Privacy Policy

Policy version: November 2021

We take your privacy very seriously. Please read this privacy policy carefully as it contains important information on who we are and how and why we collect, store, use and share any information relating to you (your personal data). It also explains your rights in relation to your personal data and how to contact us or a relevant regulator in the event you have a complaint. 

Universal Search Group Limited (Company number 13168167) (USG) (“we”, “us”, or “our”) collect, use and are responsible for certain personal data about candidates, or prospective candidates who are registering with us for roles (including at USG), clients and suppliers, and users of our website (collectively “you” or “your”). We are the data controller in relation to the processing activities set out below, meaning we are the organisation legally responsible for deciding how and for what purposes your personal data is used. 

This privacy policy reflects the standard required by the UK General Data Protection Regulation (GDPR). Some elements of this policy may not be applicable to individuals’ rights in other jurisdictions and this policy doesn’t establish additional rights to those set out in any applicable local data protection law. 

Personal data we collect about you 

We collect a range of personal data about you, including: 

• contact details e.g. your name, address, email address and telephone number and company name 

• information to check and verify your identity, e.g. date of birth 

• sensitive data 

• your billing information, transaction and payment card or other payment method information 

• details of any information, feedback or other matters you give to us by phone, email, post or via social media 

• your account details, such as username and login details 

• your activities on, and use of, our website 

• your personal or professional interests 

• your professional online presence, e.g. LinkedIn profile 

We collect and use this personal data to provide recruitment services. If you do not provide personal data we ask for, it may delay or prevent us from providing those services. 

How your personal data is collected 

We collect personal data about you: 

• directly from you, when you provide or send us information such as when you register with us or send us your CV, contact us (including via email), or via this website or social media platforms including Linked-In or otherwise; and indirectly, such as your browsing activity while on our website e.g. we automatically collect information about your visit to our website (such as the date, times and frequency of your visits). We may use your data to show you content on other websites. If you do not want us to use your data in this way, please turn off the relevant cookies; and from other sources, including third parties with your consent including referees and previous employers, networking events and similar, and educational establishments.

How and why we use your personal data 

Under data protection law, we can only use your personal data if we have a proper reason, e.g.: 

• where you have given consent; this may include us contacting you about our services, or about networking events, or where you are applying for a particular role which requires us to process your personal data 

• to comply with our legal and regulatory obligations; this may include identifying you, verifying data we hold about you, establishing your right to work and or assisting the authorities with investigations, or 

• for our legitimate interests or those of a third party; this may include contacting you via phone, email or social media to provide information about our services, matching your details with vacancies, carrying out engagements with our clients and improving our service to clients and candidates by recording calls 

A legitimate interest is when we have a business or commercial reason to use your personal data, so long as this is not overridden by your own rights and interests. We will carry out an assessment when relying on legitimate interests, to balance our interests against your own. 

How and why we use your personal data—Special category personal data 

Certain personal data we collect is treated as a special category to which additional protections apply under data protection law, including sensitive personal data revealing racial or ethnic origin, political opinions, religious beliefs, philosophical beliefs or trade union membership or concerning health or sexual orientation. 

Where we process such special category personal data, we will also ensure we are permitted to do so under data protection laws. 

Marketing 

We may use your personal data to send you updates (by email, text message, telephone or post) about our services. 

We have a legitimate interest in using your personal data for marketing purposes (see above ‘How and why we use your personal data’). This means we do not need your consent to send you marketing information. If we change our marketing approach in the future so that consent is needed, we will ask for this separately and clearly. 

You have the right to opt out of receiving marketing communications at any time by contacting us. 

We will always treat your personal data with the utmost respect and never share it with other organisations for marketing purposes. 3 

Who we share your personal data with 

We routinely share personal data with: 

• Prospective employers so that we can apply for jobs or assess your suitability or eligibility for roles 

• Third parties we use to help deliver our services to you 

• Other third parties we use to help us run our business 

• Regulatory or law enforcement agencies 

How long your personal data will be kept 

We will keep your personal data whilst we need it for the purposes set out in this policy, which in some instances may be ongoing. We may, however, need to retain your personal data for different periods as may be required by law, or to respond to any questions, complaints or claims. 

We will not keep your data for longer than necessary. When it is no longer necessary to keep your personal data, we will delete or anonymise it. 

Transfer of personal data 

It may sometimes be necessary for us to transfer your data. If we do so, we will only do so for the legitimate purposes set out in this policy and in accordance with this policy. 

Where we deliver services to you in the UK, it is sometimes necessary for us to share your personal data outside the UK, e.g. 

• With our clients and service providers located outside the UK 

• If you are based outside the UK 

Under data protection laws, we can only transfer your personal data to a country outside the UK where: 

• the UK government has decided the particular country ensures an adequate level of protection of personal data (known as an ‘adequacy decision’) 

• there are appropriate safeguards in place, together with enforceable rights and effective legal remedies for you, or 

• a specific exception applies under the data protection law. 

Your rights 

You generally have the following rights, which you can usually exercise free of charge: Access to a copy of your personal data

• Access to a copy of your personal data – The right to be provided with a copy of your personal data.
• Rectification – right to require us to correct any mistakes in your personal data.
• Erasure (also known as the right to be forgotten) -The right to require us to delete your personal data – in certain situations
• Restriction of use – The right to require us to restrict use of your personal data in certain circumstances, eg if you contest the accuracy of the data
• Data portability – The right to receive the personal data you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations
• To object -The right to object to your personal data being used for direct marketing (including profiling) and in certain other situations to our continued use of your personal data, eg where we use your personal data for our legitimate interests.
• Not to be subject to decisions without human involvement -The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you
• The right to withdraw consents – If you have provided us with a consent to use your personal data you have a right to withdraw that consent easily at any time.

For further information on each of those rights, including the circumstances in which they do and do not apply, please contact us (see ‘How to contact us’ below). 

Keeping your personal data secure 

We have appropriate security measures to prevent personal data from being accidentally lost or used or accessed unlawfully. We limit access to your personal data to those who have a genuine need to access it. 

We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so. 

How to complain 

Please contact us if you have any queries or concerns about our use of your personal data (see below ‘How to contact us’). We hope we will be able to resolve any issues you may have. 

You also have the right to lodge a complaint with the UK Information Commissioner. 

How to contact us 

You can contact Thomas Shotton] by post, email or telephone if you have any questions about this privacy policy or the information we hold about you, to exercise a right under data protection law or to make a complaint.