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EU AND UK PRIVACY POLICY
This policy explains how we might come to receive your personal data (if not
directly from you), how we use it, how and where we store it and what rights you
have to deletion of your personal data from our records. It applies across the
EU and UK. If you are a customer in Singapore please see the Singapore Privacy
Policy onwww.voltinternational.comor if you are a customer in any other
jurisdiction, please see the Privacy Policy on www.volt.com for information on
your privacy right.
When we talk about “we” we mean “Volt”. When we talk about “you” we mean any
customer of Volt whose personal data we may control or process.
If you are a Volt employee, the relevant Privacy Policy can be found on the
Intranet.
We may amend this policy from time to time. The most up to date version will
always be displayed here, on our website.
What kind of customer am I?
How we collect and use your data will differ depending on how we are interacting
with you. Please read the definitions below to identify what type of customer
you are to us, or if you already know, please go straight to that type of
customer in the sections below. If you fall into more than one category (e.g.
you have been a Contractor but are now searching for work again and are
therefore a Candidate), please read both categories, as different rules will
apply to each of those status’.
Candidate – someone who is looking for a temporary or permanent position.
Contractor – A Candidate who Volt has successfully placed in a temporary
contract with one of our end Clients.
Perm Hire – A Candidate who Volt has successfully introduced to a Client and who
the Client has hired as a permanent employee.
Supplier – Any company who supplies goods or services to Volt, other than
Intermediaries.
Intermediaries – Any company that sits between Volt and the Contractor in the
contractual chain. This group will include umbrella companies, management
companies and personal services companies (companies which a Contractor has
incorporated and through which the Contractor provides services).
Clients – Companies to which Volt provides Contractors or Perm Hires, either
directly or indirectly.
Referees – Any person whose data is provided to us by a Candidate, Contractor,
Perm Hire or employee in order for Volt to verify their work history or personal
characteristics.
Emergency Contacts – Any person whose data is provided to us by a Candidate,
Contractor or employee, for Volt to use in an emergency if that Candidate,
Contractor or employee suffers a personal injury, is killed, is arrested or any
other emergency situation, which Volt, acting reasonably, considers it should
notify to an Emergency Contact.
Glossary of other important terms
Consent – Where, after we have told you why and how we will use data we are
requesting, you, understanding what we have asked for, freely give us your
consent (and where necessary they provide additional data to us). We will
record that you have given us consent. Consent is revocable. Please see either
your specific customer section, or the “Contact us” section to notify us if you
are withdrawing your consent.
Legitimate Interests - Under the GDPR, we have a legitimate interest to process
and retain your data to meet our needs as a business (i.e. in order to operate
as a recruitment business), except where your right to protect your personal
data overrides our right. Most of the information we receive and retain about
you falls within this definition. You can tell the parts that don’t within this
document where we have specifically said you need to give your consent.
Volt – All Volt entities trading in the UK and EU, including but not limited to
Volt Europe Ltd, Volt Consulting Group Ltd, Volt Europe (Belgium) sprl and Volt
Europe (France) sarl.
Candidates
What information do we collect?
We are a recruitment business. We want to help you fulfil your potential by
finding the best possible role for you. In order to do this we need to collect,
process and retain certain information about you, so that we can identify you
and match you to job roles we are seeking to fill. We will use this information
to market appropriate roles to you.
This information will typically include your name, gender, contact details, age,
educational history, work history, proof of your identity and eligibility to
work in whichever jurisdictions you have indicated you are willing to work.
How do we collect it?
You may submit your information to us directly (e.g. via our website) or we may
receive it indirectly via a social or professional media platform or job board
either in response to a specific job advert or through our searching to find
suitable Candidates for roles.
How do we use your data?
* We store it, so that we can contact you in relation to suitable roles;
* Provide you with job finding services;
* Match your data with a job spec to establish if you are a good match for any
open job roles;
* Send your data to clients, with your consent, to allow them to consider you
for any open job roles;
Retention of your data
We retain Candidate personal data, with a view to helping you find temporary or
permanent work. We will only contact you with this aim in mind. We do not sell
your data to third parties. We only share your personal data with third
parties, to the extent necessary to fulfil our business objective of finding you
work.
If you are a Candidate, your personal data may reach us via a number of
different methods:
1. You have sent us your CV via our website;
2. You have provided your CV to one of our staff directly, either in hard copy
or electronically;
3. You have applied for a job listed in a job advert via our
website www.voltinternational.com;
4. You have applied for a job listed by Volt on a third party website;
5. You have placed your CV on a job board or social/professional media platform
and we have found it there while searching for suitable Candidates to send
to our Clients.
6. From our Client if they have sourced your services directly and are
referring you to us to act as their contracting and billing/payment agent.
Once Volt is in receipt of your information, we may use your personal data for
the purposes outlined above. We will retain this data for 24 months from the
last meaningful contact between yourself and Volt.
Deletion request
If we process the data because we believe it necessary to do so for our
legitimate interests and you feel that this is incorrect or if you no longer
want us to search for work for you, you may contact us directly at any time and
we will respond to your request within 7 days.
Data request
Our response shall detail a general overview of all of the data we hold for you
at that point in time and further instructions to provide proof of your identity
in order for the information to be accessed. Should we not receive a response to
our request within 21 days, we will send a follow-up email, and if no further
response is received, we shall assume that your request has been adequately
addressed. Please send your request to dataprotection@volt.eu.com If your
information originally reached us via a job board or social media platform,
please remember that you will need to notify that company as well as Volt that
you no longer want them to store your data, if that is your desire.
Contractors
What information do we collect?
You cannot become a Contractor without having first been a Candidate, so any
information we collected about you as a Candidate will transfer with you when
you become a Contractor. Additionally at this point, we will also ask for your
social security number and your unique taxation reference number (if any) and we
may take emergency contact details. In some countries we may need to ask your
marital status for taxation purposes. We may also need to receive copies of any
qualifications that are relevant to the role such as driving license and
professional qualifications. And for some roles we may need you to provide
details of any criminal convictions, health, financial information (if we need
to carry out financial background checks) and diversity information.
How do we use your data?
* We store and where necessary update your data;
* To comply with any contractual terms agreed between us;
* To comply with any contractual terms that have been agreed between Volt and a
third party, in relation to your placement as a Contractor;
* To comply with any reporting obligations we have to any Governmental
authority;
* To comply with any legislation and our legal obligations, including defending
or making any legal claims;
* Checking the accuracy of any data you have provided to us;
* Any reference provided to us by your referee;
* To ask you to provide feedback on your experience of Volt and/or our Client;
* Providing your data to a third party responsible for background checking,
with your consent;
* Market recruitment information to you;
* Make payments to you or your chosen Intermediary;
* Provide you with industry specific information, special offers, networking
and promotional materials, with your consent.
Retention of your data
Once you have become a Contractor, we have either a statutory right or a
legitimate interest to retain any contractual documents, documents required to
be kept under contract, or any information necessary for us to comply with any
legislation, or our legal obligations, including defending or making any legal
claims for the duration of your contract with us and for 7 years after your
final contract with us ends.
After completion of your final contract, we will retain any information we need
to market roles to you for 24 months from the last meaningful contact between
yourself and Volt.
At any time, you may contact us directly if you no longer want us to search for
work for you and we will update your preferences within 7 days of receipt of
your request. Please send your request todataprotection@volt.eu.com
Perm Hire
What information do we collect?
You cannot be hired for a permanent role with our Client, without having first
been a Candidate, so any information we collected about you as a Candidate will
transfer with you when you become a Perm Hire. Additionally at this point, we
may have a need to receive copies of any qualifications that are relevant to the
role such as driving license and professional qualifications. And for some
roles we may need you to provide details of any criminal convictions, health,
financial information (if we need to carry out financial background checks) and
diversity information.
How do we use your data?
* We store and where necessary update your data;
* To comply with any contractual terms that have been agreed between Volt and a
third party, in relation to your placement as an employee of our Client;
* To comply with any legislation and our legal obligations, including defending
or making any legal claims;
* Checking the accuracy of any data you have provided to us;
* To ask you to provide feedback on your experience of Volt and/or our Client;
* Providing your data to a third party responsible for background checking,
with your consent;
* Market recruitment information to you;
* Provide you with industry specific information, special offers, networking
and promotional materials, with your consent.
Retention of your data
Once you have commenced employment with our Client, we have either a statutory
right or a legitimate interest to retain any documents required to be kept under
the terms of our contract with the Client, or any information necessary for us
to comply with any legislation, or our legal obligations, including defending or
making any legal claims for the duration of your contract with us and for 6
years after your employment with the Client commences.
After you start employment with our Client, we will retain any information we
need to market roles to you for 24 months from the last meaningful contact
between yourself and Volt.
At any time, you may contact us directly if you no longer want us to search for
work for you and we will update your preferences within 7 days of receipt of
your request. Please send your request todataprotection@volt.eu.com
Clients – use of your data and your rights
What information do we collect?
If you are a current or prospective Client we will need to collect, process and
retain limited personal information about individuals in your organisation in
order to source the best Candidates for you, either directly or indirectly.
This information will typically be limited to names and professional contact
details of those of your staff who we need to have dealings with be they hiring
managers, finance teams, contract or legal teams, procurement teams, or senior
management.
How do we collect the information?
Typically this information will be provided directly to us, by you, but may be
provided by colleagues, or sourced from publicly available sources.
How do we use your data?
* We store and where necessary update your data;
* To enable us to provide Candidate data to you, directly or indirectly;
* To ask you to provide feedback on your experience of Volt and/or our
Contractor/Perm Hire;
* To provide you with MSP or RPO services;
* We may record meeting minutes with your personal data to improve our service
to you;
* To comply with any contractual terms agreed between us;
* To comply with any reporting obligations we have to any Governmental
authority;
* To comply with any legislation and our legal obligations, including defending
or making any legal claims.
Suppliers – use of your data and your rights
What information do we collect?
If you are a current or prospective Supplier we will need to collect, process
and retain limited personal information about individuals in your organisation
in order to receive from or provide services to you, including as part of an MSP
relationship.
This information will typically be limited to names and professional contact
details of those of your staff who we need to have dealings with be they hiring
managers, finance teams, contract or legal teams, procurement teams, or senior
management.
How do we collect the information?
Typically this information will be provided directly by the individual, but may
be provided by colleagues, or sourced from publicly available sources.
How do we use your data?
* We store and where necessary update your data;
* To enable us to receive Candidate data from you, directly or indirectly;
* To ask you to provide feedback on your experience of Volt and/or our
Contractor/Perm Hire and/or our Client;
* To provide you with MSP or RPO services;
* We may record meeting minutes with your personal data to improve our service
to you;
* To comply with any contractual terms agreed between us;
* To comply with any contractual terms that have been agreed between Volt and a
third party, in relation to your status as a Supplier;
* To comply with any reporting obligations we have to any Governmental
authority;
* To comply with any legislation and our legal obligations, including defending
or making any legal claims.
Intermediaries – use of your data and your rights
Contractors select and appoint their own Intermediaries (subject to Volt
compliance requirements) so in general, you will determine what personal data
you share with the Intermediary because you will share that information with
them directly, subject to their privacy terms.
All personal data provided to Volt directly by you, will be treated in line with
the “Contractors – use of your data and your rights” section.
Referees
If your information is provided to us by a Candidate, Contractor, Perm Hire or
employee, we may contact you to ascertain the work history or personal
characteristics of that individual. Being a referee is a responsible duty.
Many of our clients will not consider a Candidate unless references have been
taken on them so you providing a reference could make a real difference to
someone securing a temporary or permanent job.
How do we use your data?
* We will store your data and any information we receive in a reference;
* We may share your reference with our Clients;
* To comply with any legislation or our legal obligations, including defending
or making any legal claims.
Emergency Contacts
If your information is provided to us by a Candidate, Contractor or employee, we
may use it in an emergency if that Candidate, Contractor or employee suffers a
personal injury, is killed, is arrested or any other emergency situation, which
Volt, acting reasonably, considers it should notify to an Emergency Contact. We
may share your details with our Client, in particular in circumstances where the
Contractor or employee works remotely from an office.
Safeguarding your data
Via technical and process measures, we will take all reasonable steps to prevent
the loss, unauthorised access or misuse of your data. If you suspect any loss,
unauthorised access or misuse of your data by or via Volt, please contact us
immediately.
Use of data internationally
Rarely, it may be necessary to share your information internationally:
* For technical reasons, because of cloud based technologies;
* To customers who are based outside of your country of origin;
* To other Volt entities who are based outside of your country of origin.
Where this is necessary, we will ensure that your information is:
* Only shared within the EEA;
* If shared with the US, is done so under Privacy Shield Framework;
* Shared with non EEA countries which have received a finding of adequacy by
the European Commission with respect to their data protection legislation;
* Necessary for the performance of the contract between ourselves;
* Shared subject to standard contractual clauses as adopted by the European
Commission from time to time; or
* Is with your consent.
Tax Strategy
UK tax strategy
This strategy applies to Volt Europe Holdings Limited and its UK subsidiaries
(herein after referred to as “Volt”) in accordance with Schedule 19 of the
Finance Act 2016 and has been published on the Company’s public website
www.voltinternational.com, with reference to Paragraph 16(4) of this Schedule.
This strategy is applicable for all the accounting periods and will be reviewed
and updated annually.
RISK MANAGEMENT AND ATTITUDE TOWARDS TAX PLANNING
Volt continuously monitors and reviews the tax risks in relation to its
operations and has a low-risk appetite towards the tax matters. The internal
controls engaged by Volt ensures reasonable care across all the processes which
could have a material impact on compliance with its tax obligations.
We implement risk management measures including controls over compliance
processes and monitor their effectiveness. We review on a periodic basis on how
tax risks are managed, monitored and assured and on improvements that are being
made.
Volt ensures that its tax planning is aligned with its business activity and
will evaluate tax as a component of making the appropriate business decisions.
Volt ensures that reasonable care is applied in relation to all processes which
could have a material impact on compliance with its tax obligations. So, where
appropriate, we obtain timely advice from our external tax advisers in the
instances of not having the in-house expertise for any relevant tax matters. At
any time, we do not engage in artificial tax arrangements which would reduce or
evade our tax liabilities.
We conduct transactions between Volt group companies on an arm’s-length basis
and in accordance with current OECD principles.Tax incentives and exemptions are
sometimes implemented by governments and fiscal authorities in order to support
investment, employment and economic development. Where they may exist, we seek
to apply them in the spirit and the manner intended by the local government.
Volt ensures all taxes are paid on time and applicable returns are submitted on
timely basis. Our corporation tax returns are prepared by external tax advisors
and Volt reviews this prior to submission to HMRC.
APPROACH TOWARDS DEALINGS WITH HM REVENUE & CUSTOMS
Volt is committed to maintain a constructive, timely and transparent
relationship with HMRC. We ensure that HMRC is aware of significant transactions
and changes in the business and seeks to discuss any tax issues arising at an
early stage. All disclosures and clearance requirements will be adhered to. In
case of any disputes, we work collaboratively with HMRC to resolve and achieve
agreement and certainty.
GOVERNANCE
Volt Directors owns and implements our approach to tax and are also responsible
for ensuring that policies and procedures that support the approach are in
place, maintained and used consistently and that the tax team has the skills and
experience to implement the approach appropriately.
CONTACT US
If at any point during our working relationship you need to contact us about
your data privacy, either to ask questions, withdraw consent, request deletions,
provide updates to your data, or to make a complaint, you can contact us via:
dataprotection@volt.eu.com
Data Protection Department, Volt House, 3 Chapel Road, Redhill, Surrey, RH1 1QD
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