This is the privacy policy for Maldon Partners Ltd. (“we“, “our“, “us“). This Policy explains how and why we collect and use personal information, and what we do to ensure it is kept private and secure.

WHO WE ARE

We are Maldon Partners Ltd. For the purposes of data protection law, we will be a controller of the personal information we hold about you. This means we make decisions about how and why your information is used and have a legal duty to make sure that your rights are protected when we do so.
If you have any questions about our Privacy Policy, please contact us by writing to us at our registered address given above, telephoning us on +44 203 8001457 or contacting us via e-mail at GDPR@maldonpartners.com.

2. THE PERSONAL INFORMATION WE COLLECT

We collect the following types of personal information:

Information you give us

When you apply for a position displayed through various recruitment websites you provide a significant amount of personal information about yourself which is securely passed to us, this includes:

• your name;
• your contact details (e-mail address, mobile phone number);
• your address;
• details of your current employment;
• identification and proof of right to work;

If you contact us by email, telephone or via a third-party website for example on application for a position, we may keep a record of that correspondence.

This information is stored securely within our CRM system, we use this data to assess suitability for the position applied for and potentially matching you to positions in the future.

Finally, if you have interacted with us via social media e.g. by sending us a message through Twitter or Facebook, we may contact you via those platforms.

Special Category Data (also known as sensitive personal information)

We do not collect any special categories of personal information about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences. If you have disability requirements we may store the information you provide to us about your disability in order to improve our service to you.

3. COOKIES

A cookie is a small file of letters and numbers that we store on your browser or device if you agree. We use the following types of cookies:

1. Strictly necessary cookies. These are cookies that are required for the operation of our Website.
2. Analytical/performance cookies. These cookies allow us to recognise and count the number of visitors and to see how visitors move around our Website. This helps us to improve the way both sites work, for example, by ensuring that users are finding what they are looking for easily.
3. Social Media Sharing Buttons. We do use sharing buttons in order to make it easier for you to follow our content via your social media pages. These buttons are third-party cookies which are placed onto your device when you visit our Website. Even without you clicking on the relevant sharing button, these sites are aware that you have visited our Website and may use this information when building their profile of you and deciding what advertisements you might like to see. You should check the respective policies of each of these social networks to see how exactly they use your personal information. This process does not involve us collecting or storing any of your personal information ourselves.

4. HOW WE USE YOUR PERSONAL INFORMATION

We will only use your personal information when the law allows us to. Most commonly, we will use your personal information in the following circumstances:

• with your consent;
• where we need to perform a contract with you e.g. ;
• 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 (see the “Legitimate Interests” section below); or
• where we need to comply with a legal or regulatory obligation.

If you have contacted us and provided contact information, we will send you periodic e-mails and possibly telephone call advising you of positions we think you might be interested in. You can opt-out of receiving this contact at any time by clicking the appropriate link in the e-mail itself if available or replying to the sender directly citing your preference to no longer be contacted. You may also send an email directly to our data controller using the email address: GDPR@maldonpartners.com

We may use personal information held about you in the following ways:

• to inform our client of your application to their advertised position;
• to advise you of the progress of your application;
• to ensure we provide the best possible service by confirming your suitability to the position;
• to respond to queries you send us.

When contacting you for any of the above purposes we may do so by phone or email, unless you tell us otherwise. Your data will be treated in accordance with applicable data protection law. It will not be disclosed to anyone outside of Maldon Partners Ltd, and any other parties named or described in section 8 below.

5. LEGITIMATE INTERESTS

We may rely on legitimate interests to process your personal information, provided that your interests do not override our own. Where we rely on legitimate interests, these interests are:

1. to keep our records updated and to study how our services are used;
2. to administer and protect our business and online presence (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting, any data passed to us by third party referrers for example job boards or social media interaction);
3. to inform our marketing strategies;
4. to grow our business;
5. to ensure that your rights and interests are fully considered and protected at all times;

6. KEEPING YOUR PERSONAL INFORMATION SAFE

We employ a variety of physical and technical measures to keep your personal information safe and to prevent unauthorised access to, use or disclosure of it.
We control who has access to your data (using both physical and electronic means). These means include an electronic firewall and other protection measures that involve virus scanning, installation of security patches, vulnerability testing, backup and recovery planning, security audits and other steps designed to improve data protection.
Our staff receive data protection training and we have a set of detailed data protection procedures which they are required to follow when handling personal information.

7. STORAGE AND RETENTION

Where we store your personal information

Electronic data and databases are stored on secure servers, however the third-party systems we use means the data may be stored outside of the EEA, this would include CRM system, job boards, websites where you make the application which is then passed on to us via email or other means.

How long we keep it

We collect and store personal information for purposes connected with our business. As such, we will only retain your personal information for as long as necessary for those purposes.

If you apply for a position, we will retain your personal information for five years from the date of your last contact with us. We feel this is appropriate as we are able to save time for us and yourself if in future you are seeking other opportunities, we would also like to keep you informed of any new or suitable positions that we feel are appropriate.

If you apply for a temporary or contract position we keep information about our commercial relationship with you for seven years from the date of the last transaction with us. This is because we may need this data in some way to support a claim or defence in court. That is also the period within which our tax collecting authorities may demand to see and audit our records.

8. DISCLOSING YOUR PERSONAL INFORMATION

We may need to disclose your personal information to third parties. Where we do so, any such disclosure will be on the basis that these third parties are required to keep the data we give them confidential and secure and will not use it for any other purpose than to carry out the services they are performing for us.

When you apply for a position we will store the information into a secure CRM system, we disclose your name and e-mail address and CV to the potential employer. We do this for two main reasons:

• to allow them to continue with the application process as per their standard recruitment terms.
• to allow them to assess your suitability per their criteria for the position.
• to allow them to carry out any checks they may require with the aim of offering employment.

You can change your communication preferences at any time by contacting us.

If we choose to sell, transfer, or merge parts of our business or our assets, we may disclose your personal information to the new owners of the business. 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 information in the same way as set out in this policy.

9. DISCLOSURES REQUIRED BY LAW

We are subject to the law like everyone else. We may be required to give information to legal authorities if they so request or if they have the proper authorisation such as a search warrant or court order.

We also may need to retain and disclose certain personal information about you to regulatory authorities and to appropriate agencies to conduct anti-money laundering and trade sanction checks and to assist with fraud prevention. We will disclose this information as is required by law.

10. YOUR RIGHTS

We want you to remain in control of your personal information. Part of this is making sure you understand your legal rights, which are as follows:

1. where your personal information is processed on the basis of consent, the right to withdraw that consent;
2. the right to confirmation as to whether or not we are holding any of your personal information and, if we are, to obtain a copy of it;
3. from 25 May 2018, the right to have certain data provided to you in a portable electronic format (where technically feasible);
4. the right to have inaccurate personal information rectified;
5. the right to object to your personal information being used for marketing or profiling, or on the basis of our or a third party’s legitimate interest;
6. the right to restrict how your personal information is used; and
7. the right to be forgotten, which allows you to have your personal information erased in certain circumstances (though this is not an absolute right and may not apply if we need to continue using it for a lawful reason).

If you would like further information about any of your rights or wish to exercise them, please contact us using the details given in section 1.

Please keep in mind that there are exceptions to the rights above and, though we will always try to respond to your satisfaction, there may be situations where we are unable to do so (for example, because the information no longer exists or there is an exception which applies to your request).

If you are not happy with our response, or you believe that your data protection or privacy rights have been infringed, you should contact the UK Information Commissioner’s Office, which oversees data protection compliance in the UK.
Details of how to do this can be found at www.ico.org.uk.

11. UPDATING THIS POLICY

We may update this Policy at any time. When we do, we will post a notification on our Website and we will also revise the updated date at the bottom of this page. We encourage users to frequently check this page for any changes to stay informed about how we are helping to protect the personal information we hold.

This policy was last updated on 24th May 2018.