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Who We Are
At FPSG, we deliver industry leading recruitment and executive search strategies across multiple disciplines globally.
FPSG has been delivering specialist recruitment and executive search strategies to leading businesses since 2010. From our offices in Glasgow and Edinburgh our reputation for excellence has grown through working in partnership with clients and candidates in our specialist sectors in permanent, interim and temporary engagements in the UK and internationally.
FPSG is a trading name of FPSG Connect Ltd (A company registered in Scotland with registered number SC373294 and having its registered office address at 33 Bothwell Street, Glasgow, G2 6NL).
We are a Data Controller for the purposes of the General Data Protection Regulation (Regulation (EU) 2016/679) (GDPR) and related data protection legislation.
Our registration number at the Information Commissioner's Office is Z2185371.
How to contact us
If you have any questions about our Privacy Notice or our data protection policies generally, please contact us:
Initial enquiries should be directed to our Glasgow office as follows:
3rd Floor, Queens House, 29 St Vincent Place Glasgow G1 2DT
0141 270 5003
You can also reach us at our office in Edinburgh (1st floor, 6 South Charlotte Street, Edinburgh EH2 4AW) or at our registered office address.
Our Data Protection Officer is: Robert Little
We are fully committed to handling personal information in accordance with the General Data Protection Regulation (GDPR) effective as of the 25 May 2018.
This means your personal information will be:
- Processed lawfully, fairly and in a transparent manner
- Collected for specified, explicit and legitimate purposes
- Only collected as required for our lawful purposes
- Reviewed regularly
- Retained only for as long as necessary and in accordance with our retention policy
- Processed securely and with integrity
It is important that you are aware of our procedures and practices and understand your rights in relation to your personal data and this Privacy Notice is designed to be part of that information.
This Privacy Notice applies to the following categories of data subjects:
- Temporary workers or contractors who have entered into or have applied to enter into a "contract for services" ("temporary workers")
- Job seekers or other applicants for permanent employment in the public, private and third sectors who contact us or who are referred to us ("permanent candidates")
- Former and potential temporary workers or permanent candidates
Why Do We Need to Process Personal Data?
We may need to process your personal data throughout our relationship with you for multiple reasons, including but not limited to:
- Recruitment processes
- Assignments with clients
- Health and safety
- Human resources
- Regulatory requirements
- Statutory reporting such as HMRC
What Personal Data Do We Collect?
“Personal Data” or "Personal Information" is any information relating to or about an individual from which that person can be directly or indirectly identified. It does not include data where the identity has been removed (anonymous data).
There are "Special Categories" of more sensitive personal data which require a higher level of protection. This includes health data, racial or ethnic origin, political or religious affiliations and criminal records.
During the course of your engagement with us, whether as a temporary/contract worker or a candidate (permanent), we may collect the following information about you:
- Contact details (including address, home and mobile telephone numbers, email) and emergency contacts (i.e. name, relationship and home and mobile telephone numbers)
- National insurance (NI) number, tax code, other tax information and date of birth
- Professional qualifications, continuous professional development (CPD) undertaken, re-validation information to ensure you meet the requirements, medical information in relation to the requirements of working with vulnerable people
- Disclosure Scotland requirements for regulated work, for initial criminal record checks and updates as required
- Timesheets and pay details including bank details for payment purposes
- Information in your sickness and absence records (including sensitive personal information regarding your physical and/or mental health)
- Copies of correspondence both electronic and physical
- Appraisal and other assessments such as your experience surveys, client opinion surveys and supervision and support discussions (1-2-1s)
- Complaints or grievances either from you or about you
- Application forms, references from previous employers and other information collected during the recruitment process
- Nationality and immigration status and right to work in the UK clearance and other immigration information where relevant
- Proof of identity, proof of residence information and information from related documents, such as your passport
- A copy of your driving licence
- Personal preferences in relation to circumstances or predilections that determine your choice of future career options
How do we collect the information?
We may collect this information directly from you (e.g. when you submit an application to us or enter into a contract for services with us or via a face to face interview) or indirectly via the Home Office, HM Revenue and Customer (HMRC), Disclosure Scotland or our clients where you have been placed with, either as a temporary worker, contractor or permanent candidate.
We also collect data from job boards and social media platforms where we advertise or from where you submit applications. If this occurs and we have obtained this information indirectly, we will get in touch within 30 days to inform you. You always have the right to object and we will remove your information.
What is Our Lawful Basis for Processing Your Personal Data?
We will only use your personal data when the law allows us to. Most commonly, we will use your personal information in the following circumstances:
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests
- Where we have obtained your prior consent
- Where we need to perform a contract we have entered into with you
- Where we need to comply with a legal obligation
We may also use your personal information where we need to protect your interests (or someone else's interest) or where it is needed in the public interest.
As a Recruitment Agency and Staffing Solutions Company, we gather information and process personal data in order to pursue our legitimate interests of recruiting and supplying staff to clients in the public, private and third sectors. Furthermore, we process personal data in order to comply with any required legal obligations of ensuring all staff meet the requirements of the relevant sector.
We will obtain your prior consent before either referring you for a position with one of our clients or placing you (as a temporary worker, contractor or permanent staff) with one of our clients.
We also process information to comply with the legal requirements associated with the employment regulations and best practice, including without limitation the requirements of HMRC, the Modern Slavery Act 2015, the Equality Act 2010 and other employment legislation.
If you fail to provide personal information
If you fail to provide certain information when requested we may not be able to perform:
- Recruitment services to find new employment
- Contractual obligations (such as Payroll and HR)
- Legal obligations (such as ensuring the health and safety of our workers)
Change of purpose
We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
*Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law*.
How we use particularly sensitive information
”Special Categories” of particularly sensitive personal information require higher levels of protection. We need to have further justification for collecting, storing and using this type of personal information. We may process special categories of personal information in the following circumstances:
- In limited circumstances, with your explicit written consent
- Where it is needed to assess your working capacity on health grounds, subject to appropriate confidentiality safeguards
Less commonly, we may process this type of information where it is needed in relation to legal claims or where it is needed to protect your interests (or someone else’s interests) and you are not capable of giving your consent, or where you have already made the information public.
Do we need your consent?
We do not need your consent if we use special categories of your personal information in accordance with our written policy to carry out our legal obligations. In limited circumstances we may approach you for your written consent to allow us to process certain “Particularly Sensitive Data”. If we do so, we will provide you with full details of the information that we would like and the reason we need it, so that you can carefully consider whether you wish to consent. You should be aware that it is not a condition of your engagement with us that you agree to any request for consent.
Information about criminal convictions
Less commonly, we may use information relating to criminal convictions where it is necessary in relation to legal claims, where it is necessary to protect your interests (or someone else’s interests) and you are not capable of giving your consent, or where you have already made the information public.
We will collect information about criminal convictions as part of the recruitment process and throughout the duration of your engagement with us (whether as a temporary worker, contractor or permanent candidate).
We will use information about criminal convictions and offences in order to determine your suitability for our clients and the services that they perform.
Do We Share with Third-Parties?
We may share your personal information with third parties, where it is necessary to administer our recruitment services, where required by law, or where we have another legitimate interest in doing so.
We share personal information with:
- Our clients in the public, private and third sectors[*]
- Our payroll services
- Umbrella companies for payment purposes
- Other entities in our group of companies
- Other statutory bodies as required
The above is an indicative list and may change from time to time, if it does for your circumstances we will notify you.
We will take all reasonable steps to ensure all information sharing is carried out in a secure way and will ask our third-party associates to assure us they will handle your personal data securely by using contracts to make our requirements clear and within the legal requirements as set out in the GDPR.
Some third-parties share information with us to be provided to potential employers. They are:
- Disclosure Scotland
- Financial/Credit reference agencies
- Previous employers as part of the regulatory reference checks
We may sometimes send your information to EU and non EU countries, however we will never do so without your prior consent and only after the country or organisation outside the EU has been checked for adequate safeguards.
Retention of Personal Data
The retention periods for personal data depend on the purpose for which the information was obtained and will differ for different organisations.
There are elements of your records that will remain on file for lawful statutory purposes such as filing and reporting for HMRC and any supporting evidential information.
We will retain your personal details for a period of 5 years after our last meaningful contact with you, at which time we will contact you for a review. Our reasoning behind this is that the average tenure in a role is approximately 4.6 years. This allows us to find new and relevant opportunities for you.
When we refer to "meaningful contact", we mean, for example, communication between us (either verbal or written). We will consider there to be meaningful contact with you if you submit your updated CV onto our website or apply for any vacancy that we are advertising for. We will also consider it meaningful contact if there is communication between us about any potential roles, either by verbal or written communication.
Where do we store Personal Data?
Your data is stored on a secured premises in a locked cabinet and on a secure client relationship management (CRM) database enforced by password protocols.
In the event of a “high risk” personal data breach the individual(s) will be notified immediately within 72 hours as well as the Information Commissioners Office (ICO). Our company and staff shall follow our security protocols in line with our “Data Breach” company policy as well as the ICO guidelines and take all necessary precautions in order to minimise the severity of the breach for the individual. All personal data breaches will be recorded in our data breach register.
Right to be informed
You have the right to be informed about the processing of your personal data, and this Privacy Notice provides you with the information you need to reassure you that we handle your personal data securely and lawfully.
Right of access
You have the right to request access to your personal data and to request further information relating to your personal data such as the purposes of processing, the categories of organisations with whom we share your personal data, the retention period for such personal data and the existence of any automated decision-making relating to your personal data.
Right to rectification
You have the right to have any inaccuracies or factual errors corrected or incomplete data amended. If this information has been disclosed to a third-party we will inform that party and request that they amend their records. We want your information to be accurate, complete and up to date so you can ask us to make any rectifications necessary as your details or circumstances change.
Right to erasure (the right to be forgotten)
You can request to have your personal data deleted or removed if there is no compelling reason to keep it, as follows:
- If your personal data is no longer required for the purposes for which we obtained them
- Where the processing of your personal data is based on your consent and you withdraw such consent
- Where the processing of your personal data is based on our legitimate interests and you successfully object to such processing
- Where the personal data is processed unlawfully
- Where the personal data has to be erased for compliance with a legal obligation
If the personal data is held for statutory or regulatory requirements it cannot be erased. Any request made will be discussed with you, unless deletion is an obvious step.
Erasure means we could not contact you should an employment opportunity arise that you may be interested in after reviewing the job specification. Following erasure we will not retain your information and therefore it is possible that your personal information may be re-obtained from the public domain or social media which may result in contact from our organisation.
Right to restrict processing
This relates to personal data where the accuracy is contested or where you have objected to our processing based on our legitimate interests or where we no longer require the personal data but you request us to keep. It is a complex area and whilst a decision is being made in consultation with you, we will store the data but not process it.
Right to data portability
You have the right to take and use your data for other services or purposes. Where the personal data provided by you is processed on the basis of your consent or a contract between us and you, we are required to make this information available to you in a readable easily transferred format.
Right to object
Where the processing of your personal data is based on our legitimate interests, you have the right to object (based on your particular circumstances) to the way we handle, use or store your personal data. If you object to our processing of your personal data, we will restrict any further processing until we determine whether or not there are any compelling reasons why we should continue the processing.
*We do not sell your personal data and we do not use it for marketing purposes.*
Right not to be subject to automated decision-making including profiling
We do not use automatic profiling or decision-making tools.
Exercise of your rights
If you wish to exercise any of your rights in respect of your personal data, please contact us using the details above. Our Data Protection Officer will provide you with further information if required.
We will respond to any exercise of your rights within one month of such request, unless the request is complex in which case we will seek an extension and respond within a further two months thereafter.
We will respond to your requests to exercise your rights at no charge, although repeated or manifestly unfounded or excessive requests may be refused or may incur an administrative charge covering the time and other costs associated with this.
During the registration process we will ask how you wish to be contacted:
- By telephone
- By email
- By post
- By text/SMS
In the first instance we would request that you discuss any complaints with us.
The ICO website has a template letter to assist you but we are happy to discuss in person if you contact your personal consultant at 0141 270 5003 or telephone 0141 270 5000 should you be unable to reach them.
If you are not satisfied after we address your complaint you can complain to:
The Information Commissioners Office
The website has a live chat facility, or you can call 0303 123 1113 (local rate).