Last updated 25th May 2018.
2. What information do we collect
3. How and why do we use/share your information
4. For how long do we keep your information
7. Your Rights
8. Contact Details
Please note that our Website is not directed at children under the age of 13 ("Child" or "Children") and we do not knowingly collect personal information about Children. If you believe we have collected personal information about your Child, you may contact us at email@example.com and request that we remove information about your Child.
2. What information do we collect?
What is personal data?
Data we collect from you when you use our Website
When you use this Website (by filling in forms, registering to use our Website, subscribing to our service, participating in discussion boards or other social media functions on our Website) contact us by post, telephone, email or SMS, participate in a competition or promotion, send us your curriculum vitae or report a problem with this Website, we may collect, store and use certain personal information that you disclose to us. The information we collect from you will differ depending on whether you are a client or a candidate. The information we collect may include (but is not limited to) your title, name, address, e-mail address, telephone number, personal description, job history, qualifications and photograph.
We shall also collect information about you when you visit our Website through the use of technologies such as cookies. The following are examples of information we may collect:
information about your device, browser or operating system;
your login information;
time zone setting;
your IP address;
information about links that you click and pages you view on our Website
length of visits to certain pages;
products you viewed or searched for; page response times;
page interaction information (such as scrolling, clicks, and mouse-overs);
methods used to browse away from the page;
the full Uniform Resource Locators (URL) clickstream to, through and from this Website (including date and time); and any phone number used to call our customer service number.
We also partner with third parties who may collect anonymous usage or statistical data through your use of our Website (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies).
For more information on this kind of technology, please see our Cookies Policy.
We do not actively collect sensitive personal data about our candidates unless this is legally required for recruitment purposes. In our experience, a legal requirement to do so is rare. In such circumstances we will always seek explicit consent before doing so.
Other sources from which we may collect data about you:
Through publicly available sources. We use the following public sources:
Professional networking sites, including, but no necessarily limited to, LinkedIn
Email finding services that access publicly available data;
Companies House (including Companies House search)
By Reference or word of mouth. For example, you may be recommended by a friend, a former employer, a former colleague or even a present employee
Updating your information
If you want to update the information you have previously given to us, you can contact us at neuco Limited, 1 Citibase, 95 Ditchling Road, Brighton, East Sussex, BN1 4ST, or email: firstname.lastname@example.org
3. How and why do we use/share your information
Collecting your information
Here are some examples about how we may use the information we collect about you and you provide to us:
to provide you with a personalised browsing experience when using this Website;
to match your skills, experience and education with a potential employer, and to
provide your details to potential employers with whom we consider you a potential fit;
to allow you to participate in interactive features of our service, when you choose to do so;
to provide you with the information and services that you request from us;
to fulfil any contractual agreements between you and us;
to comply with legal and regulatory requirements;
to manage any account that you hold with us;
to administer our site and for internal operations including troubleshooting, data analysis, testing, research, statistical and survey purposes; to ensure that content from this Website is presented in the most effective manner for you and for your computer; and
to notify you about changes to this Website or our services; and
as part of our efforts to keep our site safe and secure.
Why is neuco allowed to use your information in this way?
We will only use your personal data in the following circumstances:
Where you have asked us to do so, or consented to us doing so;
Where we need to do so in order to perform a contract we have entered into with you;
Where it is necessary for our legitimate interests (or those of a third party) and your fundamental rights do not override those interests; and
Where we need to comply with a legal or regulatory obligation.
Sharing your information
Depending on how and why you provide us with your personal data we may share it in the following ways:
we may share your personal information with any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006;
with selected third parties including business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you (see “Service Providers” below) or for the purpose of sourcing you employment or engagements with a third party; and
with analytics and search engine providers that assist us in the improvement and optimisation of this Website.
We will not share your information with third parties in order for that third party to provide direct marketing communications to you, unless it relates to a specific activity which we are undertaking with a third party (e.g. a competition) and you have provided your consent for such use. Such activity will have its own terms and conditions relating to the way in which your information may be used.
We may also disclose your personal information to third parties in the following events:
if we were to sell or buy any business or assets, in which case we might disclose your personal information to the prospective seller or buyer of such business or assets;
if neuco or substantially all of its assets are acquired by a third party, in which case personal information held by us about our customers will be one of the transferred assets; and
if we are under a duty to disclose or share your personal information in order to comply with any legal obligation, or in order to enforce or apply our Website Terms and Conditions and other agreements entered into with you; or to protect the rights, property, or safety of our company, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
Our service providers provide us with a variety of administrative, statistical, and technical services. We will only provide service providers with the minimum amount of personal data they need to fulfil the services we request, and we stipulate that they protect this information and do not use it for any other purpose. We take these relationships seriously and oblige all of our data processors to sign contracts with us that clearly set out their commitment to respecting individual rights, and their commitments to assisting us to help you exercise your rights as a data subject. The following is a list of our major service providers:
Links to third party sites
4. For how long do we keep your information?
We will hold your personal information on our systems only for as long as required to provide you with the service you have requested.
Where you sign up to receive e-mail marketing from us we will retain your e-mail address after you ‘opt-out’ of receiving e-mails in order to ensure that we continue to honour and respect that request. To unsubscribe from marketing emails at any time, please click on the unsubscribe link at the bottom of any marketing email and update your account preferences. You may also contact us to inform us if you do not wish to receive any marketing materials from us.
Where we learn about you through our existing contacts, people who are active in your industry, or via your published online profiles, we may collect and retain the details that we are told / which you have made publicly available in order to make sure that we are able to consider you for opportunities in respect of which we are instructed. We do this on the basis that we have a Legitimate Interest in keeping records of potential high quality candidates for our clients. However, because we recognise that not everyone will want to be contacted about opportunities when they arise, we will contact you to let you know when we do this – and you will be given the opportunity to decline hearing from us in the future.
In some circumstances you can ask us to delete your data: see ‘Your Rights’ below for further information.
In some circumstances we may 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.
neuco takes the protection of your information very seriously. We use encryption (SSL) to protect your personal data when appropriate, and all the information provided to us is stored on secure servers once we receive it.
We may store your personal data on secure servers either on our premises or in secure third party data centres.
Please note that some of our clients may be based outside of the European Economic Area (the “EEA”). By submitting your personal information, you agree to this transfer, storing or processing. Where we transfer your data to a client that is outside of the EEA we seek to ensure that appropriate safeguards are in place to make sure that your personal data is held securely (our usual practice is to use the EU’s Standard Contractual Clauses) and that your rights as a data subject are upheld. If you would like more information about how the mechanisms via which your personal data is transferred, please contact email@example.com
Where we have given you (or where you have chosen) a password which enables you to access certain parts of this Website, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
7. Your Rights
As a data subject you have a number of rights in relation to your personal data. Below, we have described the various rights that you have, as well as how you can exercise them.
Right of Access
You may, at any time, request access to the personal data that we hold which relates to you (you may have heard of this right being described as a "subject access request").
Please note that this right entitles you to receive a copy of the personal data that we hold about you in order to enable you to check that it is correct and to ensure that we are processing that personal data lawfully. It is not a right that allows you to request personal data about other people, or a right to request specific documents from us that do not relate to your personal data.
You can exercise this right at any time by writing to us using the contact details set out here and telling us that you are making a subject access request. You do not have to fill in a specific form to make this kind of request.
Your Right to Rectification and Erasure
You may, at any time, request that we correct personal data that we hold about you which you believe is incorrect or inaccurate. You may also ask us to erase personal data if you do not believe that we need to continue retaining it (you may have heard of this right described as the “right to be forgotten”).
Please note that we may ask you to verify any new data that you provide to us and may take our own steps to check that the new data you have supplied us with is right. Further, we are not always obliged to erase personal data when asked to do so; if for any reason we believe that we have a good legal reason to continue processing personal data that you ask us to erase we will tell you what that reason is at the time we respond to your request.
You can exercise this right at any time by writing to us using the contact details set out here and telling us that you are making a request to have your personal data rectified or erased and on what basis you are making that request. If you want us to replace inaccurate data with new data, you should tell us what that new data is. You do not have to fill in a specific form to make this kind of request.
Your Right to Restrict Processing
neuco may process your personal data on the basis of a legitimate interest in the following ways:
For prospective candidates, referees and clients, our processing is necessary for our legitimate interests in that we need the information in order to be able to assess suitability for potential roles, to find potential candidates and to contact clients and referees.
You may also ask us to stop processing your personal data (a) if you dispute the accuracy of that personal data and want us verify that data's accuracy; (b) where it has been established that our use of the data is unlawful but you do not want us to erase it; (c) where we no longer need to process your personal data (and would otherwise dispose of it) but you wish for us to continue storing it in order to enable you to establish, exercise or defend legal claims.
Please note that if for any reason we believe that we have a good legal reason to continue processing personal data that you ask us to stop processing, we will tell you what that reason is, either at the time we first respond to your request or after we have had the opportunity to consider and investigate it.
You can exercise this right at any time by writing to us using the contact details set out here and telling us that you are making a request to have us stop processing the relevant aspect of your personal data and describing which of the above conditions you believe is relevant to that request. You do not have to fill in a specific form to make this kind of request.
Your Right to Portability
Where you wish to transfer certain personal data that we hold about you, which is processed by automated means, to a third party you may write to us and ask us to provide it to you in a commonly used machine-readable format.
Because of the kind of work that we do and the systems that we use, we do not envisage this right being particularly relevant to the majority of individuals with whom we interact. However, if you wish to transfer your data from us to a third party we are happy to consider such requests.
Your Right to stop receiving communications
For details on your rights to ask us to stop sending you various kinds of communications, please contact us.
Your Right to object to automated decision making and profiling
You have the right to be informed about the existence of any automated decision making and profiling of your personal data, and where appropriate, be provided with meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing that affects you.
Exercising your rights
When you write to us making a request to exercise your rights we are entitled to ask you to prove that you are who you say you are. We may ask you to provide copies of relevant ID documents to help us to verify your identity.
It will help us to process your request if you clearly state which right you wish to exercise and, where relevant, why it is that you are exercising it. The clearer and more specific you can be, the faster and more efficiently we can deal with your request. If you do not provide us with sufficient information then we may delay actioning your request until you have provided us with additional information (and where this is the case we will tell you).
8. Contact Details
neuco Limited, 1 Citibase, 95 Ditchling Road, Brighton, East Sussex, BN1 4ST.
Alternatively you can contact us by emailing firstname.lastname@example.org