Privacy Notice

 

Introduction

This Privacy Policy explains what we do with your personal data, whether we are in the process of helping you find a job, continuing our relationship with you once we have found you a role, 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 our website.

It describes how we collect, use and process your personal data, and how, in doing so, we comply with our legal obligations to you. Your privacy is important to us, and we are committed to protecting and safeguarding your data privacy rights.

This Privacy Policy applies to the personal data of our website users, candidates, clients, suppliers, and other people whom we may contact in order to find out more about our candidates or whom they indicate is an emergency contact. It also applies to the emergency contacts of our staff. To be clear, if you are a member of Arthur’ Staff, you should refer to the Arthur’ Staff Privacy Policy which is available on the Arthur Policy Folder.

For the purpose of applicable data protection legislation (including but not limited to the General Data Protection Regulation (Regulation (EU) 2016/679) (the “GDPR”), the company responsible for your personal data (“Arthur” or “us”) can be found in the how to contact us section.

It is important to point out that we may amend this Privacy Policy from time to time. Please just visit the website if you want to stay up to date, as we will post any changes here.

If you are dissatisfied with any aspect of our Privacy Policy, you may have legal rights and, where relevant, we have described these as well.

This Privacy Policy applies in relevant countries throughout our international network. Different countries may approach data privacy in slightly different ways and so we also have country-specific parts to this Privacy Policy.

 

What kind of personal data do we collect?

So you’re looking for a bit more insight into what data we collect about you? Here’s a more detailed look at the information we may collect. The information described below is, of course, in addition to any personal data we are required by law to process in any given situation.

 

Candidate Data

Depending on the relevant circumstances and applicable local laws and requirements, we may collect some or all of the information listed below to enable us to offer you employment opportunities which are tailored to your circumstances and your interests. In some jurisdictions, we are restricted from processing some of the data outlined below. In such cases, we will not process the data in those jurisdictions:

 

Name;

  • Age/date of birth;
  • Birth number;
  • Sex/gender;
  • Photograph;
  • Marital status;
  • Contact details;
  • Education details;
  • Employment history;
  • Emergency contacts and details of any dependents;
  • Referee details;
  • Immigration status (whether you need a work permit);
  • Nationality/citizenship/place of birth;
  • A copy of your driving license and/or passport/identity card;
  • Financial information (where we need to carry out financial background checks);
  • Social security number (or equivalent in your country) and any other tax-related information;
  • Diversity information including racial or ethnic origin, religious or other similar beliefs, and physical or mental health, including disability-related information;
  • Details of any criminal convictions if this is required for a role that you are interested in applying for;
  • Details about your current remuneration, pensions and benefits arrangements;
  • Information on your interests and needs regarding future employment, both collected directly and inferred, for example from jobs viewed or articles read on our website;
  • Extra information that you choose to tell us;
  • Extra information that your referees chooses to tell us about you;
  • Extra information that our clients may tell us about you, or that we find from other third-party sources such as job sites;
  • IP address;
  • The dates, times and frequency with which you access our services; and
  • CCTV footage if you attend our premises.

Please note that the above list of categories of personal data we may collect is not exhaustive.

 

Client Data

The data we collect about clients is actually very limited. We generally only need to have your contact details or the details of individual contacts at your organisation (such as their names, telephone numbers and email addresses) to enable us to ensure that our relationship runs smoothly

If you are an Arthur customer, we need to collect and use information about you, or individuals at your organisation, in the course of providing you services such as:

(i)     Finding candidates who are the right fit for you or your organisation;

(ii)    Providing you with a Managed Service Provider (“MSP”) programme (or assisting another organisation to do so);

(iii)   Providing you with Recruitment Process Outsourcing (“RPO”) services (or assisting another organisation to do so); and/ornotifying you of content published by Us which is likely to be relevant and useful to you (for example our Industry updates).

We also hold information relating to your online engagement with candidate profiles and other material published by Arthur, which we use to ensure that our marketing communications to you are relevant and timely.

We may also hold extra information that someone in your organisation has chosen to tell us.

To the extent that you access our website we will also collect certain data from you. If you would like more information about this, please see the website section below.

 

Supplier Data

We need a small amount of information from our suppliers to ensure that things run smoothly. We need contact details of relevant individuals at your organisation so that we can communicate with you. We also need other information such as your bank details so that we can pay for the services you provide (if this is part of the contractual arrangements between us).

To the extent that you access our website we will also collect certain data from you. If you would like more information about this, please see the website section below.

 

People whose data we receive from candidates and staff, such as referees and emergency contacts

In order to provide candidates with suitable employment opportunities safely and securely and to provide for every eventuality for them and our Staff, we need some basic background information.

We only ask for very basic contact details, so that we can get in touch with you either for a reference or because you’ve been listed as an emergency contact for one of our candidates or Staff members.

 

Website users

We collect a limited amount of data from our website users which we use to help us to improve your experience when using our website and to help us manage the services we provide.

This includes information, such as how you use our website, the frequency with which you access our website, your browser type, the location you view our website from, the language you choose to view it in and the times that our website is most popular

 

Additional Information

A number of elements of the personal data we collect from you are required to enable us to fulfil our contractual duties to you or to others. Where appropriate, some, for example candidates’ passport number and, religious affiliation, are required by statute or other laws. Other items may simply be needed to ensure that our relationship can run smoothly.

Depending on the type of personal data in question and the grounds on which we may be processing it, should you decline to provide us with such data, we may not be able to fulfil our contractual requirements or, in extreme cases, may not be able to continue with our relationship.

 

How do we collect your personal data?

 

Candidate Data

There are two main ways in which we collect your personal data:

(i)     Directly from you; and

(ii)    From third parties.

 

Personal data you give to us:

Arthur needs to know certain information about you in order to provide a tailored service. This will enable us to provide you with the best opportunities, and should save you time in not having to trawl through information about jobs and services that are not relevant to you

There are numerous ways you can share your information with us. It all depends on what suits you. These may include;

(i)     Entering your details on the Arthur website or via an application form, as part of the registration process;

(ii)    Leaving a hard copy CV at an Arthur recruitment event, job fair or office;

(iii)   Emailing your CV to an Arthur consultant or being interviewed by them;

(iv)   Applying for jobs through a job aggregator, which then redirects you to the Arthur website;

(v)    Personal data we receive from other sources

 

We also receive personal data about candidate from other sources. Depending on the relevant circumstances and applicable local laws and requirements, these may include personal data received in the following situations:

(i)     Your referees may disclose personal information about you;

(ii)    Our clients may share personal information about you with us;

(iii)   We may obtain information about you from searching for potential Candidate from third party sources, such as LinkedIn and other job sites;

(iv)   We may be sent your information from a Third Party who has found your CV on External job boards, such as Job site.

(v)    If you ‘like’ our page on Facebook or ‘follow’ us on Twitter we will receive your personal information from those sites; and

To the extent that you access our website or read or click on an email from us, we may also collect certain data automatically or through you providing it to us. For more information please see the website section below.

 

Client Data

There are two main ways in which we collect your personal data:

(i)     Directly from you; and

(ii)    From third parties (e.g. our candidates) and other limited sources (e.g. online and offline media).

We both share the same goal, to make sure that you have the best staff for your organisation. We will receive data directly from you in two ways:

(i)     Where you contact us proactively, usually by phone or email; and/or

(ii)    Where we contact you, either by phone or email, or through our consultants’ business development activities more generally.

 

Personal data we receive from other sources:

Where appropriate and in accordance with any local laws and requirements, we may seek more information about you or your colleagues from other sources generally by way of due diligence or other market intelligence including:

(i)     From delegate lists at relevant events; and

(ii)    From other limited sources and third parties (for example from our candidates to the extent that they provide us with your details to act as a referee for them).

To the extent that you access our website or read or click on an email from us, we may also collect certain data automatically or through you providing it to us. For more information please see the website section below.

 

Supplier Data

We collect your personal data during the course of our work with you.

To the extent that you access our website or read or click on an email from us, we may also collect certain data automatically or through you providing it to us. For more information please see the website section below.

 

People whose data we receive from candidates and staff, such as referees and emergency contacts

We collect your contact details only where a candidate or a member of our Staff puts you down as their emergency contact or where a candidate gives them to us in order for you to serve as a referee.

 

Website users

When you visit our website, there is certain information that we may automatically collect, whether or not you decide to use our services. This includes your IP address, the date and the times and frequency with which you access the website and the way you browse its content.

We collect your data automatically via cookies, in line with cookie settings in your browser. If you are also a candidate or client of Arthur, we may use data from your use of our websites to enhance other aspects of our communications with or service to you. If you would like to find out more about cookies, including how we use them and what choices are available to you, please see the how to reject cookies section below

 

How do we use your personal data?

 

Candidate data

The main reason for using your personal details is to help you find employment or other work roles that might be suitable for you.

The more information we have about you, your skillset and your ambitions, the more bespoke we can make our service.

 

We generally use candidate data in five ways:

(i)     Recruitment Activities;

(ii)    Marketing Activities;

(iii)   Equal Opportunities Monitoring;

(iv)   To help us to establish, exercise or defend legal claims.

(v)    In appropriate circumstances in the future, we may also use Candidate data for Profiling.

 

Recruitment Activities:

Obviously, our main area of work is recruitment, connecting the right candidates with the right jobs. We’ve listed below various ways in which we may use and process your personal data for this purpose, where appropriate and in accordance with any local laws and requirements. Please note that this list is not exhaustive.

  • Collecting your data from you and other sources, such as LinkedIn;
  • Storing your details (and updating them when necessary) on our database, so that we can contact you in relation to recruitment;
  • Providing you with our recruitment services and to facilitate the recruitment process;
  • Assessing data about you against vacancies which we think may be suitable for you;
  • Sending your information to clients, in order to apply for jobs or to assess your eligibility for jobs;
  • Enabling you to submit your CV, apply online for jobs or to subscribe to alerts about jobs we think may be of interest to you;
  • Allowing you to participate in specialist online training;
  • Allowing you to participate in the interactive features of our services, when you choose to do so;
  • Carrying out our obligations arising from any contracts entered into between us;
  • Carrying out our obligations arising from any contracts entered into between Arthur and third parties in relation to your recruitment;
  • Facilitating our payroll and invoicing processes;
  • Carrying out customer satisfaction surveys;
  • Verifying details, you have provided, using third party resources (such as psychometric evaluations or skills tests), or to request information (such as references, qualifications and potentially any criminal convictions, to the extent that this is appropriate and in accordance with local laws);
  • Complying with our legal obligations in connection with the detection of crime or the collection of taxes or duties; and
  • Processing your data to enable us to send you targeted, relevant marketing materials or other communications which we think are likely to be of interest to you.

We may use your personal data for the above purposes if we deem it necessary to do so for our legitimate interests. If you are not happy about this, in certain circumstances you have the right to object

 

Marketing Activities:

We may periodically send you information that we think you may find interesting, or to ask for your help with connecting other candidates with jobs. In particular, we may wish to use your data for the purposes listed below, where appropriate and in accordance with any local laws and requirements. Please note that this list is not exhaustive. To:

(i)     Enable us to develop and market other products and services;

(ii)    Market our full range of recruitment services (permanent, temporary, contract, outplacement, MSP programmes) to you;

(iii)   Send you details of reports, offers, networking and client events, and general information about the industry sectors which we think might be of interest to you;

 

We need your consent for some aspects of these activities which are not covered by our legitimate interests (in particular, the collection of data via cookies, and the delivery of direct marketing to you through digital channels) and, depending on the situation, we’ll ask for this via an opt-in or soft-opt-in (which we explain further below).

Soft opt-in consent is a specific type of consent which applies where you have previously engaged with us (for example by submitting a job application or CV, or registering a vacancy to be filled), and we are marketing other recruitment-related services.

  • Under ‘soft opt-in’ consent, we will take your consent as given unless or until you opt out. For most people, this is beneficial as it allows us to suggest other jobs to you alongside the specific one you applied for, significantly increasing the likelihood of us finding you a new position.
  • For other types of e-marketing, we are required to obtain your explicit consent.

 

If you are not happy about our approach to marketing, you have the right to withdraw your consent at any time. Nobody’s perfect, even though we try to be.

We want to let you know that even if you have opted out from our marketing communications, it is possible that your details may be recaptured through public sources in an unconnected marketing campaign. We will try to make sure this doesn’t happen, but if it does, we’re sorry. We’d just ask that in those circumstances you opt out again.

All our marketing is based on what we think will serve our clients and candidates best, but we know we won’t always get it right for everyone. We may use your data to show you Arthur adverts and other content on other websites, for example Facebook.

If you do not want us to use your data in this way, please turn off the “Advertising Cookies” option (please refer to our Cookies Policy). Even where you have turned off advertising cookies, it is still possible that you may see an Arthur advert, but in this case it won’t have been targeted at you personally, but rather at an anonymous audience.

 

Equal opportunities monitoring and other sensitive personal data

We are committed to ensuring that our recruitment processes are aligned with our approach to equal opportunities.

Some of the data we may (in appropriate circumstances and in accordance with local law and requirements) collect about you comes under the umbrella of “diversity information”. This could be information about your ethnic background, gender, disability, age, sexual orientation, religion or other similar beliefs, and/or social-economic background.

Where appropriate and in accordance with local laws and requirements, we’ll use this information on an anonymised basis to monitor our compliance with our equal opportunities policy.

We may also disclose this (suitably anonymised where relevant) data to clients where this is contractually required or the client specifically requests such information to enable them to comply with their own employment processes.

This information is what is called ‘sensitive’ personal information and slightly stricter data protection rules apply to it. We therefore need to obtain your explicit consent before we can use it. We’ll ask for your consent by offering you an opt-in. This means that you have to explicitly and clearly tell us that you agree to us collecting and using this information.

We may collect other sensitive personal data about you, such as health-related information, religious affiliation, or details of any criminal convictions if this is appropriate in accordance with local laws and is required for a role that you are interested in applying for. We will never do this without your explicit consent.

If you are not happy about this, you have the right to withdraw your consent at any time and you can find out how to do so below.

 

To help us to establish, exercise or defend legal claims

In more unusual circumstances, we may use your personal data to help us to establish, exercise or defend legal claims.

 

Profiling

Although at present all our recruitment activities involve human-decision making during the process, we may in the future use fully automated technologies such as expert systems or machine learning to complete a Candidate selection process from end-to-end, where appropriate and in accordance with any local laws and requirements.

Where appropriate, we will seek your consent to carry out some or all of these activities. If you do not provide consent to profiling, your application will continue to be reviewed manually for opportunities you apply for, but your profile will not be automatically considered for alternative roles. This is likely to decrease the likelihood of us successfully finding you a new job.

Where we use software to assist us with our assessment of your suitability for a particular job role and you consider that any such assessment has been made wrongly or incorrectly, you may ask for an explanation.

 

Client data

The main reason for using information about clients is to ensure that the contractual arrangements between us can properly be implemented so that the relationship can run smoothly.

 

We use client information for:

(i)     Recruitment Activities;

(ii)    Marketing Activities;

(iii)   To help us to establish, exercise or defend legal claims.

 

Recruitment Activities

This may involve:

  •  Identifying candidates who we think will be the right fit for you or your organisation;
  • Providing you with an MSP programme (or assisting another organisation to do so);
  • Providing you with RPO services (or assisting another organisation to do so). The more information we have, the more bespoke we can make our service.

 

We’ve listed below the various ways in which we use your data in order to facilitate this

  • Storing your details (and updating them when necessary) on our database, so that we can contact you in relation to recruitment activities;
  • Keeping records of our conversations and meetings, so that we can provide targeted services to you;
  • Undertaking customer satisfaction surveys; and
  • Processing your data for the purpose of targeting appropriate marketing campaigns.

We may use your personal data for these purposes if we deem this to be necessary for our legitimate interests. If you would like to know more about what this means, please see below on the legitimate interest section.

If you are not happy about this, in certain circumstances you have the right to object and can find out more about how and when to do this below

 

Marketing Activities

Subject to any applicable local laws and requirements, we will not, as a matter of course, seek your consent when sending marketing materials such as our Global Skills Index to a corporate postal or email address.

 

To help us to establish, exercise or defend legal claims

In more unusual circumstances, we may use your personal data to help us to establish, exercise or defend legal claims.

 

Supplier data

The main reasons for using your personal data are to ensure that the contractual arrangements between us can properly be implemented so that the relationship can run smoothly, and to comply with legal requirements.

 

People whose data we receive from candidates and staff, such as referees and emergency contacts

We will only use the information that our candidate gives us about you for the following purposes

  • If our candidates or Staff members put you down on our form as an emergency contact, we’ll contact you in the case of an accident or emergency affecting them; or
  • If you were put down by our candidate or a prospective member of Staff as a referee, we will contact you in order to take up a reference. This is an important part of our candidate quality assurance process, and could be the difference between the individual getting a job or not.
  • If you were put down by our Candidate or a prospective member of Staff as a referee, we may sometimes use your details to contact you in relation to recruitment activities that we think may be of interest to you, in which case we will use your data for the
  • Same purposes for which we use the data of clients.

We may use your personal data for these purposes if we deem this to be necessary for our legitimate interests.

If you are not happy about this, you have the right to object and can find out more about how to do so below.

 

Website users

We use your data to help us to improve your experience of using our website, for example by analysing your recent job search criteria to help us to present jobs to you that we think you’ll be interested in. If you are also a Candidate or Client of Arthur, we may use data from your use of our websites to enhance other aspects of our communications with, or service to, you.

Please note that communications to and from Arthur’ Staff including emails may be reviewed as part of internal or external investigations or litigation.

 

Who do we share your personal data with?

 

Candidate Data

We may share your personal data with various parties, in various ways and for various reasons.

Primarily we will share your information with prospective employers to increase your chances of securing the job you want.

If you would like to see a list of who we may share your personal data with, please see below:

(i)     Clients Companies; For appropriate roles and opportunities

(ii)    Vision: To format your CV to ensure it is presented in the strongest light and in some case in accordance of contractual agreement.

(iii)   Internally: with other members of Staff who may have relevant jobs for you.

 

Client data

We will share your data:

(i)     Primarily to ensure that we provide you with a suitable pool of candidates

(ii)    To provide you with an MSP programme (or assist another organisation to do so)

(iii)   To provide you with RPO services (or assist another organisation to do so).

Unless you specify otherwise, we may share your information with any of our group companies and associated third parties such as our service providers to help us meet these aims.

 

Supplier data

Unless you specify otherwise, we may share your information with any of our group companies and associated third parties such as our service providers and organisations to whom we provide services.

 

People whose data we receive from candidates and staff, such as referees and emergency contacts

Unless you specify otherwise, we may share your information with any of our group companies and associated third parties such as our service providers and organisations to whom we provide services.

 

Website users

Unless you specify otherwise, we may share your information with providers of web analytics services, marketing automation platforms and social media services to make sure any advertising you receive is targeted to you.

 

How do we safeguard your personal data?

 

We are committed to taking all reasonable and appropriate steps to protect the personal information that we hold from misuse, loss, or unauthorised access. We do this by having in place a range of appropriate technical and organisational measures. These include measures to deal with any suspected data breach.

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

 

How long do we keep your personal data for?

 

If we have not had meaningful contact with you (or, where appropriate, the company you are working for or with) for a period of three years (Candidate) four years (Client), we will delete your personal data from our systems unless we believe in good faith that the law or other regulation requires us to preserve it (for example, because of our obligations to tax authorities or in connection with any anticipated litigation).

 

How can you access, amend or take back the personal data that you have given to us?

 

One of the GDPR’s main objectives is to protect and clarify the rights of EU citizens and individuals in the EU with regards to data privacy. This means that you retain various rights in respect of your data, even once you have given it to us. These are described in more detail below.

Even if we already hold your personal data, you still have various rights in relation to it. To get in touch about these, please contact us or see our website for the SAR form. We will seek to deal with your request without undue delay, and in any event in accordance with the requirements of any applicable laws.

Please note that we may keep a record of your communications to help us resolve any issues which you raise. Right to requests information are:

 

Right to object:

If we are using your data because we deem it necessary for our legitimate interests to do so, and you do not agree, you have the right to object. We will respond to your request within 30 days (although we may be allowed to extend this period in certain cases). Generally, we will only disagree with you if certain limited conditions apply.

“Legitimate interests” are likely to apply to our website users, candidates, clients and suppliers. If your objection relates to us processing your personal data because we deem it necessary for your legitimate interests, we must act on your objection by ceasing the activity in question unless:

(i)     We can show that we have compelling legitimate grounds for processing which overrides your interests; or

(ii)    We are processing your data for the establishment, exercise or defence of a legal claim.

 

Right to withdraw consent

Where we have obtained your consent to process your personal data for certain activities (for example, sending your profile to a client for a position), or consent to market to you, you may withdraw your consent at any time.

 

Data Subject Access Requests (DSAR)

Just so it’s clear, you have the right to ask us to confirm what information we hold about you at any time, and you may ask us to modify, update or delete such information. At this point we may comply with your request or, additionally do one of the followings:

(i)     We may ask you to verify your identity, or ask for more information about your request

(ii)    If we provide you with access to the information we hold about you, we will not charge you for this unless your request is “manifestly unfounded or excessive”.

(iii)   If you request further copies of this information from us, we may charge you a reasonable administrative cost where legally permissible

(iv)   Where we are legally permitted to do so, we may decline your request, but we will explain why if we do so.

 

Right to erasure

In certain situations (for example, where we have processed your data unlawfully), you have the right to request us to “erase” your personal data. We will respond to your request within 30 days (although we may be allowed to extend this period in certain cases) and will only disagree with you if certain limited conditions apply.

Normally, the information must meet one of the following criteria:

(i)     The data are no longer necessary for the purpose for which we originally collected and/or processed them;

(ii)    Where previously given, you have withdrawn your consent to us processing your data, and there is no other valid reason for us to continue processing;

(iii)   The data has been processed unlawfully (i.e. in a manner which does not comply with the GDPR);

(iv)   It is necessary for the data to be erased in order for us to comply with our legal obligations as a data controller

(v)    If we process the data because we believe it necessary to do so for our legitimate interests, you object to the processing and we are unable to demonstrate overriding legitimate grounds for our continued processing.

 

We would only be entitled to refuse to comply with your request for one of the following reasons:

(i)     To exercise the right of freedom of expression and information;

(ii)    To comply with legal obligations or for the performance of a public interest task or exercise of official authority;

(iii)   For public health reasons in the public interest;

(iv)   For archival, research or statistical purposes; or

(v)    To exercise or defend a legal claim.

(vi)   When complying with a valid request for the erasure of data we will take all reasonably practicable steps to delete the relevant data.

If we do agree to your request, we will delete your data but will generally assume that you would prefer us to keep a note of your name on our register of individuals who would prefer not to be contacted. That way, we will minimise the chances of you being contacted in the future where your data are collected in unconnected circumstances. If you would prefer us not to do this, you are free to say so.

 

Right to restrict processing

You have the right to request that we restrict our processing of your personal data in certain circumstances. This means that we can only continue to store your data and will not be able to carry out any further processing activities with it until either:

(i)     One of the circumstances listed below is resolved;

(ii)    You consent

(iii)   Further processing is necessary for either the establishment, exercise or defense of legal claims, the protection of the rights of another individual, or reasons of important EU or Member State public interest.

 

The circumstances in which you are entitled to request that we restrict the processing of your personal data are:

  • Where you dispute the accuracy of the personal data that we are processing about you. In this case, our processing of your personal data will be restricted for the period during which the accuracy of the data is verified;
  • Where you object to our processing of your personal data for our legitimate interests. Here, you can request that the data be restricted while we verify our grounds for processing your personal data;
  • Where our processing of your data is unlawful, but you would prefer us to restrict our processing of it rather than erasing it; and
  • Where we have no further need to process your personal data but you require the data to establish, exercise, or defend legal claims.

If we have shared your personal data with third parties, we will notify them about the restricted processing unless this is impossible or involves disproportionate effort. We will, of course, notify you before lifting any restriction on processing your personal data.

 

Right to rectification

 You also have the right to request that we rectify any inaccurate or incomplete personal data that we hold about you.

If we have shared this personal data with third parties, we will notify them about the rectification unless this is impossible or involves disproportionate effort.

Where appropriate, we will also tell you which third parties we have disclosed the inaccurate or incomplete personal data to.

Where we think that it is reasonable for us not to comply with your request, we will explain our reasons for this decision.

 

Right of data portability

If you wish, you have the right to transfer your data from us to another data controller. We will help with this – either by directly transferring your data for you, or by providing you with a copy in a commonly used machine-readable format.

 

This right of data portability applies to:

(i)     Personal data that we process automatically (i.e. without any human intervention);

(ii)    Personal data provided by you;

(iii)   Personal data that we process based on your consent or in order to fulfil a contract.

 

Right to lodge a complaint with a supervisory authority

You also have the right to lodge a complaint with your local supervisory authority, details of which can be found below.

 

Marketing material

If your interests or requirements change, you can unsubscribe from part or all of our marketing content (for example job role emails or Arthur newsletters) by clicking the unsubscribe link in the email,

If you would like to exercise any of these rights or withdraw your consent to the processing of your personal data (where consent is our legal basis for processing your personal data), details of how to contact us can be found below. Please note that we may keep a record of your communications to help us resolve any issues which you raise.

 

How do we store and transfer your data internationally?

 

How do we transfer your data internationally:

  • Encrypted Email

 

In order to provide you with the best service and to carry out the purposes described in this Privacy Policy, your data may be transferred:

  • Between and within Arthur entities;
  • Bullhorn – Our CRM
  • Encrypted Email – From your interaction with Arthur Ltd
  • To third parties, such as Vision (overseas), who format your CV’s
  • To overseas clients;
  • To clients within your country who may, in turn, transfer your data internationally;
  • To a cloud-based storage provider (Sync)

 

We want to make sure that your data are stored and transferred in a way which is secure. We will therefore only transfer data outside of the European Economic Area or EEA (i.e. the Member States of the European Union, together with Norway, Iceland and Liechtenstein) where it is compliant with data protection legislation and the means of transfer provides adequate safeguards in relation to your data, for example:

  • By way of data transfer agreement, incorporating the current standard contractual clauses adopted by the European Commission for the transfer of personal data by data controllers in the EEA to data controllers and processors in jurisdictions without adequate data protection laws
  • By signing up to the EU-U.S. Privacy Shield Framework for the transfer of personal data from entities in the EU to entities in the United States of America or any equivalent agreement in respect of other jurisdictions
  • Transferring your data to a country where there has been a finding of adequacy by the European Commission in respect of that country’s levels of data protection via its legislation
  • Where it is necessary for the conclusion or performance of a contract between ourselves and a third party and the transfer is in your interests for the purposes of that contract (for example, if we need to transfer data outside the EEA in order to meet our obligations under that contract if you are a Client of ours); or
  • Where you have consented to the data transfer.

 

To ensure that your personal information receives an adequate level of protection, we have put in place appropriate procedures with the third parties we share your personal data with to ensure that your personal information is treated by those third parties in a way that is consistent with and which respects the law on data protection.

 

Who is responsible for processing your personal data on the Arthur website?

 

Arthur controls the processing of personal data on its website(s).

 

What are cookies and how do we use them?

 

A “cookie” is a bite-sized piece of data that is stored on your computer’s hard drive. They are used by nearly all websites and do not harm your system.

We use them to track your activity to help ensure you get the smoothest possible experience when visiting our website. We can use the information from cookies to ensure we present you with options tailored to your preferences on your next visit. We can also use cookies to analyse traffic and for advertising purposes.

If you want to check or change what types of cookies you accept, this can usually be altered within your browser settings. We also provide information about this on our website under our cookies policy

 

How to reject cookies

 If you don’t want to receive cookies that are not strictly necessary to perform basic features of our site, you may choose to opt-out by changing your browser settings

Most web browsers will accept cookies but if you would rather we didn’t collect data in this way you can choose to accept all or some or reject cookies in your browser’s privacy settings. However, rejecting all cookies means that you may not be able to take full advantage of all our website’s features. Each browser is different, so check the “Help” menu of your browser to learn how to change your cookie preferences.

For more information generally on cookies, including how to disable them, please refer to aboutcookies.org. You will also find details on how to delete cookies from your computer.

  

Our legal basis for processing your data

 

 Legitimate interests

  • Article 6(1)(f) of the GDPR is the one that is relevant here – it says that we can process your data where it “is necessary for the purposes of the legitimate interests pursued by [us] or by a third party, except where such interests are overridden by the interests or fundamental rights or freedoms of [you] which require protection of personal data.”
  • We don’t think that any of the following activities prejudice individuals in any way – in fact, they help us to offer you a more tailored, efficient service, so everyone’s a winner! However, you do have the right to object to us processing your personal data on this basis.

 

Candidate Data

Given that we operate in a niche market, Insurance& FX and recruit in niche specialisms (Risk, Actuarial, Compliance, Cat & Exposure Management, Underwriting, Broking, Claims, Operations, Data Science, ) we think it reasonable to expect that if you are looking for employment now or in the future or have posted your professional CV information on a job board or professional networking site, you are happy for us to collect and otherwise use your personal data to offer or provide our recruitment services to you, share that information with prospective employers and assess your skills against our bank of vacancies.

Once it’s looking like you may get the job, your prospective employer may also want to double check any information you’ve given us (such as the results from psychometric evaluations or skills tests) or to confirm your references, qualifications and criminal record, to the extent that this is appropriate and in accordance with local laws. We need to do these things so that we can function as a profit-making business, and to help you and other candidates get the jobs you deserve.

We want to provide you with tailored job recommendations and relevant articles to read to help you on your job hunt. We therefore think it’s reasonable for us to process your data to make sure that we send you the most appropriate content.

We have to make sure our business runs smoothly, so that we can carry on providing specialist services to candidates like you. We therefore also need to use your data for our internal administrative activities, like payroll and invoicing where relevant.

We have our own obligations under the law, which it is a legitimate interest of ours to insist on meeting! If we believe in good faith that it is necessary, we may therefore share your data in connection with crime detection, tax collection or actual or anticipated litigation.

 

Client data

 To ensure that we provide you with the best service possible, we store your personal data and/or the personal data of individual contacts at your organisation as well as keeping records of our conversations, meetings, registered jobs and placements.

From time to time, we may also ask you to undertake a customer satisfaction survey. We think this is reasonable – we deem these uses of your data to be necessary for our legitimate interests as an organisation providing various recruitment services to you.

 

Supplier data

We use and store the personal data of individuals within your organisation in order to facilitate the receipt of services from you as one of our suppliers.

We also hold your financial details, so that we can pay you for your services. We deem all such activities to be necessary within the range of our legitimate interests as a recipient of your services.

 

People whose data we receive from candidates and staff, such as referees and emergency contacts

If you have been put down by a candidate or a prospective member of Staff as one of their referees, we use your personal data in order to contact you for a reference.

This is a part of our quality assurance procedure and so we deem this to be necessary for our legitimate interests as an organisation offering recruitment services and employing people ourselves.

If a candidate or staff member has given us your details as an emergency contact, we will use these details to contact you in the case of an accident or emergency. We are sure you will agree that this is a vital element of our people-orientated organisation, and so is necessary for our legitimate interests.

 

Explicit consent

In certain circumstances, we are required to obtain your consent to the processing of your personal data in relation to certain activities, for example sending your profile to a role. Depending on exactly what we are doing with your information, this consent will be opt-in consent or soft opt-in consent.

Article 4(11) of the GDPR states that (opt-in/explicit) consent is “any freely given, specific, informed and unambiguous indication of the data subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.” In plain language, this means that:

  • You have to give us your consent freely, without us putting you under any type of pressure
  • You have to know what you are consenting to – so we’ll make sure we give you enough information
  • You should have control over which processing activities you consent to and which you don’t.
  • You need to take positive and affirmative action in giving us your consent – you will likely provide email or verbal consent, where we will tick box on our CRM so it is clear and unambiguous.

We will keep records of the consents that you have given in this way.

We have already mentioned that, in some cases, we will be able to rely on soft opt-in consent. We are allowed to market products or services to you which are related to the recruitment services we provide as long as you do not actively opt-out from these communications.

As we have mentioned, you have the right to withdraw your consent to these activities. You can do so at any time

 

Establishing, exercising or defending legal claims

Sometimes it may be necessary for us to process personal data and, where appropriate and in accordance with local laws and requirements, sensitive personal data in connection with exercising or defending legal claims.

Article 9(2)(f) of the GDPR allows this where the processing “is necessary for the establishment, exercise or defense of legal claims or whenever courts are acting in their judicial capacity”.

This may arise for example where we need to take legal advice in relation to legal proceedings or are required by law to preserve or disclose certain information as part of the legal process.

 

Annex 1 – How to contact us

 

You can write to us at the following address:

Arthur Ltd

0203 5877 234

No. 6 Lloyd’s Avenue, London, EC3N 3AX

Arthur.co.uk

 

Alternatively, you can send an email to: gdpr@arthur.co.uk

 

Get in touch with us:

  • To access, amend or take back the personal data that you have given to us;
  • If you suspect any misuse or loss of or unauthorised access to your personal information;
  • To withdraw your consent to the processing of your personal data (where consent is the legal basis on which we process your personal data);
  • With any comments or suggestions concerning this Privacy Policy

 

 

Annex 2 – How to contact your local supervisory authority

Details of your local supervisory authority: The Information Commissioner’s Office.

 

You can contact them in the following ways:

Phone: 0303 123 1113

 

Email: casework@ico.org.uk

 

Live chat.

 

Post: Information Commissioner’s Office

Wycliffe House

Water Lane

Wilmslow

Cheshire

SK9 5AF

 

Glossary

 

Candidates

Includes applicants for all roles advertised or promoted by Arthur, including permanent, part-time and temporary positions and freelance roles with Arthur’ clients; as well as people who have supplied a speculative CV to Arthur not in relation to a specific job.

Individual contractors, freelance workers and employees of suppliers or other third parties put forward for roles with Arthur, clients as part of an MSP offering or otherwise will be treated as candidates for the purposes of this Privacy Policy.

 

Clients

While it speaks for itself, this category covers our customers, clients, and others to whom Arthur provides services in the course of its business.

 

Delete

While we will endeavor to permanently erase your personal data once it reaches the end of its retention period or where we receive a valid request from you to do so, some of your data may still exist within our systems, for example if it is waiting to be overwritten. For our purposes, this data has been put beyond use, meaning that, while it still exists on an archive system, this cannot be readily accessed by any of our operational systems, processes or Staff.

 

General Data Protection Regulation (GDPR)

A European Union statutory instrument which aims to harmonise European data protection laws. It has an effective date of 25 May 2018, and any references to it should be construed accordingly to include any national legislation implementing it.

 

Managed Service Provider (MSP) programmes

Clients’ outsourcing of the management of external staff (including freelance workers, independent contractors and temporary employees) to an external recruitment provider.

 

Recruitment Process Outsourcing (RPO) services

Full or partial outsourcing of the recruitment process for permanent employees to a recruitment provider.

 

Staff

Includes employees and interns engaged directly in the business of Arthur (or who have accepted an offer to be engaged) as well as certain other workers engaged in the business of providing services to Arthur (even though they are not classed as employees). For these purposes we also include employees of Arthur who are engaged to work on clients’ premises under the terms of RPO or MSP agreements. To be clear, ‘Staff’ does not include individuals hired by Arthur for the purpose of being placed with clients outside of an RPO/MSP arrangement. These individuals are treated in the same way as Arthur’ candidates and are covered by this Privacy Policy. Likewise, independent contractors and consultants performing services for Arthur fall within the definition of a ‘Supplier’ for the purposes of this Privacy Policy.

 

Suppliers

Refers to partnerships and companies (including sole traders), and atypical workers such as independent contractors and freelance workers, who provide services to Arthur. In certain circumstances Arthur will sub-contract the services it provides to clients to third party suppliers who perform services on Arthur’ behalf. In this context, suppliers that are individual contractors, freelance workers, or employees of suppliers will be treated as candidates for data protection purposes. Please note that in this context, Arthur requires suppliers to communicate the relevant parts of this Privacy Policy (namely the sections directed at candidates) to their employees.

 

Website Users

  • Any individual who accesses any of the Arthur websites

 

Click here to find our Subject Access Request Form.