Data protection privacy notice

1. Important information and who we are

Purpose of this privacy policy

This privacy policy aims to give you information on how Sisko Group Limited collects and processes personal data belonging to you.

This privacy policy applies to:

• candidates and recipients of our work-finding services;
• users of this website; and
• any representative of our clients, business partners or suppliers.

This website is not intended for children and we do not knowingly collect data relating to children.

Controller

Sisko Group Limited is the controller and responsible for your personal data (collectively referred to as Sisko Group, we us or our in this privacy policy). We are registered with the UK Information Commissioner’s Office (ICO) as a data controller under registration number ZB128396.

We have appointed a data management team who are responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, contact us using the details set out below.

Contact details

If you have any questions about this privacy policy or our privacy practices, you can contact us via email:

Full name of legal entity: Sisko Group Limited, Company number: 12886738.

Email address: privacy@siskogroup.com

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Changes to the privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Third-party links

Our website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

2. The data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

• Identity Data includes first name, maiden name, last name, marital status, title, date of birth, gender, signature(s), National Insurance number(s) and photographic identification data.
• Contact Data includes billing address, delivery address, email address and telephone numbers.
• Employment Data includes employment and job application details such as employment history, qualifications and equality monitoring information. This also includes work-related skills (such as language proficiencies), right to work information, benefits information, tax-related information, references and information contained on your CV.
• Financial Data includes bank account and payment card details.
• Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
• Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
• Profile Data includes your username and password, services requested by you, your interests, preferences, feedback and survey responses.
• Usage Data includes information about how you use our website, products and services.
• Marketing and Communications Dataincludes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

In certain circumstances, our collection of the different categories of data set out above may include the collection of Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). We also may collect Criminal Convictions and Offences Data which results from any criminal or other background checks, as well as any results of any mandatory drugs/alcohol tests that are undertaken.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of our engagement with you (as set out in our terms of business), and you fail to provide that data when requested, we may not be able to perform our services to you.

3. How we collect your personal data

We use different methods of collecting data from and about you including:

• When you complete onboarding forms we provide to you;
• When you submit your CV to us or when you apply for vacancies on our website or on a job board;
• Through third parties or publicly available sources, such as LinkedIn. We will receive personal data about you from various third parties and public sources.
• From job boards where you have registered your details;
• When we communicate with you by email or other electronic correspondence, by telephone or using video conferencing software.
• Networking (for example, at in-person or virtual events).
• Otherwise through providing our recruitment and staffing services and operating our business.

We also collect data from and about you via our website:

• Through your actions (for example, when submitting a subscription form, when submitting a job application).
• Through automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies.
• Technical Data from analytics providers such as Google based outside the UK; and search information providers;
• Contact, Financial and Transaction Data from providers of technical, payment and delivery services; and
• Identity and Contact Data from data brokers or aggregators.

4. How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• Where we need to perform the contract we are about to enter into or have entered into with you.
• Where it is necessary for our legitimate interests as a recruitment and staffing business (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal obligation to which we are subject.
• Where our services require us to process "special category data" and where we have obtained your explicit consent to do so. If we seek and obtain your consent, you may withdraw it at any time.
• Where processing of "special category data" is necessary in the context of recruitment and staffing, or where another legal ground other than explicit consent is available to us under relevant data protection legislation.

Except as previously referred to in this paragraph 4, we do not generally rely on consent as a legal basis for processing your personal data although we will get your consent before sending your CV/details onto any prospective employer.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

We may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose or activity	Lawful basis for processing including basis of legitimate interest
To store your CV and other employment information on our database	Performance of a contract with you/our clients Necessary for our legitimate interests (to provide you with our work-finding services and/or match you to suitable vacancies)
To determine your suitability for any vacancies with our clients, and carry out all of our regulatory compliance requirements, including any background screening	Performance of a contract with you/our clients Necessary to comply with a legal or regulatory obligation Necessary for our legitimate interests (to determine your suitability including any background screening)
To make your details, including your CV, available to our consultants in connection with the recruitment process	Performance of a contract with you/our clients Necessary for our legitimate interests (to determine your suitability for any vacancies)
To deliver our services to you including engaging service providers, managing payments, fees and charges and collecting and recovering money owed to us	Performance of a contract with you Necessary for our legitimate interests (to recover debts due to us)
Assess and deduct any necessary amounts related to tax or national insurance contributions from amounts owed to you	Performance of a contract with you/our clients Necessary to comply with a legal or regulatory obligation
Checking the validity of right to work documents and other ID your details may be disclosed to an identity verification company who will conduct a soft credit check as part of the verification	Performance of a contract with you/our clients Necessary to comply with a legal or regulatory obligation Necessary for our legitimate interests (to check that your details are correct)
To manage our relationship with you which will include notifying you about changes to our terms or privacy policy	Performance of a contract with you Necessary to comply with a legal obligation Necessary for our legitimate interests (to keep our records updated)
To enable you to complete surveys	Performance of a contract with you Necessary for our legitimate interests (to study how candidates and clients use our products and services, to develop them and grow our business)
To administer and protect our business and our website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data). This includes protecting against, identifying and seeking to prevent fraud and other unlawful activity, claims and other liabilities	Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) Necessary to comply with a legal obligation
To deliver relevant website content to you and measure or understand the effectiveness of the marketing we provide to you	Necessary for our legitimate interests (to study how customers use our products and services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, products and services, marketing, customer relationships and experiences	Necessary for our legitimate interests (to define types of clients and customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about services that may be of interest to you	Necessary for our legitimate interests (to develop our products and services and grow our business)
To operate, evaluate and improve our business	Necessary for our legitimate interests (to develop our products and services and grow our business)
To comply with and enforce applicable legal requirements, relevant industry standards, contractual obligations and our policies	Necessary to comply with a legal obligation Performance of a contract with you/our client
To market our services and products	Necessary for our legitimate interests (to promote our business and services)

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

Promotional offers from us

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which vacancies, services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us or contacted us in any form, if we have engaged with you to provide you with services or if we have engaged with you on any vacancy in the past and you have not opted out of receiving that marketing.

Third-party marketing

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

Opting out

You can ask us or third parties to stop sending you marketing messages at any time by contacting us at any time.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product purchase or service provision, a product or service experience or other transactions.

Change of purpose

We will only use your personal data 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 you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

We may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

5. Disclosures of your personal data

We may share your personal data with:

• service providers who provide various services, such as IT and system administration services;
• professional advisers including lawyers, bankers, auditors and insurers;
• HM Revenue & Customs, regulators and professional bodies and other authorities;
• Potential employers/clients who may wish to engage you for a vacancy they currently have;
• Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

6. International transfers

Some of our external third parties are based outside the UK so their processing of your personal data will involve a transfer of data outside the UK.

Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data.
• Where we use certain service providers, we may use specific contracts approved for use in the UK which give personal data the same protection it has in the UK.

Contact us if you want further information on the specific mechanism we use when transferring your personal data out of the UK.

7. Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

8. Data retention

How long will you use my personal data for?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

In some circumstances you can ask us to delete your data (see below).

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

9. Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data to:

• Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
• Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
• Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
• Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
• Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
  • If you want us to establish the data's accuracy.
  • Where our use of the data is unlawful but you do not want us to erase it.
  • Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
  • You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
• Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. This right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
• Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, contact us.

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

10. Cookies

Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site.

A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer's hard drive.

We use the following cookies:

• Essential cookies. These are cookies that are required for the operation of our website. These essential cookies are always enabled because our website won’t work properly without them. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services. You can switch off these cookies in your browser settings but you may then not be able to access all or parts of our website.  
• Analytical or performance cookies. These allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
• Functionality cookies. These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).

You can find more information about the individual cookies we use and the purposes for which we use them in the table below:

Cookie Name	Purpose
fusion_laravel_session	Essential cookie used by the website framework for storing session information
fpestid	Essential cookie used by the website framework
cc527697_f24_autoId	Essential cookie used by the website framework
stonorrecruitment-_zldp	Essential cookie used by the website framework
stonorrecruitment-_zldt	Essential cookie used by the website framework
XSRF-TOKEN	Essential security cookie to protect users against unwanted execution of modifying requests
G_ENABLED_IDPS	Essential cookie used for Google API authentication
purecookieDismiss	Essential cookie used to not show cookie popup again, once cookie policy has been consented to.
shortListCookie	Functional cookie used to Save/Shortlist jobs
lfp_shortlisted_jobs	Functional cookie used to Save/Shortlist jobs
Shortlist_NOT_LOGGED_IN_ADDED	Functional cookie used to Save/Shortlist jobs
cookie_job_type	Functional cookie used when searching jobs by location or job type or category or location or keyword
cookie_location	Functional cookie used when searching jobs by location or job type or category or location or keyword
cookie_category	Functional cookie used when searching jobs by location or job type or category or location or keyword
cookie_minimum_location	Functional cookie used when searching jobs by location or job type or category or location or keyword
cookie_keyword	Functional cookie used when searching jobs by location or job type or category or location or keyword
cookie_type (grid/list)	Functional cookie used to remember the preferred job listing layout and job listing sorting for any user
cookie_sortby (most relevant/ most recent, etc)	Functional cookie used to remember the preferred job listing layout and job listing sorting for any user
_ga	Analytic cookie used by Google Analytics
_ga_866987MH87	Analytic cookie used by Google Analytics
_gid	Analytic cookie used by Google Analytics
fpestid	Used by ShareThis (for Social Share) - Stored on Stonor site
pxcelAcc3PC	Used by ShareThis (for Social Share) - Stored on external site
__stid	Used by ShareThis (for Social Share) - Stored on external site
__stidv	Used by ShareThis (for Social Share) - Stored on external site
whatsappmsgcookie	Used by Whatsapp (for Social Share) - Stored on external site

To opt out of being tracked by Google Analytics across all websites, visit http://tools.google.com/dlpage/gaoptout