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PRIVACY STATEMENT
* Our Pledge
* General
* Candidates
* Clients & Suppliers
* Website Users
ENSURING YOUR PRIVACY IS KEY TO
OUR BUSINESS
NO SURPRISES
We will tell you clearly how your personal data is used in our business.
YOUR CAREER ALLY
Your data is key to our business, so we'll mind it as if it was our own.
NO SPAM
We will always aim to send you information that is relevant to you.
THE BARE ESSENTIALS
We won’t collect information that we don’t need.
WHEN IT'S NO LONGER NEEDED - IT'S GONE
We won’t hold onto information that we don’t need!
GENERAL PRIVACY STATEMENT
* ABOUT MORGAN MCKINLEY AND WHAT WE DO
The Morgan McKinley Group provides recruitment solutions to meet our clients’
needs by connecting specialised talent with leading employers across multiple
geographies, industries and disciplines.
We are a recruitment agency and recruitment business as defined in the
applicable employment and industry specific legislation and regulations,
including but not limited to, the Employment Agencies and Employment
Businesses Regulations 2003 (our business).
Within the Morgan McKinley Group, we also provide other services as follows:
executive search, managed services, and consultancy, acting in the capacity
of Processor.
This Privacy Statement applies to the companies listed in Group Companies &
Supervisory Authority (together the “Morgan McKinley Group”).
* OVERVIEW OF OUR APPROACH TO PRIVACY
We are a global recruitment business. We connect specialised talent with
leading employers across multiple industries and disciplines and we collect
personal data in order to provide these services.
In the Morgan McKinley Group the protection of your personal data is very
important to us because we recognise how important it is to you, and quite
simply, YOU are OUR business.
In most cases Morgan McKinley Group is the controller of personal data
processed as described in this Privacy Statement for the purposes of the
General Data Protection Regulation in Europe (“GDPR”). When providing
services under the M3S and Accreate trading names, we act generally as a data
processor.
This Privacy Statement applies to the processing of personal data by the
Morgan McKinley Group in its role as controller of personal data under the
GDPR. Personal data includes any data about a person that enables them to be
identified from that data. This Privacy Statement describes our approach to
privacy. It includes detailed information about the type of personal data
that we process and how it is used and managed within the Morgan McKinley
Group.
* WHOSE PERSONAL DATA DO WE HAVE?
This Privacy Statement applies to personal data we process in relation to:
* Candidates
* Clients
* Suppliers
* Website Users
As a recruitment business we connect those looking for a job (“Candidates”)
with businesses who are looking for Candidates (“Clients”). For the purposes
of this Privacy Statement, a Candidate is:
* an active job seeker;
* someone we identify as a potential job seeker;
* a contractor of Morgan McKinley Group.
Our services include:
* the placing of Candidates with Clients in permanent and contract
positions. A contract position is where the Candidate is supplied to a
Client of Morgan McKinley Group and is engaged on a contract of, or for,
service, is operating via a personal service or umbrella company, or is an
employee;
* a managed service offering, where bespoke sourcing and managed recruitment
solutions are provided to meet the needs of the Client.
This Privacy Statement is not applicable to employees of Morgan McKinley
Group.
* SHARING OF PERSONAL DATA
We will need to share your information in order to provide services to you.
We will always ensure that any transfer of personal data is undertaken in
compliance with the law and ensures that appropriate technical and
organisational measures are undertaken by any processor or sub-processor.
In certain circumstances, we may disclose personal data as follows:
* between the companies in the Morgan McKinley Group in order to provide
services to Candidates and Clients;
* to business partners and sub-contractors for the performance of any
contract relating to services provided for the purposes of servicing our
Clients and Candidates, including email, chat, ticketing, CRM, ATS,
payment processors, data aggregators, hosting service providers, external
consultants, auditors, IT consultants and lawyers;
* to analytics and search engine providers that assist us in the improvement
and optimisation of the Website. This consists of information relating to
the web pages visited on the Website and tracking codes from service
providers like LinkedIn, Google and Marketo;
* if a company in the Morgan McKinley Group or substantially all of its
assets are acquired by a third party, in which case personal data held by
us will be one of the transferred assets;
* if we are under a duty to disclose or share personal data in order to
comply with any legal obligation (including tax, audit or other
authorities), or in order to enforce or apply any contracts that we have;
and/or
* to protect our rights, property, or safety, or that of our Clients,
Candidates or others. This may include exchanging information with other
companies and organisations for the purposes of fraud protection.
More specifically, we may share Candidate information with the following
parties:
* Clients and potential Clients;
* third party representatives of our clients;
* third parties providing verification services (for example, criminal
record checks/ pre-employment screening services and assessments);
We may be required to share references provided by Associate Contacts of
Candidates in the event of an access request by the Candidate.
* HOW DO YOU ACCESS/UPDATE/DELETE YOUR DATA
You have various rights relating to how your personal data is used including
the right:
* to ask for access to the information we hold on you;
* to change information you think is inaccurate;
* to delete information (your right to be forgotten);
* to ask us to limit what we use your data for;
* to have your personal data moved to another provider (data portability);
* to make a complaint.
You have various rights relating to your personal information and how it is
used by Morgan McKinley Group as follows:
You can ask for access to the information we hold on you. When we receive a
request from you in writing, we must give you access to the information you
have requested as well as details of the processing, the categories of
personal data concerned and the recipients of the personal data. We will
provide the first copy of your personal data free of charge but we may charge
you a reasonable fee for any additional copies.
You can ask to change information you think is inaccurate. You should let us
know if you want to change the personal data we hold. We may not always be
able to change or remove that information, but we will correct factual
inaccuracies and may include your comments in the record.
You can ask to delete information (your right to be forgotten). In some
circumstances you can ask for your personal information to be deleted, for
example, where:
* your personal information is no longer needed for the reason that it was
collected in the first place;
* you have removed your consent for us to use your information (where we
have no other legal reason us to use it);
* there is no legal reason for the use of your information;
* deleting the information is a legal requirement.
Where your personal information has been shared by the Morgan McKinley Group
with others, we will do what we can to make sure those using your personal
information on our behalf as processors comply with your request for erasure.
Please note that we can’t delete your information where:
* we are required to have it by law;
* it is used for freedom of expression;
* it is used for public health purposes;
* it is used for scientific or historical research or statistical purposes
where deleting the data would make it difficult or impossible to achieve
the objectives of the processing; or
* it is necessary for legal claims.
We cannot give you access to a copy of your data if this would adversely
affect the rights and freedoms of others. For security reasons we will not
give you access to credit/debit card details but will delete these from our
systems at your request.
* You can ask us to limit what we use your personal data for
You have the right to ask us to restrict what we use your personal data
for where:
* you have identified inaccurate information, and have told us of it;
* where we have no legal reason to use that information but you want us to
restrict what we use it for rather than erase the information
altogether.
When personal data is restricted, it can’t be used other than to: securely
store the data, with your consent, to handle legal claims and protect
others, or where it is for important public interests.
Where restriction of use has been granted, we will inform you before we
carry on using your personal data.
You have the right to ask us to stop using your personal data for any of
our services. Where possible we will seek to comply with your request, but
we may need to hold or use data because we are required to by law. You
should also be aware that if your request is approved this may cause
delays or prevent us delivering that service.
* You can ask to have your personal data moved to another provider (data
portability)
You have the right to ask for your personal information to be given back
to you or another service provider of your choice in a commonly used
format. This is called data portability.This right only applies to data
stored in electronic form where we’re using your personal information on
the grounds of consent or pursuant to a contract with you. It does not
apply where it would adversely affect the rights and freedoms of others.
* You can make a complaint
You have the right to lodge a complaint with the local supervisory
authority for data protection in the EU member state where you usually
reside, where you work or where you think an infringement of data
protection law took place.
* SECURITY MEASURES
We monitor for and do everything that we can to prevent security breaches.
We will take all steps reasonably necessary to ensure that all personal data
is treated securely in accordance with this Privacy Statement and the
relevant law.
In particular, we have put in place appropriate technical and organisational
procedures to safeguard and secure the information we manage and collect.
To protect the privacy and security of personal data, we will also take
reasonable steps to verify your identity before granting access to
information as appropriate.
Once we have received your information, we will use strict procedures and
security features for the purpose of preventing unauthorised access.
We also use secure connections to protect personal data during its
transmission. Where you have been given (or where you have chosen) a password
which enables you to access services, you are responsible for keeping this
password confidential. We ask you not to share your password with anyone.
If you think that there has been any loss or unauthorised access to personal
data of any individual please let us know immediately.
* CROSS BORDER DATA TRANSFERS
We may share personal data outside the EU, however we will always ensure that
this is done in compliance with the relevant laws.
As a global organisation we use and share personal data both inside and
outside the EU. We ensure that any transfer of data outside the EU is
undertaken using legally compliant transfer mechanisms and in accordance with
the GDPR.
When we transfer personal data outside of the EU, we generally rely on the
Standard Contractual Clauses under Article 46.2 of the GDPR adopted by the EU
Commission however we may also rely on some of the other legally compliant
transfer mechanisms.
* THIRD PARTY WEBSITES
We are responsible for our own privacy practices, not those of a third party.
You may access Morgan McKinley Group services through links to and from third
party websites. If you follow a link to any of these websites, please note
that these websites may have their own privacy statements. We do not accept
any responsibility or liability for these third party websites nor do we
provide support for their services. Please undertake the appropriate due
diligence before submitting any personal data to these websites.
* AMENDMENTS TO THIS PRIVACY STATEMENT
We will update the date on this Privacy Statement when we make changes to it.
We will post any changes on the website and when doing so will change the
updated date at the top of this privacy statement. If you are not happy with
any changes that we have made, we understand you may wish to cease using our
services
In some cases we may provide you with additional notice, for example by
email, of changes to this Privacy Statement. If we deem the changes to be
material, we will provide you with such additional notice well in advance of
the changes taking effect.
* HOW TO CONTACT US
You can write to us at:
privacy@morganmckinley.com
Data Protection Officer
Morgan McKinley
Connaught House
No. 1 Burlington Road
Dublin 4
Ireland
Please contact us if you have any questions about this Privacy Statement or
the information we hold about you.
* GROUP COMPANIES & SUPERVISORY AUTHORITY
As well as contacting us, you can contact the Data Protection Supervisory
Authority relevant to you if you have any concerns about this Privacy
Statement, or about the way we are processing your personal data.
This Privacy Statement applies to the following companies in the Morgan
McKinley Group. Please also see the contact details for the Supervisory
Authority relevant to you below.
Morgan McKinley Group Company Relevant Supervisory Authority In the United
Kingdom: Morgan McKinley Group Limited (trading as “Morgan McKinley”) is a
company registered in the UK, company number 03037211 and registered office
at 15 Fetter Lane, Holborn, London EC4A 1BW, United Kingdom The Supervisory
Authority in the United Kingdom may be contacted at the following postal
address if you have any concerns or questions about the processing of your
personal data:
Information Commissioner's Office,Wycliffe House, Water Lane,
Wilmslow,Cheshire SK9 5AF, United Kingdom In Ireland: Morgan McKinley, La
Creme, M3S and Accreate are registered business names of Premier Recruitment
International UC. Premier Recruitment Int’l is a company registered in
Ireland, company number 131679 and registered office Penrose Dock Two, Alfred
St, Victorian Quarter, Cork, T23 YY09 The Supervisory Authority in Ireland
may be contacted at info@dataprotection.ie you have any concerns or questions
about the processing of your personal data. In Australia: Morgan McKinley Pty
Limited, a company registered in Australia, company number 124730098 and
registered office Level 9, 383 Kent Street, Sydney, NSW 2000 The Supervisory
Authority in Ireland may be contacted at info@dataprotection.ie you have any
concerns or questions about the processing of your personal data. In
Singapore: Morgan McKinley Pte Limited, a company registered in Singapore,
company number 200503018E and registered office 1 Raffles Place #47-02 One
Raffles Place Tower 1 Singapore 048616 The Supervisory Authority in Ireland
may be contacted at info@dataprotection.ie you have any concerns or questions
about the processing of your personal data. In Hong Kong SAR: Morgan McKinley
Limited, a company registered in Hong Kong SAR, company number 774413 and
registered office Suite 3407, Lippo Centre, Tower II, 89 Queensway,
Admiralty, Hong Kong SAR The Supervisory Authority in Ireland may be
contacted at info@dataprotection.ie you have any concerns or questions about
the processing of your personal data. In Japan: Morgan McKinley KK, a company
registered in Japan, company number 0104-01-054224 and registered office
Holland Hills Mori Tower 17F | 5-11-2 Toranomon Minato-ku | Tokyo 105-0001,
Japan The Supervisory Authority in Ireland may be contacted at
info@dataprotection.ie you have any concerns or questions about the
processing of your personal data. In Mainland China: Morgan McKinley Job
Intermediary (Shanghai) Co. Ltd , and registered office Suite 6106, Tower 1,
Plaza 66, No.1266 West Nanjing Road, Shanghai 200040, Mainland China The
Supervisory Authority in Ireland may be contacted at info@dataprotection.ie
you have any concerns or questions about the processing of your personal
data. In Canada: Morgan McKinley Inc, a company registered in Canada, company
number BC1118752 and registered office Suite 400,725 Granville Street,
Vancouver, BC, Canada V7Y 1GS The Supervisory Authority in Ireland may be
contacted at info@dataprotection.ie you have any concerns or questions about
the processing of your personal data.
* OVERVIEW OF CANDIDATE DATA
We want to explain clearly how we process the Candidate personal data that we
hold.
In order to provide our recruitment services we need to collect personal data
relating to our Candidates. This section of the Privacy Statement provides
specific information relating to Candidates.
CANDIDATE PRIVACY
* OVERVIEW OF CANDIDATE DATA
We want to explain clearly how we process the Candidate personal data that we
hold.
In order to provide our recruitment services we need to collect personal data
relating to our Candidates. This section of the Privacy Statement provides
specific information relating to Candidates.
* CANDIDATES & ASSOCIATED CONTACTS
Our Candidates are individuals to whom we provide our services, for example
advising them and assisting them to find a new career opportunity.
As a recruitment business we connect those looking for a job (“Candidates”)
with businesses who are looking for Candidates (“Clients”). For the purposes
of this Privacy Statement a Candidate includes:
* an active job seeker who registers with us with the purpose of us helping
them to find a job, or applies to a role that we have advertised;
* someone who we have placed with a Client whether on a permanent or
contract basis;
* someone we identify as a potential job seeker (for more information see
Sources of Personal Data);
* for the purposes of this Privacy Statement a contractor of Morgan McKinley
Group is defined as a Candidate.
An “Associated Contact” of a Candidate means individuals whose contact
details are provided to us where, for example:
* a Candidate may make a referral of another jobseeker;
* a Candidate may provide the details of their emergency contacts;
* a Candidate may provide us the details of a referee;
* A Client Contact with whom Morgan McKinley Group has/had a Candidate on
contract assignment, may provide a reference for that Candidate.
* SOURCES OF PERSONAL DATA
We have a large variety of sources of Candidate data. We will only ever
source data that is necessary to provide services to you and in a way that
would be generally expected.
We receive personal data about Candidates from a variety of sources. The
primary source is from our Candidates directly. Examples of the sources of
personal data of Candidates are as follows:
* the Candidate may send their CV to us with the intention of registering
with us to be informed of potential job vacancies;
* the Candidate may apply directly to a position advertised on a Morgan
McKinley Group website;
* the Candidate may apply to a position advertised on a third party jobs
website;
* the Candidate may be sourced from publicly accessible platforms where
Morgan McKinley employees are also registered users, for example LinkedIn;
* the Candidate may be sourced from third party CV providers such as jobs
websites who provide CV search facilities and where users have made their
CV data available to registered customers of these sites;
* we receive Candidate information when the Candidate interacts with our
communications e.g. websites and advertisements;
* we may receive personal data about a Candidate from nominated referees of
the Candidate or from other Associated Contacts of the Candidate;
* the Candidate may be referred to us from a Client who wishes us to payroll
the Candidate as a contractor;
* when we are providing a managed services solution to a client, the
Candidate may be referred to us from a third party recruitment business
which is a supplier to us for that client;
* when we are providing a managed services solution to a client, the
Candidate may be referred to us directly from that client requesting that
we process their application on their behalf.
* LAWFUL PROCESSING
We have to process personal data legally. If we look for consent we will
always ensure that Candidates know what they are consenting to. We may also
process personal data without consent but only if that is compliant with the
GDPR and/or is in line with the reasonable expectations of Candidates and
Associated Contacts.
Under the GDPR we must have a lawful basis for processing all personal data.
The GDPR sets out the grounds where processing of personal data can be
undertaken legally. The main grounds used by Morgan McKinley Group to process
personal data are as follows:
Contract
If we have a contract with a Candidate, such as a contract worker, or where
the Candidate has entered into a work finding services agreement for the
provision of services, we will process personal data in order to fulfil the
requirements of the contract, or to undertake set up requirements prior to
entering into the contract.
Legal Obligation
If we have a legal obligation to process personal data, such as the payment
of taxes, we will process personal data on this legal ground.
Legitimate Interests
The GDPR states that we may process personal data “if necessary for the
purposes of the legitimate interests pursued by the controller or by a third
party, except where such interests are overridden by the interests or
fundamental rights and freedoms of the data subject which require protection
of personal data”. We may use legitimate interests where we do not have GDPR
compliant consent, or where the information is collected indirectly about
Candidates (see Sources of Personal Data). We have assessed the scenarios
where we use legitimate interests as a legal ground for processing and we
consider our processing is in line with Candidate expectations and that there
is a balance between our interests, and those of Candidates. Candidates may
object to any processing undertaken on the grounds of legitimate interests.
To find out How do you Access / Update / Delete Your Data, please read that
section of our General Privacy Statement.
Consent
Consent may be collected when a Candidate applies to a position advertised on
our websites, or when a candidate completes our registration process (see
Sources of Personal Data). Where we are unable to collect consent for a
particular processing activity we will only process personal data if we have
another lawful ground.
Defence of legal claims
In limited circumstances and in accordance with the law we may use Candidate
information in the defence of legal claims or enforcing legal rights, such as
IP rights.
Assessment of employee working capacity
In certain circumstances, particularly in the case of a contract worker, we
may be required to assess the working capacity of that worker and we will
operate under this legal ground in relation to any tests or assessments
undertaken involving the processing of sensitive personal data.
* HOW WE USE CANDIDATE PERSONAL DATA
We want to ensure that the personal data is used for the purposes that you
would expect and our ultimate goal is that there should be no surprises for
Candidates in the way that personal data is used by Morgan McKinley. Personal
Data is used for the following key business activities to ensure that we can
deliver the best recruitment services to you:
* Recruitment Services
* Marketing
* Finance
* IT
* Legal
* Equal Opportunities & Diversity
Recruitment Services
Our business is to assist and advise Candidates in their search for job
opportunities. In providing our services, we may use personal data for the
following purposes (we will only ever use the personal data as described here
if we have a legal basis for doing so):
* to keep in contact with Candidates, to inform, update and discuss new
relevant job opportunities and any subsequent progression through the job
search process, for example about interviews, job offers, onboarding, and
in the case of contract workers, the timesheet and payment processes;
* to keep up to date information about the Candidate in relation to their
job search process and their requirements, in order to assess their
suitability for current or future vacancies for example based on their
previous skills and experience overall, their own statements about career
aspirations, professional development, strengths and weaknesses, their
level of managerial experience, professional qualifications;
* to contact referees as part of the recruitment process for permanent roles
or as part of the screening process for contract roles;
* to record emergency contact details for contract workers;
* to understand the profile of organisations in which Candidates are
currently / previously employed;
* to create a record/file for the Candidate on our internal systems to
associate all notes and tracking throughout the job search, interview,
placement, onboarding and contracting process;
* to understand current and expected salary, notice period and available,
current and required locations in order to enhance and impact the success
of the matching process and ensure the Candidate is provided with the most
relevant opportunities;
* to develop the relationship between Morgan McKinley Group and the
Candidate and ensure a more personalised service;
* to meet the requirements of the Client application process including
criminal record and credit checks (where relevant);
* to verify the information provided by Candidates using evaluations and
tests (including functional capability and psychometric testing) at the
request of the Client;
* to pay referral fees;
* to retain evidential proof of the identity of the Candidate;
* to share Candidate information with Clients. We are not responsible for
the processing activities of Clients once a Candidate’s personal data has
been shared. Please refer to the Privacy Statement of the relevant Client;
* to carry out our obligations under Client contracts;
* to enable Candidates to participate in our career development services
* to tailor our products and services to better identify the right
Candidates and present the right opportunities at the right time and meet
Candidate and Client needs more effectively;
* to undertake modelling based on demographic, behavioural, geographic data
in order to produce lead scores that may predict the jobs, locations and
companies Candidates are most likely to be interested in, or to predict
which Candidates our Clients are most likely to hire;
* to undertake profiling for the purposes of semi-automated or manual
decision making about Candidates.
Marketing
We aim to provide Candidates with information that is relevant and personal
to the service that they expect to receive from us. When drafting and sending
marketing communications, we may use personal data for the following
purposes:
* to personalise and make the marketing information sent as relevant as
possible;
* to ask for your help in relation to sharing information about
opportunities we may have, with your network;
* to aggregate data used as part of surveys or to produce market insights;
* to segment and distribute targeted marketing;
* to follow up with attendees of our events/webinars or to contact attendees
about current or future opportunities;
* to ask for your opinion about our products or services;
* to produce aggregated models to predict trends and produce market
insights.
Finance
We may use and create personal data about Candidates for the purposes of
making and receiving payments including the following scenarios (we will only
ever use the personal data as described here if we have a legal basis):
* to make an offer of salary and benefits to a Candidate on behalf of a
Client in relation to a specific job offer;
* to generate placement activity on our central systems in order to invoice
a Client;
* to benchmark salaries for Candidates with similar experience or for
companies with similar vacancies;
* to undertake financial audits;
* to communicate payroll and other financial information to Candidates and
Clients.
IT
We are continuously developing our software and systems to improve the
services that we provide to our Candidates. We use personal data in some
cases to facilitate that development including the following (we will only
ever use the personal data as described here if we have a legal basis):
* to gain customer insights to help optimise and develop new products and
services for Candidates;
* to store and backup information;
* to undertake modelling to identify improvements and efficiencies in the
recruitment process.
Legal
We may need to process certain personal data as part of our legal
obligations, and to ensure our recruitment practices are in line with our
diversity programmes. We may use personal data for the following purposes (we
will only ever use the personal data as described here if we have a legal
basis):
* to capture consent/contract acceptance on paper or electronic registration
forms, terms & conditions or forms;
* to comply with our legal obligations in respect of: the collection of
taxes, levies, contributions; the detection of crime; labour standards;
anti-bribery legislation; and industry specific legislation;
* to comply with Client requests relating to their employment practices;
* to comply with the law in certain jurisdictions;
* to fulfil contractual obligations with Clients and vendors, for example,
in relation to the enforcement of intellectual property rights.
Equal Opportunities & Diversity
We may process certain personal data as part of our commitment to Equal
Opportunities & Diversity, for example to ensure our recruitment practices
are in line with our diversity programmes. We may use personal data for the
following purposes (we will only ever use the personal data as described here
if we have a legal basis):
* to promote diversity or inclusion in the workplace.
A Candidate’s personal data relating to diversity is held anonymously and
used for statistical purposes only.
* THE PERSONAL DATA WE HAVE
This section describes the personal data that we collect about Candidates. We
only collect the personal data that we require in order to provide the best
service to you and deliver the services that you expect. We have described
here in as much detail as possible the personal data that we use in order to
provide our services and the purposes for which it is used. For further
information on the purposes click here.
Depending on the scope of the relationship that we have with you as a
Candidate (described here) we may collect some or all of the following
personal data. The personal data collected will also depend on the country
where the information is being collected and local laws. We use the personal
data as described in How we Use Personal Data and we have outlined the
relevant purposes in the table below:
Examples of Personal Data Purpose for collection Associated Contact
information including phone number, email address, social media links, home
address, email marketing permissions, SMS permissions.
* Recruitment Services
* Marketing
* IT
* Legal
* Finance
Candidate CV including date of birth, employment history, skills/ experience,
languages, educational history, qualifications, membership of professional
associations, contact details of employer references/character references,
licenses held, interests and hobbies.
* Recruitment Services
* Marketing
* Finance
* IT
* Legal
* Equal Opportunities & Diversity
Candidate special categories of personal data including diversity data such
as gender, religion, ethnic origin, sexual orientation, but we will only
source this data with the direct consent of Candidates.
* IT (data storage)
* Legal
* Equal Opportunities & Diversity
Candidate registration data including systems assigned identifiers (like ID,
Morgan McKinley Office, Morgan McKinley Group Brand, Morgan McKinley
Consultant), date record added, Work Finding Services Agreement (in relevant
locations), Candidate registration form (with Associated Contact Data),
Candidate Terms and Conditions.
* Recruitment Services
* Marketing
* Finance
* IT
* Legal
* Equal Opportunities & Diversity
Candidate application data including salary, notice period, details of visa
or eligibility to work, photographic images, video applications if available,
desired salary, CV received date, ‘referred by’.
* Recruitment Services
* Marketing
* Finance
Candidate metadata from candidate including summary of recency, frequency and
timeline of email engagement from Candidate emails / marketing interaction.
* Recruitment Services
* IT
Candidate compensation data including salary and benefits offered to the
Candidate by Client.
* Finance
* IT
Candidate contractor’s payroll data including bank details, tax information
and documentation, social security information, National Insurance/Social
Security Number, payment information, Limited / Umbrella Company details.
* Finance
* IT
Candidate Career and Event Management Registration Data including Name,
Contact Email Address, Account Information, Unsubscribe details, subscription
preferences, Web metadata.
* IT
Associated Contact Referees including Name, Phone Number, Email Address and
reference details.
* Recruitment Services
* IT
Associated Contact Emergency Contact including Name, Phone Number, Email
Address and relationship to Candidate.
* Recruitment Services
* IT
* RETENTION OF CANDIDATE INFORMATION
Our aim is to build lasting relationships with our Candidates and thus to
contribute to long term career success and development. So our goal is to
continue to engage and interact with Candidates even after they have secured
a new position - for example to keep them informed of market developments,
invite them to topical seminars and networking events, and to be on hand to
offer advice about career planning. But, we recognise that the level of
engagement we have with different Candidates will vary and so our retention
policy is designed to reflect this. If we lose touch with a Candidate we
recognise that the personal data we collected is no longer needed for the
purpose for which it was collected and we won't retain it any longer.
Examples of the activities that we would consider evidence of our ongoing
engagement with a Candidate and thus a reason to continue holding their data
include:
* the Candidate meeting one of our consultants, to register for new
opportunities, or for example to update on their situation and seek career
advice or some other professional input;
* us sending a Candidate’s CV to a Client for consideration for a role;
* us arranging an interview between the Candidate and a Client;
* us exchanging email correspondence or having telephone conversations with
the Candidate;
* the Candidate interacting with us in other ways for example, clicking to
open our market insights, newsletters, surveys etc.
Unless the Recruitment Services have been provided to the Candidate, such
personal data will be retained for a period of twelve months following the
date of the last engagement by the Candidate with any marketing communication
received. If a Candidate unsubscribes to marketing communications the
Candidate personal data will be deleted from the marketing database and no
further marketing communications will be sent.
Specifically in relation to Recruitment Services, IT, Finance, Legal, Equal
Opportunities & Diversity, personal data will be retained in accordance with
the above statements unless we are required to keep it for legal reasons. It
will then only be retained for the period required by law and will not be
further processed for any other purpose.
CLIENT & SUPPLIER PRIVACY
* OVERVIEW OF CLIENT CONTACT & SUPPLIER CONTACT DATA
We want to explain clearly how we process the Client Contact and Supplier
Contact personal data that we hold.
In order to provide our recruitment services we need to collect personal data
relating to Client Contacts and Supplier Contacts and this section of the
Privacy Statement provides specific information relating to the information
collected.
* CLIENT CONTACTS
Client Contacts include individuals working for businesses who employ the
types of Candidates that we specialise in sourcing.
For the purposes of this Privacy Statement, a Client Contact includes members
of Client staff, whose contact details we hold, and members of staff of a
company who we deem a potential Client of ours, and whose contact details we
hold.
* SUPPLIER CONTACTS
Supplier Contacts include individuals working for businesses who may provide
services to us.
For the purposes of this Privacy Statement, Supplier Contacts include anyone
working in a business that is a supplier or potential supplier of services to
us.
* SOURCES OF PERSONAL DATA
We source Client Contact and Supplier Contact information in order to serve
the business relationship. We will only ever source personal data that is
necessary and in a way that would be generally expected.
We receive personal data about Client Contacts and Supplier Contacts from a
variety of sources, as follows:
* the information is often provided by the Client Contact or Supplier
Contact, or created by Morgan McKinley Group as part of the business
relationship;
* the information may be collected from public sources;
* the information may be collected indirectly from another person within the
Client or Supplier Business;
* the information may be collected through our website as part of
registration;
* the information may be collected indirectly from a website or from a third
party.
* LAWFUL PROCESSING
We have to process personal data legally. We will process Client Contact or
Supplier Contact personal data in a manner that is compliant with the GDPR
and in line with reasonable expectations.
We have to have a lawful basis for processing all personal data. The GDPR
sets out the grounds where processing of personal data can be undertaken
lawfully. The main lawful grounds used by Morgan McKinley Group to process
personal data of Client Contacts and Supplier Contacts are as follows:
Legal Obligation
If we have a legal obligation to process personal data, such as the payment
of taxes to revenue.
Legitimate Interests
The GDPR states that we may process personal data “if necessary for the
purposes of the legitimate interests pursued by the controller or by a third
party, except where such interests are overridden by the interests or
fundamental rights and freedoms of the data subject which require protection
of personal data”. It is considered reasonable to use Client Contact and
Supplier Contact personal data for our legitimate interests for our business
relationship or potential relationship with Clients and Suppliers.
Client Contacts and Supplier Contacts may object to any processing undertaken
on the grounds of legitimate interests. To find out How do you Access /
Update / Delete Your Data, please read that section of our General Privacy
Statement.
Defence of legal claims
In limited circumstances and in accordance with the law we may use Client
Contact and Supplier Contact information in the defence of legal claims.
* HOW WE USE PERSONAL DATA
We want to ensure that the personal data is used for the purposes that you
would expect and our ultimate goal is that there should be no surprises for
Client Contacts or Supplier Contacts in the way that personal data is used by
Morgan McKinley. To ensure that we can have a good business relationship with
our Clients and our Suppliers, Personal Data is used for the following key
business activities:
* Client Recruitment Services
* Marketing
* Finance
* IT
Client Recruitment Services
Our business is to find the right Candidates for our Clients and also the
right Clients for our Candidates. We use Client Contact personal data as part
of that business for the following purposes:
* to keep in contact with Client Contacts to discuss and review their hiring
needs and requirements;
* to inform, update and discuss Candidates that might be of interest to the
Client;
* to organise and schedule interviews with Candidates;
* to inform the Client about progression of a Candidate through the
recruitment process, to discuss the placement and on-boarding of a
Candidate, and communication relating to the payment process;
* to discuss any reference or other pre-screening information provided for a
Candidate;
* to understand the type of Candidates required by the Client, and build up
knowledge and understanding of the Client organisation and its structure;
* to create a record/file for the Client on our internal systems to
associate all notes and tracking throughout the job search, interview,
placement, on-boarding and contracting process;
* to develop the relationship between Morgan McKinley Group and the Client
and ensure a more personalised service;
* to send Client Contact information to Candidates in relation to the
interview and on-boarding process; and
* to carry out our obligations under our contract with the Client.
Marketing
We aim to provide Client Contacts and Supplier Contacts with information that
is relevant and personal to the service that they expect to receive from us.
We may use their personal data as follows:
* to personalise the marketing information that we send;
* to provide relevant information that we consider may be of interest;
* to aggregate data used as part of surveys or to produce market insights;
* to segment and distribute targeted marketing;
* to follow up with attendees of our events/webinars; and to ask for
opinions about our products or services.
Finance
We use personal data about Client Contacts and Supplier Contacts for the
purposes of making and receiving payments as follows:
* to generate placement activity on our central systems in order to invoice
the Client; and
* to communicate payroll and other financial information to Clients and
Suppliers.
IT and Analytics
We are continuously developing our software and systems to improve the
services that we provide to our Clients and Suppliers. We use Client Contact
and Supplier Contact personal data in some cases to facilitate that
development as follows:
* to gain insights to help optimise products, and to develop new products
and services for Candidates and Clients;
* to tailor our products and services to better identify the right
opportunities at the right time and meet Client needs more effectively;
* to produce aggregated models to predict trends and produce market
insights;
* to undertake modelling to produce lead scores in order to predict which
Candidates our Clients are most likely to hire;
* to undertake modelling to identify improvements in efficiencies in the
recruitment process; and
* to store and backup information.
* THE PERSONAL DATA WE HAVE
Morgan McKinley Group collects and processes very limited information about
Client Contacts and Supplier Contacts. We only collect the personal data that
we require in order to ensure we can have a productive business relationship
with Clients and Suppliers.
Client Contact Personal Data Purpose The types of data we process include:
name, phone number, email address, marketing permissions, company, job title,
reporting line, Candidate feedback, last contact details and timeline
communications.
* Client Recruitment Services
* Marketing
* Finance
* IT
Supplier Contact Personal Data Purpose The types of data we process include:
name, phone number, email address, marketing permissions, company, job title.
* Marketing
* Finance
* IT
* RETENTION
Our mission is to build lasting relationships with Clients for the purposes
of finding the Client the right people for the Client business.
We only retain Client Contact and Supplier Contact personal data for as long
as it is needed for the purpose for which it was collected. After that it is
deleted from our systems.
WEBSITE USERS PRIVACY
* OVERVIEW OF WEBSITE USERS
We want to explain clearly how we process the Website User personal data that
we hold.
For the purposes of this Privacy Statement a Website User is any individual
who accesses any of the Morgan McKinley Group websites (the “Website”).
We collect personal data relating to Website Users and this section of the
Privacy Statement provides specific information relating to the information
collected.
* SOURCES OF PERSONAL DATA
We source Website User information in order to improve our services and
develop the Website.
We receive personal data about Website Users who access our advertisements or
our Website regardless of whether they interact or register with the Website.
* LAWFUL PROCESSING
We have to process personal data legally. If we look for consent we will
always ensure that Website Users know what they are consenting to. We may
also process personal data without consent but only if that is compliant with
the GDPR and is in line with the Website User’s reasonable expectations.
We have to have a lawful basis for processing any personal data. The GDPR
sets out the grounds where processing of personal data can be undertaken
lawfully. The main lawful grounds used by Morgan McKinley Group to process
personal data of Website Users is on the grounds of consent or because we
believe that it is in the legitimate interests of the Website User and us.
* HOW WE USE PERSONAL DATA
We want to ensure that the personal data is used for the purposes that you
would expect and our ultimate goal is that there should be no surprises for
Website Users in the way that personal data is used by Morgan McKinley Group.
We have described here the purposes for which Website User information is
used by Morgan McKinley Group.
We generally use Website User data for Website performance analytics and to
improve the service that we provide to each Website User. We try to present
the information that might be of interest to Website Users based on their
browsing history.
* THE PERSONAL DATA WE HAVE
Morgan McKinley Group collects and processes very limited information about
Website Users. We only collect the personal data that we require in order to
deliver and improve the services we provide.
Types of Website User Personal Data include:
* Information that identifies you as an individual or relates to an
identifiable individual, including: CV, name, title, company name, job
function, expertise, postal address, telephone number, or email address.
* Information that does not reveal your specific identity or does not
directly relate to an identifiable individual. This might include, for
instance, browser and device information; App usage data; information
collected through cookies, pixel tags, and other technologies; demographic
information and other information provided by you; or aggregated
information. We use this information to facilitate our operation of the
Sites and for delivering our service and marketing our service to you.
* RETENTION
Our mission is to build lasting relationships with our customers.
We will only retain personal data for as long as it is needed for the purpose
for which it was collected. After that it is deleted from our systems.
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