inform you about our services.

You should not refer or provide us with personal information about someone else unless with that person’s consent.  

How Do We Process Your Personal Data?
We must always have a lawful basis for processing your personal data. This may be because the data is necessary for our performance of a contract with you, because you have consented to our use of your personal data, or because it is in our legitimate business interests to use it.
We only collect and use your personal data for legitimate reasons relating to our recruitment and business consulting services. We assume that, if you are looking for new employment or have posted your CV on a job board or professional networking site, you would expect us to use your personal data to fulfil our recruitment services.

We identify and evaluate candidates for jobs agreed and approved by our clients (mostly on a retained basis), as well as for future roles that may become available. For example, we need to process your data to shortlist you for an interview, or to identify the right career opportunity for you.
Your personal data may be used for one of the following purposes:

Providing and managing your account when you register on our website, to manage your access to our site or receive job alerts, for example. 
Supplying our services to you, for example providing recruitment and consulting / coaching services.  
Personalising and tailoring our services for you.
Communicating with you. This may include responding to emails or calls from you. Recordkeeping in relation to recruiting and hiring, for example scheduling interviews or recording feedback. 
Supplying you with marketing information by email that you have opted-in to (you may unsubscribe or opt-out at any time). 

We may also use aggregate data to help us understand our users as a group so that we can provide you with a better service and provide targeted content / job adverts on our website as well as third party websites when these are visited by registered users of the Website. This data is not personally identifiable data.

Marketing Communications 
With your permission and/or where permitted by law, we may also use your personal data for marketing purposes, which may include contacting you with information, news, and insights on our services. You will not be sent any unlawful marketing or spam. We will always work to fully protect your rights and comply with our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations, and you will always have the opportunity to opt-out.

Where we have previously engaged with you (for example where you have submitted an application or CV to us) or where you have posted your details on a job board we will assume that you have given permission for us to contact you with details of opportunities we believe might be of interest to you.  You will have the right to withdraw such permission at any time and we have a privacy tool on our CRM database to manage your preferences.

Automated Decision Making 
During our processing of your information we may use functions that could be defined as automated decision making. Typically, this would be where you have submitted a CV/resume to us and we use an industry standard 3rd party product which uses complex proven semantic and natural language algorithms to “read” and extract data from the submitted document and create a profile for you in our database. This information could later be used to then match your profile against vacancy profiles also stored within our database.

However, human intervention is always involved given the subjective nature of search and selection. For clarity, we do not make recruiting or hiring decisions based solely on automated decision-making.

How Long Will We Keep Your Personal Data / Your Consent?
We will only hold your data for as long as we need to in order to use it as described above or for as long as we have your permission to keep it. As we may support candidates with placements over many years, and potentially throughout their careers, the purpose for which we retain candidate data can be ongoing. 

Typically, we intend to hold your data for no longer that 24 months before seeking consent to continue to hold your data. You may wish to remain on our database to be considered for future job opportunities. The Privacy Tool on our database allows us to monitor and control your consent preferences. If you do not give consent, we will remove your data. As an example, if we identify you as a potential candidate for a client and you do not respond within 30 days, we will delete any data we hold. 

We conduct regular data-cleansing and updating exercises with our candidates to ensure that the data that we hold is accurate and that we are not holding data for too long. We will continue to review our Retention Policy. 

How and Where Do We Store Your Personal Data?
Your data may be stored in our offices outside of the European Economic Area (“the EEA”) (The EEA consists of all EU member states, plus Norway, Iceland and Liechtenstein). If we do store data outside the EEA, we will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within the EEA and under the GDPR. We apply equal rigor to the security of data held and processed across our global network.
Please be aware that countries which are outside the European Economic Area may not offer the same level of legal protection for your personal information as under UK law, although any collection, storage and use of your personal data by us (or on our behalf) will continue to be governed by this privacy policy.

Examples of where we might store your data include, our secure company servers; computers permanently located in our premises; laptop computers and other mobile devices provided by the us to our employees; physical records stored in our office locations above; our recruitment database which is highly confidential and only accessible to our employees.

How Do We Share or Transfer Your Personal Data?
Your personal data may be accessible by, or transferred, or duplicated with other companies or employees in our group for the purposes of recruitment and consulting services. For example, your personal data may be accessed by recruiters and interviewers working in the country where the position for which you are applying is based, as well as by recruiters and interviewers working in different countries within our global organization. As another example, we may seek your consent to share your details with our clients when we wish them to consider you for a job opportunity which means we may send your information between our entities which may exist outside of Europe, to overseas clients or to clients within your country who may in turn transfer your data internationally.

We will only make your personal information visible to the organisations we are working with when you are put forward for an opportunity. We will notify you in the event we wish to explore job opportunities for you outside the European Economic Area (EEA) and we will give you the opportunity to withhold your consent.

Third Parties: We may engage or employ other companies and individuals (third parties) to perform functions on our behalf. Examples include: 

hosting and/or maintaining of our website content;
the provision of marketing services;
IT support carrying out testing and development work on our CRM system or business technology systems;  
Payment processors or local tax authorities (for our direct employees, for example)

These organisations are appointed by Andalucia Technology Recruitment data processors and authorised to use your personal information only as necessary to provide the relevant services to us.  For example, emails or our database may be hosted in the cloud. Whilst these cloud providers would not typically have direct access to your information, storage is considered processing under GDPR. These organisations are required to process such information based on our instructions and in accordance with this Privacy Policy. If any of your personal data is required by a third party, as described above, we will take steps to ensure that your personal data is handled safely, securely, and in accordance with your rights, our obligations, and the third party’s obligations under the law.

In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if you are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.

What Are Your Rights?
We take reasonable steps designed to keep your personal data accurate, complete, and up-to-date for the purposes for which it is collected and used. We also have implemented measures that are designed to ensure that our processing of your personal data complies with this Privacy Policy and applicable law. Under the GDPR, you have the following rights, which we will always aim to uphold:

The right to be informed about our collection and use of your personal data.
The right to access the personal data we hold about you, sometimes knows as a ‘subject access request’.
The right to have your personal data rectified.
The right to ask us to delete or dispose of any of your personal data that we have.
The right to restrict (i.e. prevent) the processing of your personal data.
The right to object to us using your personal data for a particular purpose.
The right to data portability.
Rights relating to automated decision-making and profiling.
The right to lodge a complaint if you are unhappy about our use of your personal data.

Data Security
The security of your personal data is of great importance to us, and to protect your data we have put in place suitable physical, electronic and managerial procedures to safeguard and secure data collected and processed by us. Examples include (but not limited to):

all employees and other parties working on behalf of Andalucia Technology Recruitment are made fully aware of both their individual responsibilities and the company’s responsibilities under the GDPR and under the company’s Data Protection Policy;
only employees and other parties working on behalf of the company that need access to, and use of, personal data in order to perform their work shall have access to personal data held by us;
all personal data stored electronically is backed up, with backups stored securely;
passwords used to protect personal data are changed regularly and secure.

Notwithstanding the security measures that we take, it is important to remember that the transmission of data via the internet may not be completely secure and that you are advised to take suitable precautions when transmitting to us data via the internet.

Cookies and Websites
Our site may place and access certain first party cookies on your computer or device. First party cookies are those placed directly by us and are used only by us. We use cookies to facilitate and improve your experience of our site and to provide and improve our services.  Our site also uses analytics services, for example Google Analytics, which also use cookies. Website analytics refers to a set of tools used to collect and analyse usage statistics, enabling us to better understand how people use our site. You may access our site without providing any data at all. However, to use all features and functions available on our site you may be required to submit or allow for the collection of certain data. You may restrict your internet browser’s use of cookies. For more details, please refer to our Cookie Policy.

Our website may also link or direct you to other websites or external content which are not within our control. Links to other websites may be provided for your convenience and information. While we will use our best endeavor to ensure that we link or direct you only to websites that share our privacy and security standards, we are not in the position to guarantee the same and we will not be responsible for the protection and privacy of any personal data which you provide on those websites. These sites have their own privacy statement in place, and we recommend you review these if you visit any linked website. You should therefore exercise caution including reviewing the privacy policy of those websites before disclosing any personal data.
We may compile statistics about the use of our website including data on traffic, usage patterns, user numbers, sales and other information. All such data will be anonymised and will not include any personally identifying information.

How Can You Control Your Data?
We want you to feel in control of your personal data. When you submit information via our site, you may be given options to restrict our use of your data. We also aim to give you strong controls on our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from us which you may do by unsubscribing using the links provided in our emails or by managing your account).
You have the right to: be informed about our collection and use of your personal data; access the personal data we hold about you, sometimes knows as a ‘subject access request’; have your personal data rectified; ask us to delete or dispose of any of your personal data that we have; restrict (i.e. prevent) the processing of your personal data; object to us using your personal data for a particular purpose; data portability; make changes relating to automated decision-making and profiling; lodge a complaint if you are unhappy about our use of your personal data.

How Can You Access and / or Remove Your Data?
You have the legal right to ask for a copy of any of your personal data held by us at any time. This is sometimes known as a ‘subject access request’.  You can also contact us to request for your account to be closed or for your personal data to be deleted at any time.  If you need assistance accessing, updating, correcting or removing your personal information from our systems, or if you no longer desire our services, please e-mail us using the details below.  We aim to respond to all data related requests within 48 hours of receiving your request.

How Do I Contact You?
If you have any questions about anything to do with your personal data and data protection, please contact Derek A Langley, Director derek@and-rec-net or by telephone on +44 7770 654100

Changes to this Privacy Policy
We may change this Privacy Policy from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection. Any changes we may make to our Privacy Policy in the future will be posted on this page so please check back frequently to see any updates or changes.