This Privacy Notice details the procedures by which Staffing 360 Solutions Inc and its group of companies (herein referred to as “we”, “us”, “our” and “ours”) will process personal information provided to us or held by us, also known as ‘personal data’. This notice also encompasses our trading divisions within the United States, namely Key Resources Inc., Lighthouse Professional Services, Monroe Staffing, and Headway Workforce Solutions (‘Associates’), and all references to “we”, “us”, “our” and “ours” include Associates and all our group companies.
We are dedicated to protecting the privacy of personal data and adhering to the legal obligations under US federal and state privacy laws. We request that you inform us about any changes to your personal information to ensure it remains accurate and updated.
Our primary service involves assisting individuals in finding employment opportunities with our client companies. This service, referred to as ‘Recruitment Services’ in this notice, also includes our role as an employer, engaging staff for the provision of our recruitment services.
The individual responsible for data protection matters within our organization ('Responsible Person') is Aneta Basiuk, Director of Operations and Compliance, who can be contacted at 01737 822000 or email@example.com.
If you choose not to have your personal data processed in accordance with this policy, please do not provide it to us. Please refer to Section 4 ’Your rights‘, concerning data that we already hold or receive from third parties.
Section 1: Candidates
This section applies to individuals wishing to utilize or currently using our Recruitment Services or looking for a role to work with us (‘a Candidate’):
The personal data we collect or receive includes, but is not limited to:
- Email and other contact details
- Date of birth
- Job history (including information relating to placements through us)
- Educational history, qualifications & skills
- Visa, passport, and other right to work or identity information
- Bank details
- National insurance and tax (payroll) information
- Emergency contacts, next of kin, and family details
- Relationship with third parties including referees
- Personal information relating to hobbies, interests, and pastimes
- Information contained in references and pre-employment checks from third parties
- Other sensitive personal information such as health records (see ‘Sensitive Personal Data’ section below)
- Where applicable, information relevant to safeguarding responsibilities
- Marketing preferences
We may obtain your personal data from various sources, including:
- You (e.g., a resume, application or registration form, or communications with you)
- A Client or other users of your services
- Other candidates
- Other persons connected with you or whose details you have provided to us
- Online jobsites
- Marketing databases
- The public domain
- Social Media
- During an interview
- Conversations on the telephone or video conferencing (which may be recorded)
- Notes following a conversation or meeting
- Our websites and software applications
How we will use your personal data:
The processing of your personal data may include:
- Collecting and storing your personal data, whether in manual or electronic files
- Notifying you of potential roles or opportunities
- Assessing and reviewing your suitability for job roles
- Introducing and/or supplying you to actual or potential Clients
- Engaging you for a role with us or with our Clients including any related administration e.g. timesheets and payroll
- Conducting reasonable welfare checks
- Communicating with third parties in the event of an emergency, accident, or any issue relating to workplace safety
- Gathering market or sector-specific information and providing the same to our Clients
- Sending information to third parties with whom we have or intend to enter into arrangements which are related to our Recruitment Services
- Complying with our legal obligations, for example reviewing, using, and passing on information as required for the protection of health and safety of staff and visitors
- Providing information to regulatory authorities or statutory bodies, and our legal or other professional advisers including insurers
- Marketing our Recruitment Services
- Retaining a record of our dealings
- Recording how you engage with our Recruitment Services including through our website and IT and communication systems
- Establishing quality, training, and compliance with our obligations and best practice
- Backing up information on our IT and communications systems
Why we process your personal data:
1. Entering into and performing a contract with you:
To provide our Recruitment Services, we may enter into a contract with you and/or a third party. In order to enter into a contract, we will need certain information, for example, your name and address. A contract will also contain obligations on both your part and our part, and we shall process your data as necessary for those obligations. For instance, to process payroll, a national insurance number and bank details will be required.
2. Compliance with legal obligations (regulatory and statutory obligations):
We must comply with numerous statutory provisions when providing our Recruitment Services, necessitating the processing of personal data. These include the Conduct of Employment Agencies and Employment Businesses Regulations 2003, which among other things require us to:
- Verify your identity
- Assess your suitability for an external job role
- Maintain records for specific periods
When we engage a person to work for us (whether directly or as supplied to a Client), there are other statutory obligations that must be complied with including payroll, tax, social security, HMRC reporting requirements, and any other law or regulation.
We are also required to comply with statutory and regulatory obligations relating to business generally, for example complying with tax, bribery, fraud/crime prevention, health and safety and data protection legislation, and cooperating with regulatory authorities such as HMRC or the Information Commissioner’s Office.
3. Our legitimate interests (carrying on the commercial activity of Recruitment Services):
In providing our Recruitment Services, we will carry out some processing of personal data which is necessary for our legitimate interests, which include:
Retaining records of our dealings and transactions and where applicable, use such records for the purposes of:
- establishing compliance with contractual obligations with Clients or suppliers
- addressing any query or dispute that may arise including establishing, exercising, or defending any legal claims
- protecting our or our Clients' reputation
- maintaining a backup of our system, solely for the purpose of being able to restore the system to a particular point in the event of a system failure or security breach
- evaluating quality and compliance including compliance with this Privacy Notice
- determining staff training and system requirements
Using your personal data to:
- assess suitability and contact you regarding potential opportunities and/or our services
- gather market information or trends including providing analysis to potential or actual Clients
- source potential opportunities or roles as part of our Recruitment Services
- personalize your experience and our offering, whether via our website or otherwise
- address emergencies and conduct welfare checks
- meet any obligations we have concerning workplace safety and security, including the safety of others
For our commercial viability and to pursue these legitimate interests, we may continue to process your personal data for as long as we consider necessary.
In certain circumstances, we may obtain your consent to process your personal data in a particular way.
Sensitive Personal Data (SPD)
Sensitive personal data is information which is intensely personal to you and is usually irrelevant to our considerations. It may include information revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, and data concerning health. However, we may collect sensitive personal data if there is a lawful reason for doing so, and where it is necessary for us to have such data.
Where you provide sensitive personal data to us voluntarily, you agree that we may use such data as provided by this Privacy Notice.
Retention of your data
Your personal data will be retained by us only for as long as is necessary for the purposes set out in this policy, unless a longer retention period is required by law. Typically, we will retain your personal data for a period of up to seven years from the end of our relationship with you. However, this may be longer if there is a statutory requirement to retain it for a longer period, or in accordance with our data retention policy.
Security and storage of information
We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Notice.
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized 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.
Information on our websites
Any information you provide to us through our websites may be placed by us on servers located in countries outside of the EU. If you do not agree with this, please do not provide personal data or allow it to be collected.
You have various rights in relation to your personal data under Data Protection laws in the United States. In California, for instance, the California Consumer Privacy Act (CCPA) provides a range of rights concerning your personal data. You can learn more about these rights on the official website of the California Privacy Rights Act.
On a federal level, the Federal Trade Commission (FTC) provides a privacy and security section on their website which offers helpful information regarding data protection.
We want to ensure that your personal data is accurate and up to date. If any of the information that you have provided to us changes, for example, if you change your email address or if you wish to cancel any request you have made of us, or if you become aware we have any inaccurate personal data about you, please let us know by sending an email to firstname.lastname@example.org. We will not be responsible for any losses arising from any inaccurate, inauthentic, deficient or incomplete personal data that you provide to us.
If we wish to use your personal data for a new purpose, not covered by this Privacy Notice, then we will provide you with a new notice explaining this new use prior to commencing the processing and setting out the relevant purposes and processing conditions.
Changes to our privacy notice
We keep our privacy notice under regular review and we will place any updates on our website. This privacy notice was last updated on 24th October 2023.
If you have any questions, comments or requests regarding this Privacy Notice, please feel free to contact us by sending an email to email@example.com or by writing to: Compliance Department, Staffing 360 Solutions, Inc., 415 Madison Avenue, 14th Floor, New York, NY 10017.
The above Privacy Notice is from Staffing 360 Solutions and its group of companies, which includes their trading divisions within the United States: Key Resources Inc., Lighthouse Professional Services, Monroe Staffing, and Headway Workforce Solutions. The notice outlines the company's commitment to protecting the privacy of personal data and adherence to legal obligations under US federal and state privacy laws. It describes the types of personal data collected, sources from which this data may be obtained, the purposes for processing this data, and the conditions under which it may be processed. It also details the rights individuals have concerning their personal data, and the measures taken to ensure the secure handling of this data. The notice emphasizes the importance of keeping personal data accurate and updated, and provides contact information for queries, comments, or requests regarding the Privacy Notice.