Privacy Policy

About Us

We are Medella Life Limited (a registered company in England under company number 12659887 with our registered offices at Nelhurst Cottage Copson Lane, Stadhampton, Oxford, United Kingdom, OX44 7TZ.

We act as an “employment agency” for the introduction and placement of candidates for permanent and or fixed term roles with our clients for the purposes of the Conduct of Employment Agency and Employment Businesses Regulations (2003) (Conduct Regulations) and as an “employment business” in respect of the introduction and supply of contract resource for temporary and or contract roles with our clients for the purposes of the Conduct Regulations.

We are required to comply with the Conduct Regulations and other employment related laws in the provision of our respective temporary and or permanent recruitment services.

We are registered with the Information Commissioner Office (ICO) with registration number ZA775797

Our services

We are a niche supplier of recruitment services and we specialise in the Life Science space. We provide a tailored recruitment service to our client organisations who are seeking to find talent to fill their interim, contractor, permanent and/or fixed term vacancies.

Our role

In delivering our recruitment services, we assist and support:

Client organisations in finding suitable talent for their skills needs now and, in the future.
Candidates in identifying and exploring new and relevant employment opportunities for them now and in the future
The wider social aims of reducing skills shortages, ensuring more people find work, and reducing and maintaining low unemployment in the UK.

How to contact us

If you have any queries or questions about this privacy notice, please contact our data protection manager at privacy@leaderengineering.com or you may call us on +44 20 4511 0354

Should you wish to contact us more formally to exercise any of your rights in law or to request information about our use of your personal information please refer to Your Rights and How to Complain and Contact Us below.

Personal information

Whose personal information do we collect and use

We collect, use, and store personal information in respect the following types of individuals:

Candidates (i.e. job applicants/work-seekers) Individuals who approach us seeking a new role or to discuss a role (whether for contract or permanent roles) that they have become aware of, who respond to an advertisement we publish in respect of a role, or who we approach as someone who may be interested in a role we are currently seeking to fulfil for a client organisation or who may be interested in future roles we may have.
Contract Resource (i.e. temporary workers, independent contractors, sub-contractors) Individuals who are Candidates and whom are subsequently supplied on a contract assignment to a Client, and whether engaged by us as directly as a PAYE Worker or engaged under contract through their personal service company (PSC) or employed or engaged via an umbrella company.
Client Contacts Employees within the HR function, hiring managers, and other employees within client organisations that we have communications with respect to our services and or otherwise have dealings with when providing our recruitment service.
Supplier Contacts Employees and other authorised individuals within organisations whom delivering business and/or support services to us as a supplier to maintain and/or operate our services under a contract for services.
Referees Work and or personal referees whom our Candidates/Contract Resource may provide details of either in their CV, our registration form, or as requested by us or any other person that we approach to verify employment history as part of our suitability and employment checks undertaken in the provision of our recruitment services.
Emergency Contacts/Next of Kin Members of family and or partner whom a Candidate/Contract Resource may provide to us as their emergency contact/next of kin.
Referred Candidates Friends, colleagues, and other contacts whom any Candidate/Contract Resource, Client, Supplier or other third party with whom we have had dealings with in the provision of our recruitment service may refer to us or recommend we contact with respect to a role or the delivery of our recruitment services.
Website Users Individuals who access our website and whether or not they are individuals within any of the above categories.

When we refer to “you” or “your” we refer to the category of individual to whom the section of the privacy notice relates.

Personal information we may collect

Candidates and Contract Resource

We may collect and process a range of personal information about you, whether obtained directly from you or obtained from a third-party source, and which includes but is not limited to contact details, work and employment history, education, and professional qualifications and your personal interests that we believe are relevant to perform our services, administer any contract assignments that you undertake through us and comply with our legal obligations. We may collect the following personal information from you:

Candidate/Contract Resource Personal Information Table

In respect of our communications with you and the delivery of our services, we may obtain personal information from you arising from:

Your use of our website (please see our website terms and conditions and cookie policy for more information)
Applications you make to roles we advertise for (via our website or via a job board)
Your attendance at any networking event we host or sponsor
Your attendance at any recruitment fair where we are promoting our services
When you talk to us over the phone, via email, or through any text or email messaging service

We may obtain personal information about you from third party sources:

Job boards
Our website
Networking Sites (any professional and or social networking site where you have uploaded or published personal information to)
Referrals – a personal or professional recommendation from a third party (typically family member, friend, colleague or former employer)
PSC or umbrella company – whom you supply your services through and whom is acting on your behalf

We may collect further personal information about you in anticipation of or as part of on-going compliance with a contract assignment from third party sources referred to in the Candidate/Contract Resource Personal Information Table.

If you do not give personal information

You can choose not to give us personal information when we seek to collect personal data from you at any stage in the recruitment process. We may need to collect personal information by law in certain circumstances. If you choose not to give us this personal information, it may delay or prevent us from delivering our services to you or prevent us from continuing with any particular application for a role or require us to terminate our contract with you, your PSC or umbrella company on the basis we cannot comply with the law.

If you choose not to give us information that we require to undertake our assessment of your suitability for roles, we may not be able to proceed to register you and or otherwise introduce you to roles through us or continue to administer our contract with you or your PSC or umbrella if this has already commenced for a contract assignment, but we can advise you of the implications of not giving us information at the time we request it.

It may also be the case that a role requires us to fulfil Client Requirements to facilitate a Candidate’s introduction and or progression through the recruitment process for a particular role. If you do not wish to give us personal information in response to a Client Requirement, this could mean that we cannot progress your application with the Client concerned or we cannot introduce you to a Client where we notify you prior to your introduction. We will make this clear as soon as we are aware of any Client Requirement which affects a role you are interested in. Whilst not providing the personal information will affect the role relevant to the Client concerned, it will not affect your ability to be introduced for other roles we may have with other Clients.

Client Contacts and Supplier Contacts

We may collect and process personal information for our Client Contacts and Supplier Contacts and which will typically include Contact details and Service communications. We will only collect such personal information either directly from you as a Client Contact or Supplier Contact as a consequence of our communications with you, indirectly during service negotiations with a Client or Supplier, indirectly from the contract with our Client or our Supplier, or indirectly from a Job Board or via a Networking Site. We may use such personal information to contact you to discuss our recruitment services with you now and in the future, to deliver our recruitment services to you, to perform our obligations under a contract with the Client, and to keep in touch with you regarding future roles that you may have for which you wish to find suitable Candidates for.

Referees

We may collect and process personal information relating to Contact details for Referees who are provided to us by a Candidate/Contract Resource.

We will only collect such information directly from a Candidate/Contract Resource or from a Job Board the Candidate/Contract Resource has published their details on or profile of the Candidate/Contract Resource from a Networking Site. Referee details will be shared with our Clients in the delivery of our recruitment services when a Candidate/Contract Resource is introduced or supplied for roles with our Clients. Where we act as an employment agency Clients may contact you to seek a reference on a Candidate when considering offering a permanent or fixed term role or upon the offer of such a role to a Candidate. Less commonly, our Clients may require us to take up references during the permanent recruitment process.

We will only use your Contact details for the purpose of taking up a reference for a Contract Resource where we determine it necessary in the conduct of our suitability checks and or where we are required to do so by a Client for a role.

Emergency Contacts/Next of Kin

We may collect and process personal information relating to your Contact details provided to us by a Candidate/Contract Resource.

We will only use such personal information to contact you as a direct consequence of an emergency relating to a Candidate/Contract Resource arising during the recruitment process or during a contract assignment with us and where we reasonably believe it necessary to contact you for the immediate health or safety interests of the Candidate/Contract Resource.

Referred Candidates

We may collect and process personal information relating to Contact details for Referred Candidates who are provided to us by a Candidate/Contract Resource, Client or other third party.

We will receive personal information about you directly from the individual who referred you or from a Job Board or profile for a Networking Site that you may be subscribed to. We will only use such personal information to contact you as a direct consequence of you being referred to us. We will typically ask the person referring you to confirm that you are willing to be contacted by us or in the alternative we will ask the person referring you to introduce you to us. If you express an interest in discussing a role with us now or in the future as a consequence of our contact with you as a Referred Candidate, we will register you and you will be considered a Candidate/Contract Resource for the purposes of this privacy notice. If you are not interested in discussing a role with us and confirm that you do not wish to receive further communications from us having been referred to us, we will not retain your personal information.

Website Users

We may collect personal information via our third-party service providers, such as Google Analytics and various job boards. As you use our websites, we may automatically collect your Technical Data and or Usage Data. We collect this personal data by using cookies, server logs and other similar technologies. Please see our Cookies Policy for further details.

How personal information is protected

Under data protection law, we are only able to use personal information for specific reasons and always provided we are using personal information fairly and we have advised you of our use. Please see our data protection policy for an explanation of the lawful reasons for processing of information.

We must have a legal basis to process your personal information. The legal bases we rely upon to offer our work-finding services to you are:

Where we have a legitimate interest (LI)
To comply with a legal obligation that we have (Legal Obligations)
To fulfil a contractual obligation that we have with you (Contract Necessity)
You consent to our processing (Consent)

Where personal information we collect is considered to be a special category of data or data relating to criminal convictions and or offences (which are considered more sensitive personal information), there are additional requirements that we must fulfil. We will not collect or use more sensitive personal information without your consent unless the law allows us to do so. If we do seek to collect and or use such information, it will usually only be when it is necessary and for one of the following reasons:

We are required to comply with or exercise our rights in the field of employment laws (Employment Law Obligations);
It is for reasons of substantial public interest in compliance with the Data Protection Act 2018 (SBT); or
It is to establish, exercise or defend legal claims and or to seek legal advice in respect of any potential or existing legal claim (Legal Claims)
We obtain your explicit consent to our processing (Explicit Consent)

Our processing activities – Candidates/Contract Resource

We will use your personal information to:

Register your Contact details and other personal information in our database in order to consider you and discuss with you any relevant roles that we submit candidates for now and in the future (LI)
Assess your skills, qualifications, and suitability for relevant roles, and which may include but not be limited to interviewing you (LI)
Undertake compliance requirements with the Conduct Regulations (Legal Obligations)
Carry out any standard pre-screening and or background checks that we require for roles and assignments including but not limited to criminal conviction checks (Legal Obligations), (LI) or (Consent)
Discuss any potential role identified with you and ascertain your willingness to work in the role concerned for Conduct Regulations purposes (Legal Obligations)
Introduce you to a Client for a role that we have discussed with you (directly or via an Intermediary) (LI).
Discuss you as a potential suitable candidate with a Client (directly or via an Intermediary) (LI).
Carry out any background screening, employment verification, and or reference checks relevant to a role where it has been instructed by a Client (LI) or (Consent).
Communicate with you and the Client (or any Intermediary) about the recruitment process and during each stage of such recruitment process (LI).
Administer and manage your contract for services with us (PAYE Workers), performance guarantee or other personal undertaking by the Contract Resource, or your contract with us via your PSC or your umbrella company (LI) or (Contract Necessity)
To provide confirmation (by way of verification) of your engagement with us as a Contract Resource to any future employers where we receive a reference request for you (we can only provide this for as long as we hold personal information unless you request us retain your personal information for a longer period) (LI)
Keep you updated in respect of all applications that you made to us or roles that you have been submitted for by us, provide you feedback in respect of your interviews and keep a record of your applications and the outcome of any interviews (LI).
Keep records related to your introductions and the outcome of those submissions (LI)
Comply with our legal or regulatory requirements in respect of contract assignments and the introduction of candidates for temporary and or permanent roles (including but not limited to our compliance with Immigration legislation, Conduct Regulations, Agency Workers Regulations 2010 (AWR), Equality Act 2010, Health and Safety legislation) – (Legal Obligations)
Share your personal information with third parties where required by law or where necessary in pursuit of our legitimate interests (Legal Obligations) or (LI) – for more information see Sharing your personal information below.
We may use your personal information to help us to establish, exercise or defend legal claims and which may include but not be limited to obtaining external advice in respect of any potential or existing legal claims (LI).
Keep you informed of future relevant roles that may arise now and in the future by post, email, telephone and or other electronic means (marketing communication) (LI).
Contact you individually regarding a role which we believe will be of interest to you whether by post, email, telephone, and or other electronic means (marketing communication) (LI).
Keep you informed of developments in our services that we believe will be of interest to you by post, email, telephone, and or other electronic means (marketing communication) (LI).
Ask you for your help in finding Candidates for roles that we have e.g. through a refer a friend promotion by post, email, telephone, and or other electronic means (marketing communication) (LI)
Keep you informed about relevant professional information; published salary surveys and industry reports relevant to you, networking events, and other relevant information about the industry sector or your skills sector which we believe may be of interest to you by post, email, telephone, and or other electronic means (marketing communication) (LI).
Keep a record of your unsuitability for roles where this has arisen due to any misconduct, any act, error, or omission by you, any harassment or any behaviour of a violent, threatening, or intimidating nature towards us, our staff or any third party, any misrepresentation or conveyance of false information by you, or your unprofessional behaviour; and which has led to your contract assignment being terminated, your application being rejected or no longer processed, or any offer being withdrawn by us or a Client; to ensure that we do not introduce or supply you for roles (LI)

Occasionally, we may require your consent from time to time for the collection and processing of personal information for certain processing activities which are not identified above, which will notify you of at the time of such request for personal information.

Legitimate Interest

Our processing of your personal information is necessary for us to ascertain your suitability for potential roles that we have and to ensure we are matching you to the right roles based on our understanding of your career aspirations and goals. We believe it is important that we have a rounded and informed understanding of your work history, technical and personal skills, and your outside interests in order to achieve these aims.

Our sharing of your personal information with Clients regarding potential employment opportunities as well as introducing you for specific roles is necessary to ensure that we have the best chance of finding relevant employment opportunities for you and the best chance of us successfully filling roles for Clients.

Our assessment of your suitability and completion of our own pre-screening and background checks on you is necessary for us to ensure that you have the technical skills and ability to perform the contract assignment, to mitigate our exposure to claims arising from your negligent performance of the services, to ensure that it would not be detrimental for you or the Client to work together, and to evidence how we determine your suitability for the role if ever disputed and or audited by our Client; all of which are legitimate interests of ours.

We may collect and process personal information relating to you that we would not ordinarily undertake of our own volition, and we will advise you of any such requirements for a role when discussing the role with you. This may involve us asking you to comply with additional pre-screening requirements of a Client, in addition to those we have already undertaken for our assessment of your suitability and require you to enter into additional contractual obligations where related to contract assignments. We will only require the collection and processing of such personal information where we are asked to by the Client (Client Requirements). Our collection and processing of such personal information is necessary for us to comply with our contractual obligations to our Client.

We may process personal information relating to any Contract Resource to administer, perform, and or manage the contract with the PSC or umbrella company for the services of the Contract Resource which is in our legitimate business interests and including in particular our ability to process personal information of the Contract Resource to terminate any contract assignment and or to deal with any dispute arising under the contract with the PSC or umbrella company. To the extent that a Contract Resource has entered into a personal guarantee and or performance deed with us in respect of a contract assignment, we shall be entitled to administer, communicate, and threaten and or bring legal proceedings against the Contract Resource as is necessary to enforce our rights under such contract against the Contract Resource, which is in our commercial interests.

We may contact you by sending marketing communications about potential roles, our services, and professional information which we believe are relevant to you and would be of interest to you. Our continued contact with you now and in the future on this basis is beneficial and necessary to ensure that you receive the best range and choice of employment opportunities; that we may continue to assist and support you in your career aspirations at the various stages of your career; that our Clients continue to have access to a broad range of suitable Candidates for roles that they may have now and in the future, that Clients may receive introductions in a more time efficient manner through our access to suitable Candidates, and that we may continue to fulfil roles for Clients to maintain a sustainable and profitable business.

We are willing to confirm by way of engagement verification details confirming that you were engaged by us during a particular period if requested by any future employer or other person whom you have been advised will seek references and or engagement/employment verification for the period that we retain your personal information. We are not obliged to give a reference or verify your employment/engagement. Should you wish us to retain your information beyond the period we may ordinarily retain your personal information for, you may request us at any time to maintain core employment verification personal information however we will have no obligation to maintain your details beyond the retention period advised.

We will process your personal information where it is in our interests to establish, exercise and or defend legal claims; to seek legal advice in respect of such legal claims (Legal Claims), to prevent criminal acts and or unlawful acts including but not limited to fraud.

Contract Necessity

Our processing on this basis shall only apply to the extent that we may engage Contract Resource as PAYE workers. We are required to process certain Financial information that you have provided, in order to perform our contract with you and which includes but is not limited to make payments to you after statutory deductions to you and administering statutory entitlements and benefits.

Legal Obligations

Our processing on this basis shall apply to the extent that we are required to process personal information to comply with our obligations under the Conduct Regulations, the AWR and to process financial information to comply with our obligations under UK tax, social security, and payroll legislation in respect of PAYE workers, with our obligations for tax intermediary reporting for PSCs, with our obligations to comply with the agency legislation in respect of any Contract Resource engaged as self-employed, and or applying the rules of public sector IR35 for PSCs.

Processing of sensitive information – Candidates and Contract Resource

Criminal Convictions - We do not request this information as part of our own assessment of your suitability for roles. However, we may occasionally collect such personal information in respect of a Client Requirement or through information you disclose to us. We may also request that you undertake a more detailed background check (as required by our Clients) by a third-party background screening provider (Screening Provider) and which may include but not be limited to a criminal record check (Basic Disclosure check or more enhanced DBS check as applicable). Such background check shall be subject to the Screening Provider’s own data protection consent form and privacy notice.

Health Information

Prior to an offer of a role - We will only request and process personal information that you provide to us about any disability status to consider whether we need to provide appropriate adjustments during the recruitment process, for example where adjustments need to be made during a test or interview for a role. If a role requires us to ascertain your ability to carry out certain duties which are intrinsic to that role, we may require you to provide health information to help us in that assessment during the recruitment process.

Post offer of a role - We may process health information prior to or during a contract assignment, to the extent that we have legal obligations to comply with and which fall within the field of employment law and social security including but not be limited to our obligations under the Equality Act 2010, Health and Safety legislation, Conduct Regulations, AWR, Working Time Regulations 1998.

For the processing of any health information in pursuit of our recruitment service outside of the above reasons, we will always seek your Explicit Consent.

Equal Opportunities

We do not currently process sensitive personal information about race or ethnicity, sex or sexual orientation, or religious beliefs for equal opportunities monitoring purposes. If a Client contractually requires us to undertake such monitoring in respect of Candidates and or Contract Resource introduced and processed for roles and this cannot be processed on an anonymous basis (which would naturally fall outside of the requirements of GDPR) we will only collect and process such sensitive personal information with your Explicit Consent or for reasons of SBT.

Our processing activities and reasons for processing - Other Individuals

Client Contacts and Supplier Contacts

We may use personal information to contact you to discuss and or market our full range of recruitment services or discuss your services to us now and in the future, to administer and deliver relevant services, to perform our obligations and enforce our rights under a contract with you, to keep in touch with regarding developments in services delivered and which we believe will be of benefit to us both, and to manage the commercial relationship with you. Less commonly, we may need to process your Contact details in the event we are required to comply any legal and or statutory obligations, and or for which we may rely upon grounds relating to our Legal Obligations. We may process your personal information to deal with Legal Claims. We do not collect and or process any sensitive information about you.

Referees

We will only use your Contact details for the purpose of taking up a reference for a Candidate/Contract Resource where we determine it necessary in the conduct of our suitability checks and or where we are required to do so by a Client for a role that a Candidate/Contract Resource has been introduced for. It is in our legitimate interest to take up references where we are required to do so at the request of our Client to ensure we comply with the terms of our contract with a Client and to ensure that our Candidate/Contract Resource has the best chance of being successful in the recruitment process where references are required to be taken prior to an offer. Less commonly, we may need to process your Contact details in the event we are required to comply any legal and or statutory obligations, and or for which we may rely upon grounds relating to Legal Obligations. We may process your personal information to deal with Legal Claims. We do not collect and or process any sensitive information about you. Your details may be processed in connection with a contractual or statutory audit where our Contract Resource records are audited by our Client for compliance purposes. For any processing of your personal information outside of the above processing activities, we will seek your consent.

Referred Candidates

We will only use your Contact details for the purpose of contacting you as a consequence of you being referred to us and in connection with our services.

We have a legitimate interest in ensuring that we identify potential suitable Candidates/Contract Resource for roles that we are working on now and in the future to ensure that we can best meet the requirements of our Clients as they arise and so we can meet the needs of our Referred Candidates who require contract assignment roles. Upon registering with us, Referred Candidates will be considered Candidates for the purpose of this privacy notice. If you do not wish to register with us, your details will not be retained. Less commonly, we may need to process your Contact details in the event we are required to comply any legal and or statutory obligations, and or for which we may rely upon grounds relating to Legal Obligations. We may process your personal information to deal with Legal Claims. We do not collect and or process any sensitive information about you.

Website Users

We use a third-party service, Google Analytics, and various job boards to collect standard internet log information and details of visitor behaviour patterns. We use this service to ascertain information such as the number of visitors visiting our website and which individual pages are viewed within our website. Information is processed in a way which does not identify an individual.

We may also enable our website to remember information that changes the way the website behaves or looks, like your preferred language; and whether this relates to our own website or a third-party website which you access through a link from within our website.

We may use personal information to allow us to show you adverts while you are online that are relevant to you

Cookies

A cookie is a simple text file that is stored on a Website User’s PC or mobile device by a website’s server. Each cookie is unique to your web browser. It will contain some anonymous information, such as a unique identifier and the site name. Sometimes, we will use cookies to deliver the services we believe add value to our business and assist us in developing and improving our website for all Website Users. You can find out more about this and how to turn off cookies by reading our Cookies Policy.

You can set your browser to refuse all or some browser cookies or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of our website may become inaccessible or not function properly.

Our Communications

We have clarified our grounds for sending you marketing communications under GDPR for legitimate interests. Under existing rules on electronic marketing communications, if we wish to send you marketing communications by electronic means we are either required to obtain your consent to send marketing communications or we may treat you as an existing customer (you are treated as having opted-in to marketing communications). We may rely upon your consent to send certain marketing communications to you. We may also treat you as an existing customer on the basis that we have had dealings with you with respect to the provision of our services. We only send you marketing communications regarding relevant roles, or otherwise in connection with our services or similar services and provided that you have not opted out of receiving our marketing communications. We may use cookies for marketing purposes subject to this privacy notice and our Cookies Policy. We do not share your personal information for marketing purposes with any other person and provided you have not opted out of receiving our email marketing communications.

You have the right at any time to opt out of receiving future marketing communications from us or otherwise object to our future marketing communications by emailing us directly. Please see Contact Us – Your Rights for more information.

Automated decision-making

No decision whether or not to introduce and/or utilise Candidates/Contract Resource for roles is made without human intervention and no decision is based solely on automated decision-making.

We may use search functionality available within our systems or through Networking Sites to help identify Candidates/Contract Resource who may be suitable for us to consider for roles. Search functionality is used in the ordinary course of business to assist us in finding suitable Candidates/Contract Resource. You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making, unless we have a lawful basis for doing so and we have notified you.

Security of your personal information

We have put in place measures to protect the security of your information.

Third-party providers will only process your personal information in accordance with our instructions and upon terms under which they have agreed to treat the information confidentially and to keep it secure.

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

Candidate/Contract Resource - our Clients are data controllers in their own right for the purposes of data protection laws, and therefore are required to comply with the requirements of security under GDPR. Our terms of business require the Client to comply with the requirements of GDPR and they will have their own privacy notice and policy with respect to their own processing of personal information they collect and use. Should you wish to understand what other personal information, if any, they collect about you, and or process outside of our expectations in this privacy notice, or any queries in relation to their processing of your personal information as a data controller you should contact the Client directly.

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

How long we keep your personal information

We will retain your personal information only for as long as is necessary and in accordance with the legitimate interests of our Suppliers, Clients, our Candidates/Contract Resource and our own commercial needs to maintain a sustainable and profitable business but subject always to any overriding law which requires us to retain certain information for longer periods.

We believe that it is reasonable and fair that we retain personal information in accordance with the following periods:

Candidates – From the date we register your personal information, we expect to have on-going discussions and communications with you during your career with respect to existing and future roles however those discussions arise, and which may include you applying for roles and or being interviewed for roles (Career Discussions) and we expect to successfully place you into roles during your career. However, we understand that there may be periods during which we have no Career Discussions with you and or we have not been able to successfully place you into a role, after which time it may be reasonable to expect that your personal information will no longer be of interest or relevance to us and should be deleted. We will remove your personal information from our CRM and systems if we have not had any Career Discussions with you for more than 2 years since our last Career Discussion, we will remove your personal information from our CRM and systems. We may retain your personal information for a longer period than specified above where we are required to in compliance with any Legal Obligations and or as may be required by us to deal with any Legal Claims as is necessary and in our legitimate interest.

We may retain any personal information (including any sensitive personal information) for any role that you have been introduced for (whether or not you have been successful) for a period up to 18 months from our introduction to ensure that we may comply with our Legal Obligations and or may establish or defend and or exercise any legal claims as is necessary and in our legitimate interest.

Contract Resource – We will retain any personal information collected and used for a particular contract assignment for a period of up to 7 years in order to comply with our Legal Obligations, to deal with any Legal Claims, and to reply to any employment verification requests received from any new employer or recruitment agency whom requests confirmation of your work history through us. Should you be placed on a further contract assignment and any personal information collected and used for the purpose of your previous contract assignment is relevant and valid for processing for the same purposes for the new contract assignment, we shall be entitled to use such personal information for the current assignment.

Client Contacts– We will retain your personal information for as long as we provide services to you and for as long as it may be reasonable and commercially beneficial to us and to you to remain in contact with you for marketing purposes.

Supplier Contracts – We will retain your personal information for as long as we receive services from you and for a period of up to 1 year thereafter.

Referees – We will retain your personal information for as long as a Candidate’s personal information is held by us in accordance with the above retention period.

Emergency Contact/Next of Kin – We will retain your personal information for as long a Candidate/Contract Resource receives our services and or for as long as they undertake any contract assignment, and for a period of up to 1 year thereafter.

Referred Candidates – If you do not wish for us to discuss potential roles with you having contacted you as a consequence of a referral as described in this privacy notice, we will not retain your personal information. If you express an interest in discussing potential roles when we contact you, you will become a Candidate for the purposes of retention.

Website Users – We will retain your personal information for 2 years after your last visit or use of our website or any pages within our website.

Sharing your personal information

Sharing personal information with third parties

Contract Resource only

We will share personal information in the provision of our recruitment service that we have collected about you with:

· Clients in order that we can discuss, introduce and or supply you for a role, to allow the Client to assess your suitability for an interview and or offer of a role, and in order to facilitate the recruitment process (e.g. for the purpose of arranging interviews, undertaking tests etc.) and which shall include the Client’s end customer for a particular contract assignment.

· Other recruitment agencies who act as a master vendor, neutral vendor, or managed supplier of services to a Client (Intermediary), and in this circumstance we will share your personal information with the Intermediary who is managing the recruitment process for the Client. For the purposes of this privacy notice, reference to “Client” shall include any Intermediary.

· Umbrella companies whom administer the engagement of and payroll of Contract Resource who undertake contract assignment roles for us upon you wishing to accept a contract assignment role through us.

Candidate and Contract Resource only

We will share personal information in the provision of our recruitment service that we have collected about you with:

· With job boards, job aggregators and other third-party partners we utilise to give you the best opportunity of finding a relevant and suitable role for you.

· Our own third-party service providers who deliver services on our behalf and who may process your personal information in the performance of those services under our instruction (subject to agreements with our third-party service providers) and which include but not be limited to our payroll service providers, our background and ID checks service providers, our accountants, our auditors, legal advisors, insurers and IT service and CRM providers.

· Those categories of third-party sources identified in the Candidate personal information table whom deliver services to us as we require to comply with any Client Requirements, we are obliged to comply with under our contract with the Client

Referees and Emergency Contacts/Next of Kin

We will share personal information of our Referees with the above persons only to the extent that it is necessary in the performance of our services. We will share personal information of our Emergency Contacts/Next of Kin to the above persons only to the extent it is necessary to ensure that contact those persons in an emergency in the interests of the Candidate/Contract Resource.

All

Our own third-party service providers who deliver services on our behalf and who may process your personal information in the performance of those services under our instruction (subject to agreements with our third-party service providers) and which include but not be limited to our payroll service providers, our background and ID checks service providers, our accountants, our auditors, legal advisors, insurers and IT service and CRM providers.
Any authority; which may include but is not limited to; central and local government departments, law enforcement and fraud prevention agencies, HM Revenue & Customs, Employment Agencies Standards Inspectorate (EASI), Gangmasters Licensing & Abuse Authority (GLAA), and other statutory regulators;
Any public information sources and third-party organisations that we may use to perform our suitability and checks; including but not limited to the DVLA, Companies House, Disclosure and Barring Service (DBS), and credit reference agencies.
Any third party whom we instruct to perform audits on our behalf, whether to assess compliance with any statutory duties or as may be required to comply with any contractual commitments that we have.
Any relevant industry trade body that we may be a member of from time to time.
Any potential purchaser of our business or the potential owners of any other business we may potentially wish to merge with in the future.
We will share your personal information with the above third parties where required by law or where we have a legitimate interest in doing so. We have a legitimate interest in:

Complying with our obligations and duties in law
Complying with our obligations under contract with Clients and other third parties
Maintaining our professional accreditations and memberships of professional bodies
Maintaining security and the protection of our IT systems
Assisting authorities in the prevention of crime and fraud
Seeking to prevent criminal acts or other unlawful acts including but not limited to fraud
Notifying authorities in respect of any threat to public security or safety
Assisting the authorities in maintaining national security and protecting public security
The establishment, defence, and or exercise of legal claims and or the instruction and receipt of legal advice in respect of the same

All our third-party service providers are required to take appropriate security measures to protect your personal information in line with our policies. We do not allow our third-party service providers to use your personal information for their own purposes. We only permit them to process your personal information for specified purposes and in accordance with our instructions.

Website Users

Our website and/or services may include links to third party websites, plug-ins and applications, such as in the form of banner advertisements. Clicking on those links, or enabling those connections, may allow third parties to collect or share personal information about you. We do not control these third parties and are not responsible for their data protection compliance. When you leave our website, or connect to a third party from us, it is your responsibility to familiarise yourself with their privacy policy or notice, as we accept no responsibility for, and have no control over, them or any information or data collected by or for them.

Transfer of personal information outside of Europe (EU members & EEA members)

Candidates/ Contacts Resource

We do not envisage transferring your personal information outside of Europe. However, occasionally we may be instructed on roles which are based outside of Europe and therefore personal information may be processed outside of Europe. If processing of your personal data is required outside of the Europe, and the country concerned does not have an adequacy decision in place with the European Commission (which allows that country to be treated as a safe place to transfer and process data alongside other European country and to the standards equivalent to GDPR), we will ensure that your personal information does receive an adequate level of protection by requiring any recipient of your personal information to enter into contractual terms and conditions which requires the same level of protection afforded to processing inside of Europe (appropriate safeguards). If we are unable to put into place these appropriate safeguards, we will typically seek your explicit written consent prior to introducing you for a role which requires processing outside of Europe having given you notice of the risks in having your personal data processed outside of Europe, unless we believe we may process your personal information outside of the EEA for important reasons of public interest or to establish, exercise or defend legal claims; if it is necessary for the performance of a contract with you or with a third party where we believe that contract was entered into by us for your benefit.

We confirm that your personal information is retained within our customer relationship management system (CRM) which is a cloud-based service provided by Bullhorn and your personal information is held securely on Bullhorn’s servers. Bullhorn adheres to the principles of the EU-U.S Privacy Shield framework. For more information on Bullhorn’s GDPR position please refer to https://www.bullhorn.com/uk/bullhorn-uk-and-eu-cookies-and-privacy-statement/. To the extent that emails identifying you are personal data for the purposes of GDPR, we confirm that our emails are administered through a cloud-based service, Microsoft Office 365. Microsoft adheres to the principles of the EU-U.S Privacy Shield framework. If you wish to learn more about the U.S. privacy shield, please refer to https://ico.org.uk/concerns/eu-us-privacy-shield/.

Your contact details may be retained within our accounting software for payroll and invoicing activities, which is a cloud-based service provided by Bullhorn.

If we need to transfer personal information to other parties outside of Europe in the future; whether due to any system changes, appointment of new third-party service providers or otherwise, we will ensure that we have appropriate safeguards in place in order to transfer personal information outside of Europe or in the absence of appropriate measures we will only transfer such personal information outside of Europe with your written consent.

Your Rights and How to Complain

Under data protection laws, you have a range of rights which help to protect you in respect of our processing of your personal information. If you are unhappy with how we deal with your request to exercise your rights, or you are unhappy with our response to your request, you may make a complaint to the Information Commissioner’s Office (ICO) who is the supervisory authority responsible for enforcing data protection laws in the UK. You can contact the ICO by post, by email, telephone or live chat. The ICO details are:

Tel: 03031231113 Email: casework@ico.org.uk

Mail: ICO, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF

We recommend that you read your right to make a complaint at https://ico.org.uk/concerns/.

Your Rights

Your rights in connection with personal information

Under certain circumstances, by law you have the right to:

Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it. We may ask you to verify your identity as part of our security measures for the protection of personal information. We may also ask you for more information regarding your request in order to ensure that we meet our obligations fully. Whilst no fee is generally chargeable for access requests, we reserve the right to charge a fee if you make repeated requests, ask for further copies of our disclosure, or your request is considered excessive in our reasonable view. We may also decline your request for access if we believe that your request is vexatious.
Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
Request erasure of your personal information. This enables you to ask us to delete or remove personal information 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 information where you have exercised your right to object to processing (see below). However, please note:

We may not be able to erase certain personal information due to our continuing legal obligations or in other circumstances allowed under data protection laws.
We cannot guarantee that you will not be contacted by us following erasure if your personal information remains in the public domain (e.g. if you have published or uploaded information to job boards and Networking Sites) and we suggest that you allow us to retain a personal identifier for our list of individuals we should not contact in an effort to prevent you being contacted again (if you request this as part of or as a consequence of any request to erase your personal information).

Object to processing of your personal information 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. You also have the right to object when we are processing your personal information for direct marketing purposes. We have a right to reject your request if we decide that our interests in continuing to process your personal information override your interests, rights and freedoms in certain circumstances.
Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it. We can only store your personal information during this time and will not delete or otherwise use your personal information, except in relation to Legal Claims, where it is to protect the rights of another person, or it is for reasons of important public interest, or where you have consented to a particular use.
Right not to be subject to automated decision making and profiling in respect of your personal data. This enables you to object to any processing undertaken on this basis. Please note that you do not undertake such processing currently.
Request the transfer of your personal information to another party (this will only apply to personal information which is processed on the grounds of consent and which is processed by automated means by us)

Contact Us

If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact us in writing at contactus@medellalife.co

Right to withdraw your consent

Where you have been asked for consent for processing, you can withdraw your consent at any time. If your consent relates to a Client Requirement, you understand that we may not be able to progress your application for the role concerned. If this is the case, we will let you know. Please note that you can only withdraw your consent to processing activities to which you have consented. You can withdraw your consent by emailing us at contactus@medellalife.co