Privacy Policy for Candidates

Last updated: July 2023

AWS Recruitment Ltd is an independent recruitment company who specialise in the recruitment of permanent staff within the Not for Profit Sector. AWS Recruitment Ltd is a company registered in Scotland, Registered No SC416380.

This privacy policy describes how we collect and use personal information about you, including personal information you provide us when you apply for opportunities we list for our clients or apply to be considered for such opportunities as they arise, in accordance with the UK General Data Protection Regulation (UK GDPR) and Data Protection Act 2018 (DPA). AWS Recruitment Ltd (referred to as the Company, we, us, or our) are the controller and responsible for your personal data, referred to in this notice as Personal Information or personal data.

We take data protection very seriously and understand the importance of protecting your privacy and Personal Information. ‘Personal Information’ or personal data is information that identifies you as an individual such as your name, date of birth, email address, CV and IP address.

This privacy policy is designed to explain how Personal Information, including information you submit to us via our website, by email or through our office is used .   It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your Personal Information.

How do we collect information from you?

We collect and use your Personal Information in accordance with this, our Privacy Policy.

The majority of the Personal Information you provide to us freely when you give us your CV, application letter and/or completed registration form. Other Personal Information may be collected through automated technologies or interactions, (including via our website and job boards) or third party or publicly available sources, such as analytics providers or search information providers, such as Companies House and the Electoral Register.

Please do not submit such Personal Information to us if you do not wish us to process it.

Personal Information we collect about you may include the following

General identification and contact information: your name, address, email, telephone details, gender, marital status, date of birth, nationality.

Information enabling us to provide recruitment services: including, location, whether or not you hold a driving licence, CV and career details.
Publicly available information or information you provide to us in relation to professional history: educational background, employment history, skills and experience, professional licenses and affiliations, educational and professional qualifications.
We do not process special category data such as data about your racial or ethnic origin, health, political opinions, religious or philosophical beliefs, trade union membership, genetic or biometric data, sex life or sexual orientation.  We do not process criminal convictions data.  We will update this policy if this changes.

If you fail to provide Personal Information

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to connect you with employers or identify suitable roles). In this case, we may have to cancel the contract you have with us but we will notify you if this is the case at the time.

What legal basis do we rely on to process your Personal Information?

Consent
AWS Recruitment Ltd processes your Personal Information with your consent. For example, we rely on consent when you register with AWS Recruitment Ltd or when you send us your CV. You have the right to withdraw consent at any time.  Where consent is the only legal basis for processing, we will cease to process Personal Information after consent is withdrawn.

The processing is necessary to fulfil a contract
AWS Recruitment Ltd may process your data when we need to do this to fulfil a contract with you, including sending your CV, with your permission, to a client for a specific job application.

Legitimate interest
AWS Recruitment Ltd also processes your data when it is in our legitimate interests to do this and when these interests are not overridden by your data protection rights. Our legitimate interests include:

• Ensuring the security and integrity of our services and ensuring that our website operates effectively.
• Providing and supplying services to our clients and candidates.
• Protecting candidates, clients, employees and other individuals and maintaining their safety, health and welfare.
• Sending communications on potential positions which are relevant and tailored to individual candidates.
• Handling candidate and client contacts, queries, complaints or disputes.
• Fulfilling our duties to our candidates, clients, colleagues and other stakeholders.

The processing is necessary because of a legal obligation that applies
AWS Recruitment Ltd may process your data to comply with our legal and regulatory obligations, e.g. preventing, investigating and detecting crime, fraud or anti-social behaviour and prosecuting offenders, including working with law enforcement agencies.

Special categories of particularly sensitive personal information require higher levels of protection. We need to have further justification for collecting, storing and using this type of personal information. We may process special categories of personal information in the following circumstances:

In limited circumstances, with your explicit written consent.
As a data processor on behalf of clients and in accordance with their instructions, to assist them to carry out legal obligations or exercise rights in connection with employment.
Where it is needed in the public interest, such as for equal opportunities monitoring, including as a data processor on behalf of our clients and in accordance with their instructions.
Where it is necessary to protect you or another person from harm.
Less commonly, we may process this type of information where it is needed in relation to legal claims or where it is needed to protect your interests (or someone else’s interests) and you are not capable of giving your consent, or where you have already made the information public. 

In general, we will not process particularly sensitive personal information about you unless we have your consent or, at the request of our clients and in accordance with their instructions, where it is necessary for them to perform or exercise obligations or rights in connection with employment. On rare occasions, there may be other reasons for processing, such as it is in the public interest to do so.

Who do we share your Personal Information with?

AWS Recruitment Ltd may make Personal Information available to:

Our clients
In the course of our business to help you search for a suitable position, AWS Recruitment Ltd may make Personal Information available to potential employers.

Our service providers
This includes external third-party service providers, such as accountants, payroll providers, auditors, lawyers and other outside professional advisors; IT systems, support and hosting service providers; document and records management providers; technical engineers; data storage and cloud providers and similar third-party vendors and outsourced service providers that assist us in carrying out business activities.

Government bodies and public authorities
AWS Recruitment Ltd may share Personal Information with governmental or other public authorities (including, but not limited to,  law enforcement agencies, HMRC and the police).

Occasionally we may share Personal Information with other third parties. We will always do this under contract, for specified purposes and require them to process Personal Information in accordance with our instructions.

International transfers

Some of our external third parties are based outside the UK so their processing of your Personal Information will involve transfer of data outside the UK.
Whenever we transfer your Personal Information out of the UK, we ensure a similar degree of protection is afforded to it by ensuring appropriate safeguards are implemented, such as where your Personal Information is transferred to countries (including EU countries) that have been deemed to provide an adequate level of protection for personal data, or 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.

We may request your explicit consent in specific circumstances where we will transfer your data outside of the UK and the above do not apply.  Otherwise, if any part of the work we undertake requires it, we may transfer your Personal Information to a country outside the UK provided that one of the following conditions applies:

The country to which the personal data are transferred ensures an adequate level of protection for your rights and freedoms.
The transfer takes place in accordance with binding corporate rules authorised by the relevant data protection authority or other safeguards set out in Article 4 of the GDPR.
You have given informed, explicit consent.
The transfer is necessary for one of the reasons set out in the GDPR, including the performance of a contract between us, or to protect your vital interests.
The transfer is legally required on important public interest grounds or for the establishment, exercise or defence of legal claims.
The transfer is authorised by the relevant data protection authority where we have taken adequate safeguards with respect to the protection of the data subjects’ privacy, their fundamental rights and freedoms, and the exercise of their rights.
Where we use third party suppliers to provide services on our behalf, including online job and recruitment sites, these suppliers may process personal data on our behalf as “processors” and are subject to written contractual conditions to only process that personal data under our instructions and protect it. In the event that we do share personal information with external third parties as processors, we will only share such personal data strictly required for the specific purposes and take reasonable steps to ensure that recipients shall only process the disclosed personal data in accordance with those purposes.

Third party links

Our site may, from time to time, contain links to and from the third-party websites, plug-ins and applications. If you follow a link to any of these websites, or enable any of these connections this may allow third parties to collect or share data about you.  We do not control third party websites and are not responsible for their privacy statements.  When you leave our website we encourage you to read  their privacy policies before you submit any personal data to these websites.

Social Media Platforms

This website may use social sharing buttons which help share web content directly from web pages to the social media platform in question. Users are advised before using such social sharing buttons that they do so at their own discretion and note that the social media platform may track and save your request to share a web page through your social media platform account. Any such tracking is subject to that website’s own privacy policy.

How we use your Personal Information

AWS Recruitment Ltd only uses your Personal Information where the law allows us to, most commonly where you have provided your consent; we need it to perform the contract we are about to enter into or have entered into with you; where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests; or where we need to comply with a legal obligation.  We may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data.

In particular, we may use your Personal Information as follows:

• To provide our recruitment services to you.
• To maintain our business relationship, where you are a user of our website, or candidate.
• To enable you to submit your CV for general applications, to apply for specific jobs or to receive information about potential positions.
• To match your details with job vacancies, to assist us in finding a position that is suitable for you and to submit your CV (with your permission) to clients in order to apply for jobs.
• To answer your enquiries.
• To fulfil contractual obligations with our clients.
• To engage with trusted third parties where we have retained them or engage with them to provide services that you or our clients have requested, such as reference, qualification and criminal reference checking services (as required), verification of the details you have provided from third party sources, psychometric evaluations or skills tests. These third parties are required to respect the security of your personal data and to treat it in accordance with the law.
• To engage with third parties who perform functions on our behalf and who also provide services to us, such as professional advisors, IT consultants carrying out testing and development work on our business technology systems, research and mailing houses and function coordinators. These third parties comply with similar undertakings of privacy and confidentiality as AWS Recruitment Ltd.  These third parties are required to respect the security of your personal data and to treat it in accordance with the law.
• We may also release personal information to regulatory or law enforcement agencies, if they require us to do so. We will also disclose your information where we are permitted and requested to do so by law.
• We may also seek your consent to collect, hold, use and disclose your personal information for any other purpose not listed above.  Otherwise, 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, please 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.  Please note that 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.
• Our website may also use a website recording service which can record mouse clicks, mouse movements, page scrolling and any text keyed into website forms. Data collected by this service is used to improve our website usability. The information collected is stored and is used for aggregated and statistical reporting, and is not shared with anybody else. 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 this website may become inaccessible or not function properly. For more information about the cookies we use, please see Cookie Consent
• Business sales – To engage with 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.

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.

Your rights

Under certain circumstances, you have rights as an individual which you can exercise in relation to the Personal Information we hold about you:

The right to be informed how your personal data will be stored and used.
The right to access your personal data. This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
The right to rectification. You have the right to have personal data modified or updated if it is inaccurate or incomplete though we may need to verify the accuracy of the new data you provide to us.
The right to erasure. This enables you to ask us to delete or remove personal data, including that held by third party suppliers 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. To ask us to permanently delete your personal data, send an email to our Data Privacy Manager (see below) with the subject line “Permanently delete my information and account”.
The right to restrict processing. 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.
The right to data portability, which allows you to obtain and reuse your personal data for your own purposes across different services. It allows you to move, copy or transfer your personal data easily from one IT environment to another in a safe and secure way, without hindrance to usability. Note that 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.
The right to object to processing of your data based on legitimate interests or the performance of a task in the public interest/exercise of official authority (including profiling); processing for direct marketing purposes; and processing for purposes of scientific/historical research and statistics.
Rights in relation to automated decision making and profiling, i.e. to not be subject to a decision based solely on automated processing, including profiling.
The right to withdraw your 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 above, please contact us.  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. 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.  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.

How long we store your Personal Information for

We will retain your Personal Information for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, 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 requirements.

In some circumstances you can ask us to delete your data: see ‘Your Rights’ above for further information.

Your duty to inform us of changes

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

Who to contact about your Personal Information

We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy policy.  That post is held by  Donna McKay.

If you have any questions about this policy or our use of your Personal Information you can email [email protected] or write to the Data Privacy Manager, AWS Recruitment Ltd, 21 Young Street, Edinburgh, EH2 4HU.

If you do not think we are handling your Personal Information adequately, you have the right to lodge a complaint with the Information Commissioner’s Office.  Further information, including contact details, are available at https://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 Privacy Policy
We review this Privacy Policy regularly and reserve the right to make changes at any time to take account of changes in our business and legal requirements. We will place updates on our website.
Please take a look at the “LAST UPDATED” date at the top of this Privacy Policy to see when it was last revised.

The Site is operated by AWS Recruitment Ltd. AWS Recruitment Ltd is registered in Scotland. Registered number: SC416380. Registered address: 21 Young Street, Edinburgh, EH2 4HU.