Rowlands Group Ltd
Privacy Statement
Rowlands Group Limited (“Rowlands”, “us”, “we”) is a private company incorporated in Jersey with the registered company number 117840. Rowlands is a recruitment business which provides recruitment services to its clients and work-seekers (candidates). We also provide temporary employment services to our clients and employ temporary employees.
We take data protection and privacy seriously and your personal data is protected by The Data Protection (Jersey) Law 2018 (“DPJL”). Rowlands must process personal data (including, at times, a limited amount of sensitive personal data) so that we can provide our recruitment services – in doing so, Rowlands acts as a data controller and in some cases a joint data controller with our clients. Where your personal data is shared with other parties, the privacy policies of those parties will also apply to your personal data and the way in which it is processed. Please refer to the individual privacy policy of those parties for further information.
This Privacy Policy explains what kind of personal data we collect about you, how we collect it and use it and how we protect it. It also explains the rights that you have as a data subject. This Privacy Policy covers the personal data of our clients, candidates, temporary employees, suppliers, website users, and people whose data we receive from candidates such as referees and emergency contacts. Rowlands is committed to maintaining a high level of security and confidentiality relating to all personal data that we deal with.
Please note we may amend this Privacy Policy from time to time. Please continue to visit our web page if you would like to stay up to date, as we will post any changes or updates there: https://www.rowlands.co.uk/legal_documents/privacy_policy
If you have any further questions about our Privacy Policy, please do not hesitate to contact us using the details listed below.
Data controller
The Data Controller (as defined in the DPJL) is Rowlands Group Limited, a company registered in the Island of Jersey with the following address: Trinity House, Bath Street, St Helier, Jersey, JE2 4ST, which includes:
Rowlands Recruitment Limited;
Rowlands Graduate;
Rowlands Training Services;
Rowlands Executive; and
Rowlands Temporary Resourcing
Name: Rowlands Group Limited FAO Maggie Meiklejohn
Telephone: +44 (0)1534 626777
Email: mydata@rowlands.co.uk
The type of personal data that we collect
Candidates
To enable us to provide you with the highest level of service and place you in the job role that you want, we need to collect and process certain information about you, including (but not limited to) your name, address, contact details, age/date of birth, residential qualifications, employment history, other information provided within your CV and your social security number. We may also collect information that relates to any health issues or disabilities to the extent that this information may be relevant to the type of employment you are seeking, in addition to details about any criminal convictions.
Temporary employees
To enable us to provide you with the highest level of service and help you fulfil your temporary assignment(s) under Rowlands Zero Hour Contract, we need to collect and process certain information about you, including (but not limited to), your name, address, contact details, age/date of birth, residential qualifications, professional qualifications, bank account details, ITIS rate and social security number. We also collect information in relation to your employment history, residential history and details about any criminal convictions.
Clients
To help you to find and recruit the right candidates for your organisation, we collect information such as contact details of individual contacts at your organisation (including their names, telephone numbers and e-mail addresses). This enables us to engage with you when we have suitable candidates and provide you with a high level of service.
Suppliers
In order for us to engage you to provide us with certain services, we collect information such as contact details of individual contacts at your organisation (including their names, telephone numbers and e-mail addresses) in addition to bank details so that we can pay you for the services that you provide, in accordance with our contractual obligations.
Referees and emergency contacts provided by candidates or temporary employees
In order to provide a high quality recruitment service and also to prioritise the safety of our candidates and employees, we collect basic contact details such as a name and contact number or e-mail address. This enables us to contact you if one of our candidates or temporary employees have listed you as a referee to verify information such as employment or education history or if they have listed you as their emergency contact.
People who use our website
When you browse our website, we will collect information about how and when you use the website and information that is collected automatically via cookies. We collect this data to improve our website and ultimately enhance your user experience. We may also collect data such as your name and e-mail address if you provide this information through our website.
If you use our candidate account area within the website we will collect the personal information that is provided directly by your (for example your name, e-mail address and a copy of your CV). Our website is secure and meets ISO certification. Your information will remain within this secure environment unless it is deleted by you (through the 'Right To Be Forgotten' request in your account profile area) or you may contact our data controller who can delete this on your behalf.
How we collect your personal data
Candidates
Where appropriate and in accordance with any local laws and requirements, the main ways that we collect personal data of candidates are:
from information provided directly by you (for example, within your application form and your CV and information that you provide through our website or in other communications you have with us);
from information received from third parties (for example, through referees, interviewers, clients, websites such as LinkedIn, Facebook or Twitter, jobs boards or through third party testing and screening providers); and
from information that we collect automatically when you visit our website or use our chat function (for example, information relating to your movement throughout our website and information collected automatically via cookies).
Temporary employees
Where appropriate and in accordance with any local laws and requirements, the main ways that we collect personal data of temporary employees for the screening process are:
from information provided directly by you, for example, the information that you provide through our screening/on-boarding process and through other communications that we have with you; and
from the information received from third parties, including (but not limited to) referees, including reference providers such as previous institutions where you have studied, worked, are currently (or were previously) a director, obtained a professional qualification, have professional membership with, your accountant to confirm periods of self-employment, job agencies to confirm periods of non-employment, our trusted third party suppliers to enable your personal data checks to be completed in jurisdictions outside of the UK, verification application databases and companies providing credit check services, Disclosure and Barring Services (DBS) or Disclosure Scotland for Criminal Records Checks.
Clients
Where appropriate and in accordance with any local laws and requirements, the main ways that we collect personal data of our clients are:
from information provided directly by you (for example, when we are communicating in relation to placing individuals within your organisation); and
from information that we collect automatically when you visit our website or use our chat function (for example, information relating to your movement throughout the website and information collected automatically via cookies)
Suppliers
Where appropriate and in accordance with any local laws and requirements, the main ways that we collect personal data of our suppliers are:
from information provided directly by you (for example, when you provide us with your contact and payment details); and
from information that we collect automatically when you visit our website or use our chat function (for example, information relating to your movement throughout the website and information collected automatically via cookies).
Referees and emergency contacts provided by candidates or employees
We are provided with your details by candidates or employees who have listed you as either a referee or their emergency contact.
People who use our website
When you visit our website we collect some information automatically through cookies which provide us with information to help us to improve your experience. There is further information in the cookies section below. We also collect information from you through your use of the chat function or any information that you provide through our website such as your name, contact details and CV. We also collect data through our e-mail service provider in relation to whether or not you open the e-mails that we send.
Legal basis and purpose for processing personal data
Some categories of the personal data that we collect from you are required to enable us to fulfil our contractual duties to you or to others. Some other categories of personal data are required by statute, for example, our requirement to collect candidates’ social security numbers. Our clients may also require this personal data, and/or we may need your data to enter into a contract with you. If you decide not to provide us with your personal data, we may be unable to fulfil our contractual obligations and may be unable to provide you with our recruitment services or engage you to provide us with services.
Other categories of personal data may be required so that we can provide you with an efficient service based on our legitimate interests as a recruitment services provider (further detail is provided below). Where our legal basis for processing your data is based on our legitimate interests, in certain circumstances you have the right to object to us processing your data on this basis if you wish. Please see below for more information about your right to object to the processing of your data.
Candidates
The main purpose for which we use your personal data is to help you to find suitable employment options by providing an effective recruitment service which is tailored to your specific requirements. This could include for example, contacting you about job opportunities, assessing your suitability for those opportunities, updating our databases, putting you forward for job opportunities, arranging payments to you and developing and managing our services and relationship with you and our clients. We do not sell personal information collected through this site or use your personal information for any other purposes than those stated above.
In accordance with the DPJL, the main legal basis upon which we use and process your personal data is because such processing is necessary for the purposes of legitimate interests pursued by Rowlands (as the data controller) or by a third party or parties to whom the data are disclosed. Our legitimate interests are to provide recruitment services to both our candidates and clients to help match individuals to the right jobs within the right organisations. In order to rely upon this basis for processing, the processing must not be unwarranted in any particular case by reason of prejudice to the rights and freedoms or legitimate interests of you (as the data subject).
If you are looking for employment opportunities or have provided your CV information and other personal information on a jobs board, professional networking site or directly to us, we think that it’s reasonable to assume that you are happy for us to collect and otherwise use this personal data to try and assist you by offering or providing you with our tailored recruitment services. This may include sharing that information with prospective employers and assessing your skills against the job positions that we are recruiting for. We also think that it’s reasonable to expect that as the recruitment process progresses, prospective employers may want to verify the information that you have provided to us such as employment history, education and qualifications or may want you to complete various testing processes (to the extent that this is necessary, appropriate and in accordance with local laws) to ensure that they can pursue their legitimate interest to recruit the most appropriate candidate for the role. We need to assist our clients with this so that we can operate successfully as a recruitment business and continue to successfully place our candidates in roles.
We use your data in a way which we believe you would reasonably expect us to use it, given our legitimate interest as a recruitment services provider. We do not believe that the manner in which we process your personal data prejudices your rights and freedoms or legitimate interests. In fact, the way in which we process your personal data enables us to provide a better service to both our clients and candidates so this is beneficial to all parties.
Some categories of personal data, such as any health data or data relating to any criminal convictions, are processed on the basis that you have provided your explicit consent for us to do so. You can withdraw this consent at any point by contacting us on the contact details provided above. We may also use your personal data to send you vacancy alerts or for marketing purposes such as sending you our newsletter. We will require your explicit consent in order for us to send this to you. Even where you have previously provided your consent for us to circulate our newsletter or to receive vacancy alerts, you can withdraw this consent at any time by clicking the unsubscribe button at the bottom of the e-mail.
Temporary employees
The main purpose for which we use your personal data is principally for the purposes of identifying and placing you on Temporary Assignments. For the Employer’s business and administrative purposes including payroll and for the purposes of complying with applicable laws, regulations and procedures.
Rowlands and our clients jointly are responsible for determining the legal basis for your temporary employment screening for each temporary assignment. We collect your personal data and will request your consent to process the data you have provided. This consent is required to facilitate the employment screening process by enabling us to process your data and obtain information and verifications from relevant parties. Typically these relevant parties (organisations and referees) will not share your information unless we can demonstrate that our request is made with your knowledge and agreement.
Article 11 of the DPJL states that consent “means any freely given, specific, informed and unambiguous indication of the data subject’s wishes by which he or she, by a statement or a clear affirmative action, whether orally or in writing, signifies agreement to the process of that data”. In plain language, this means that:
you have to give us your consent freely, without us putting you under any type of pressure;
you have to know what you are consenting to – so we’ll make sure we give you enough information;
you should have control over which process activities you consent to and which you don’t; and
you need to take positive and affirmative action in giving us your consent – we’re likely to provide a tick box for you to check so that this requirement is met in a clear and unambiguous fashion.
We will keep records of the consents that you have given in this way. The main purpose for which we use your personal data is to provide an effective screening service to verify information in order to help you to find suitable employment options. We do not sell personal information collected through this site or use your personal information for any other purposes other than those stated above.
Clients
The main purpose for which we use information about our clients is to enable us to provide our recruitment services to you, mainly through sourcing appropriate candidates to place within your organisation. We think it’s reasonable to expect that if you are working with us in order to find a candidate to fill a vacancy within your organisation that we would use your data to assist with this process if we identify a potential candidate. We may also use your information to invite you to events that we think may be of interest to you, for example the Recruitment Forum, or to circulate market updates.
We use your data in a way which we believe you would reasonably expect us to use it, given our legitimate interest as a recruitment services provider. We believe that the manner in which we process your information is necessary for the purposes of our legitimate interests as an organisation providing you with these recruitment services and does not prejudice your rights and freedoms or legitimate interests.
Suppliers
The main purpose for which we use information about our suppliers is to enable our business relationship to operate effectively, so that we can continue to engage you to provide us with services. We think it’s reasonable to expect that if you are providing us with a service, we will use information such as your contact details and payment details to ensure that we can communicate with you in relation to the services that you provide to us and pay you for them, in accordance with our contractual obligations. We use your data in a way which we believe you would reasonably expect us to use it given our legitimate interests as a recipient of your services. We do not believe that the manner in which we process your personal data prejudices your rights and freedoms or legitimate interests.
Referees and emergency contacts provided by candidates or employees
If you have been listed as a referee by a candidate, we will use your personal data to contact you to verify various details, for example relating to their employment history. This is to ensure that we are placing appropriate candidates in appropriate roles. If you have been listed as an emergency contact by a candidate or an employee, we will use your personal data to contact you in the event of an accident or emergency affecting that individual. We use your data in a way which we believe you would reasonably expect us to use it given our legitimate interests as a recruitment services provider and an employer. We do not believe that the manner in which we process your personal data prejudices your rights and freedoms or legitimate interests.
People who use our website
The main purpose for which we use your data is to optimise our website and improve your experience. We use your data in a way which we believe you would reasonably expect us to use it given our legitimate interest to improve website performance. We do not believe that the manner in which we process your personal data prejudices your rights and freedoms or legitimate interests. There is more information on this in the cookies section below.
Who we share your personal data with
Where your personal data is shared with other parties, the privacy policies of those parties will also apply to your personal data and the way in which it is processed and the period for which it will be retained. This may be different to the provisions contained in this Privacy Policy and may continue to apply in the event that our relationship with that party comes to an end. Please refer to the individual privacy policies of those parties for further information. We can provide you with copies of these individual privacy policies upon written request.
Candidates
In order to place you in the job that you want, we may share your personal data with the following categories of people, including but not limited to:
prospective employers;
individuals and organisations who hold information related to your reference or application to work, such as current, past or prospective employers, educators and examining bodies and employment and recruitment agencies;
group companies or trusted third parties such as our service providers (including companies providing testing and screening services, to the extent that these checks are appropriate and in accordance with local laws) client service providers or external consultants (only where you have expressly consented to us doing so) where we feel this will help us to provide you with the best possible service;
trusted third parties such as our service providers including IT and software service providers; and
government regulatory bodies or law enforcement agencies where considered necessary for us to fulfil any legal obligations applicable to it.
Temporary employees
In order to provide our employment screening services to help you secure a temporary assignment, we may share your personal data with the following categories of people, including but not limited to:
Clients (and their on-boarding partners) of Rowlands Temporary Resourcing with whom you hold your Temporary Assignment with;
Individuals and organisations who hold information related to your reference or application to work, such as current or past or prospective employers, other referees who you have provided, educators and examining bodies, employment and recruitment agencies, credit references agencies or bankruptcy databases, Disclosure and Barring Services (DBS) or Disclosure Scotland for Criminal Records Checks.
Trusted third parties such as our service providers including IT and software service providers;
Trusted third party service providers that enable your personal data checks to be completed in jurisdictions outside of Jersey; and
Government regulatory bodies or law enforcement agencies where considered necessary for us to fulfil any legal obligations applicable to it
Clients
Unless you specify otherwise, we may share your information with prospective candidates, within the Rowlands Group or with trusted third parties such as our service providers where we feel this will help us to provide you with the best possible service.
Suppliers
Unless you specify otherwise, we may share your information within the Rowlands Group and with trusted third parties such as our service providers and organisations that we provide services to.
Referees and emergency contacts provided by candidates or employees
Unless you specify otherwise, we may share your information within the Rowlands Group and with trusted third parties such as our service providers and organisations that we provide services to.
People who use our website
We may share your information within the Rowlands Group and with trusted third parties such as our IT service providers and e-mail service providers.
Transferring your data internationally
We may transfer some of the information you provide to us to countries outside the European Economic Area (‘EEA’) for the purposes of providing our work finding services. In relation to suppliers, your personal data may be held on cloud based systems which are located outside of the EEA. We will take steps to ensure adequate protections are in place to ensure the security of your information. The EEA comprises the EU member states plus Norway, Iceland and Liechtenstein.
How long we keep your personal data for
We only retain your personal data for as long as is necessary for us to use your personal data for the purposes described above or to comply with our legal obligations. However, we may need to continue to hold some of your personal data after this period in order to comply with our legal obligations.
When determining the relevant retention periods, we will consider factors such as:
our contractual obligations and rights in relation to the relevant personal data;
any legal obligation(s) that we have under applicable law to retain data for a certain period of time;
our legitimate interests;
statute of limitations under applicable law(s);
(potential) disputes;
any requests that you may have made for your information to be deleted; and
guidelines issued by relevant data protection authorities.
Once we have deleted your personal data we will no longer hold this data and you will therefore be unable to exercise your rights of access, erasure, rectification and data portability after this time.
Candidates
We will delete your personal data from our systems if we have not had any meaningful contact with you for three years, unless you within your right request that we delete or erase your data sooner.
Temporary employees
Most personal information about Temporary Employees which the Employer holds is likely to be relevant to the nature of the employee’s employment any such personal information should be held until after 10 years after the date that the Temporary Employee ceases to work at the Employer. However, Personal Data may be retained for longer if the Employer considers there is a valid reason to believe that it is likely to be needed in future. As soon as the Employer becomes aware of any contemplated litigation, all documents potentially relating to that litigation must be preserved and routine document destruction procedures for those documents must be placed on hold.
Temporary screening carried out will be kept on file for the duration of your temporary assignment and will be kept on your record for as long as you are actively a candidate of Rowlands Recruitment.
Website users
Your information will remain within this secure environment unless it is deleted by you (through the 'Right To Be Forgotten' request in your account profile area) or you may contact our data controller who can delete this on your behalf.
Your rights as a data subject
Under the DPJL, greater rights are afforded to individuals in respect of their personal data and you can exercise these rights even after you have provided us with your personal data. We have set out information regarding these rights below, but if you would like any further information or clarification in respect of any of these rights, please do not hesitate to contact us. We will aim to deal with your request as soon as possible and in any event within 4 weeks (subject to any extensions that we are lawfully entitled to). Please note that any communications which you make in relation to such a request may be recorded in order to enable us to resolve any issues efficiently.
Your right to object to the processing of your personal data
You have the right to object to our processing of your personal data where the processing is carried out for one of the following reasons:
our legitimate interests;
to enable us to perform a task in the public interest or exercise official authority;
for direct marketing purposes; or
for scientific, historical, research, or statistical purposes.
The “legitimate interests” and “direct marketing purposes” categories above are the most relevant here.
If you object to us processing your personal data for direct marketing purposes, we are obliged to stop the processing. If you object to us processing your personal data because we deem it necessary for our legitimate interests, we will be obliged to stop the processing unless we can show that we have compelling legitimate grounds for processing which override your interests or that the processing is necessary for the establishment, exercise or defense of a legal claim.
Other rights
Your right to request access (data subject access requests)
You have the right to request confirmation from us as to whether your personal data is being processed by us as the data controller (or on behalf of us) and if so, you have the right to request information regarding certain aspects of the processing and access to your personal data. We will not charge you for providing you with access to the personal data which we hold for you, unless your request is “manifestly unfounded or excessive” or if you are requesting further copies of information that we have already provided to you. In such cases, we may charge you a reasonable administrative cost where legally permissible. We may also request further information from you in order to verify your identity. Where we are legally permitted to do so, we may refuse to act on your request but we will always provide reasons if we do so.
Your right to rectify your personal data
If any of the personal data that we hold for you is inaccurate or incomplete, you have the right to make a written request that we rectify the personal data. If we are satisfied as to the accuracy and completeness of such personal data, we are entitled to take no further action but we will always explain our reasoning for this. In order for us to provide you with the best possible service, it is important that the personal information that we hold about you is accurate and complete. Please keep us informed if your personal information changes during the period for which we hold your data.
Your right to be forgotten (the right of erasure)
You have the right to request that we erase the personal data that we hold for you if certain circumstances apply, such as:
the personal data are no longer necessary for the purpose for which they were originally collected and/or processed;
you have withdrawn your consent to us processing your data, and there is no other valid legal reason for us to continue processing;
where the basis on which we process your personal data is because we believe that it’s necessary to do so for our legitimate interests and you object to the processing on that basis and we are unable to demonstrate any overriding legitimate grounds for our continued processing;
where you object to the processing of your personal data for direct marketing purposes;
the data has been processed unlawfully (i.e. in a manner which is not compliant with the DPJL); or
it is necessary for the personal data to be erased in order for us to comply with our legal obligations as a data controller.
To the extent that the processing is necessary for any of the following reasons, we are entitled to refuse to comply with the request for erasure:
to exercise the right of freedom of expression and information;
to comply with legal obligations or for the performance of a public interest task or exercise of official authority;
for public health reasons in the public interest;
for archival, research or statistical purposes; or
to establish, exercise or defend a legal claim.
Your right to restrict processing
You have the right to request that we restrict the processing of your personal data where one of the following circumstances applies:
where you contest the accuracy of the personal data that we are processing about you. In this case, we would restrict the processing of your personal data until the accuracy of the data is verified;
where our processing of your data is unlawful, but you would prefer that we restrict our processing of it rather than erasing it;
where we have no further need to process your personal data but you require the data to establish, exercise, or defend legal claims; or
where you object to our processing of your personal data for our legitimate interests (or public function). In this case, you can request that we restrict the processing of your personal data until we verify our grounds for processing it.
If you obtain a restriction of processing of your data, we will still be able to store your data but we won’t be able to continue to process it unless you consent or the processing is for the purposes of legal proceedings, vital interests (i.e. matters of life or death) or in the public interest. We will, of course, inform you before we lift any such restriction.
In relation to the above rights of rectification, erasure and restriction of processing, if we have shared the personal data with third parties, we will notify them about the rectification or erasure of personal data or restriction of processing, unless this is impossible or involves disproportionate effort. If requested by you, we will also tell you which third parties we have disclosed the personal data to. In the event that we think that it’s reasonable for us not to comply with your request, we will explain our reasons for this decision.
Your right to data portability
You have the right to obtain and transfer your personal data between data controllers, so that you can reuse your personal data for your own purposes across different services on another online platform. This right of data portability applies where the personal data:
has been provided to us by you;
is processed based on your consent or in order to fulfil a contract; and
is processed automatically (i.e. without any human intervention).
We will provide you with your data in a commonly used machine-readable format or alternatively, where technically feasible, we may directly transfer the data for you.
If we have reasonable doubts in relation to the identity of an individual making any of the above requests, we may request further information from you in order to verify your identity.
Where we think that it is reasonable for us not to take any action in relation to one of the above requests, we will explain our reasons for this decision.
Automated individual decision making
Because our recruitment services require human involvement throughout the process, there won’t be any instances where a decision is made based solely on automated decision making.
Withdrawal of consent
You have the right to withdraw this consent at any time. You can do this by contacting Rowlands directly.
Your right to complain to the Data Protection Authority
You have to the right to lodge a complaint with the Data Protection Authority through the Office of the Information Commissioner. The Office of the Information Commissioner can be contacted in the following ways:
Telephone:+44 (0)1534 716530
Email: enquiries@jerseyoic.org
Address: Office of the Information Commissioner, 2nd Floor, 5 Castle Street, St Helier JE2 3BT
Website: https://oicjersey.org
If you would like to exercise any of these rights, or withdraw your consent to the processing of your personal data (where consent is our legal basis for processing your personal data), details of how to contact us can be found above. Please note that we may keep a record of your communications to help us resolve any issues which you raise.
How we protect and store your data
We have a range of technical and organisational measures in place to ensure that your personal data is appropriately safeguarded including policies and procedures to deal with any suspected data breach.
Where we engage a third party to process your personal data (for example, a testing or screening company), we will seek to enter into an agreement to specify the obligations of each party and we will endeavour to ensure that any such third party has appropriate measures in place to protect your personal data against any unauthorised or accidental use, access, disclosure, damage, loss or destruction.
The data you provide to us is stored on cloud based systems.