ClearHub (”We” or “Us” or “Our”), a division of Clearvision (CM) 2005 Limited and Clearvision USA, Inc., is committed to protecting and respecting your privacy.
Any reference to our Group means our subsidiaries, our ultimate holding company and its subsidiaries, our associated companies as defined in section 1159 of the UK Companies Act 2006 (our Group).
This notice, together with any terms and conditions or framework agreement between us and you, sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us.
The General Data Protection Regulation (GDPR) (Regulation (EU) 2016/679) replaced the Data Protection Regulation (Directive 95/46/EC) with effect from 25th May 2018. The GDPR aims to harmonise data protection legislation across EU member states, enhancing privacy rights for individuals and providing a strict framework within which commercial organisations can legally operate.
Even though the UK will leave the EU in March 2019, the GDPR will be applicable in the UK from 25th May 2018. The Government intends for the GDPR to continue in UK law post Brexit and has also introduced a Data Protection Bill to replace the current Data Protection Act 1998 in due course.
Your new rights under the GDPR are set out in this notice but will only apply once the GDPR comes into effect on 25th May 2018.
Please read the following carefully to understand our views and practices regarding your personal data and how it will be utilised.
For the purposes of data protection legislation in force from time to time the data controller is Clearvision of Laurel Farm, Wintershill, Durley, Southampton, SO32 2AH, United Kingdom.
We are a dedicated Atlassian Contractor Placement Service business, we also provide IT contractors and consultancy (our “Services”). We collect the personal data of the following types of people to allow us to undertake our business:
Prospective and placed candidates for permanent or temporary roles;
prospective and live client contacts;
supplier contacts to support our services; and
employees, consultants, temporary workers.
We collect information about you to carry out our core business and ancillary activities.
This is information about you that you give us by utilizing our website (completion of forms) www.clearhub.tech (our “Site”) or by corresponding with us by phone, e-mail or otherwise. It includes information you provide when you register to use our Site, to enter our database, subscribe to our Services, attend our events, participate in discussion boards or other social media functions on our Site, enter a competition, promotion or survey and when you report a problem with our Site.
The information you give us or we collect about you may include your name, address, private and corporate e-mail address and phone number, financial information, compliance documentation and references verifying your qualifications and experience and your right to work in the United Kingdom, curriculum vitae and photograph, links to your professional profiles available in the public domain e.g. LinkedIn, Twitter, business Facebook or corporate website.
We and our third party service providers, including analytics and third party content providers, may automatically collect certain information from you whenever you access or interact with the Service. Each time you visit our Site we will automatically collect the following information:
Technical information, the information we collect also includes the Internet Protocol (“IP”) address or other unique device identifier (“Device Identifier”) for any device (computer, mobile phone, tablet, etc.) used to access the Service. A Device Identifier is a number that is automatically assigned or connected to the device you use to access the Service, and our servers identify your device by its Device Identifier; additional data we may collect is your login information if applicable, as well as browser type and version.
information about your visit, including the full Uniform Resource Locators (URL), to, through and from our Site (including date and time), pages you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs) and methods used to browse away from the page.
This is information we obtain about you from other sources such as LinkedIn, corporate websites, job board websites, online CV libraries, your business card, and personal recommendations.
We are working closely with third parties including [business partners, sub-contractors in technical, professional, payment and other services, advertising networks, analytics providers, search information providers, credit reference agencies and professional advisors. We may receive information about you from them for the purposes of our recruitment services and ancillary support services.
We use information held about you in the following ways:
To carry out our obligations arising from any contracts we intend to enter into or have entered into between you and us and to provide you with the information, products and services that you request from us or we think will be of interest to you because it is relevant to your career or to your organisation.
To provide you with information about other goods and services we offer that are similar to those that you have already utilized, been provided with or enquired about.
The core service we offer to our candidates and clients is the introduction of candidates to our clients for the purpose of temporary or permanent engagement. However, our Service expands to supporting individuals throughout their career and to supporting businesses’ resourcing needs and strategies.
Our legal basis for the processing of personal data is for legitimate business interests, described in more detail below, although we will also rely on contract, legal obligation and consent for specific uses of data.
We will rely on contract if we are negotiating or have entered into a placement agreement with you or your organisation or any other contract to provide Services to you or receive services from you or your organisation.
We will rely on legal obligation if we are legally required to hold information on to you to fulfil our legal obligations.
We will in some circumstances rely on consent for particular uses of your data and you will be asked for your express consent if legally required.
Our legitimate interests in collecting and retaining your personal data is described below:
As a dedicated Atlassian Contractor Placement Service, we introduce candidates to clients for permanent employment, temporary worker placements or independent professional contracts. The exchange of personal data of our candidates and our client contacts is a fundamental, essential part of this process.
In order to support our candidates’ career aspirations and our clients’ resourcing needs we require a database of candidate and client personal data containing historical information as well as current resourcing requirements.
To maintain, expand and develop our business we need to record the personal data of prospective candidates and client contacts. If you are looking for employment or have posted your CV information on a job board or professional networking site, it is reasonable to assume you are happy for us to use your personal data to provide you with our Services. This includes sharing information with prospective employers and assess your skills against our current vacancies. You can request to be removed from our database at any time by emailing email@example.com.
In order to provide a personalised and efficient Service, we would like to provide tailored job recommendations and relevant articles related to your career, job search and the IT industry. To deliver these Services, we think it is reasonable to process your data in order to send you the most relevant and appropriate content. From time to time, we would also like to invite candidates and clients to take part in surveys relating to contracted work / recruitment which aim to develop careers and prospects within the industry you work in.
Should we want or need to rely on consent to lawfully process your data we will request your consent by email or by an online process for the specific activity we require consent for and record your response on our system. Where consent is the lawful basis for our processing you have the right to withdraw your consent at any time.
to administer our Site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
as part of our efforts to keep our Site safe and secure;
to make suggestions and recommendations to you of our Site about goods or services that may be of interest.
We do not undertake automated decision making or profiling. We do use our computer systems to search and identify personal data in accordance with parameters set by a person. A person will always be involved in the decision-making process.
We will share your personal information with selected third parties including:
clients for the purpose of introducing candidates to them and for the purpose of arranging interviews and engagements;
clients, business partners, suppliers and sub-contractors for the performance and compliance obligations of any contract we enter into with them or you;
credit reference agencies, our insurance broker, compliance partners and other sub-contractors for the purpose of assessing your suitability for a role where this is a condition of us entering into a contract with you.
In the event that we sell or buy any business or assets, in which case we will disclose your personal data to the prospective seller or buyer of such business or assets.
If Clearhub and all of its assets are acquired by a third party, in which case personal data held about its customers / candidates / contractors will be one of the transferable assets.
If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply any terms and conditions or framework agreement and other agreements between us and you; or to protect the rights, property, or safety of ClearHub our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
The lawful basis for the third-party processing will include:
Their own legitimate business interests in processing your personal data, in most cases to fulfil their internal resourcing needs;
for the purpose of a contract in place or in contemplation;
to fulfil their legal obligations.
The data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (”EEA”). It may be transferred to third parties outside of the EEA for the purpose of our recruitment / contractor services. It may/will also be processed by staff operating outside the EEA who work for us or for one of our suppliers. This includes staff engaged in, among other things, our recruitment services and the provision of support services. By submitting your personal data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy notice.
All information you provide to us is stored on our secure servers. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our Site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access
We understand our legal duty to retain accurate data and only retain personal data for as long as we need it for our legitimate business interests and that you are happy for us to do so. Accordingly, we have a data retention notice and run data routines to remove data that we no longer have a legitimate business interest in maintaining.
We do the following to try to ensure our data is accurate:
Our website enables you to manage your data and to review whether the details we hold about you are accurate
Prior to making an introduction we check that we have accurate information about you
We keep in touch with you so you can let us know of changes to your personal data
We segregate our data so that we keep different types of data for different time periods. The criteria we use to determine whether we should retain your personal data includes:
the nature of the personal data;
its perceived accuracy;
our legal obligations;
whether an interview or placement has been arranged.
We may archive part or all of your personal data. We may pseudonymise parts of your data, particularly following a request for suppression or deletion of your data, to ensure that we do not re-enter your personal data on to our database, unless requested to do so.
For your information, pseudonymised data is created by taking identifying fields within a database and replacing them with artificial identifiers, or pseudonyms.
Our current retention notice is available upon request.
You have the right to ask us not to process your personal data for marketing purposes. We will usually inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes and we will collect express consent from you if legally required prior to using your personal data for marketing purposes.
You can exercise your right to accept or prevent such processing by checking certain boxes on the forms we use to collect your data. You can also exercise the right at any time by contacting us at firstname.lastname@example.org
Our Site may, from time to time, contain links to and from the websites of our partner networks and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
1. Right to
You have the right to be provided with clear, transparent and easily understandable information about how we use your personal data and your rights. This is why we’re providing you with the information in this Privacy Notice.
2. Right of access
You have the right to obtain access to your personal data (if we’re processing it) and certain other information (similar to that provided in this Privacy Notice). This is so you’re aware and can check that we’re using your personal data in accordance with data protection law.
3. Right to rectification
You are entitled to have your personal data corrected if it’s inaccurate or incomplete.
4. Right to erasure
This is also known as ‘the right to be forgotten’ and, in simple terms, enables you to request the deletion or removal of your personal data where there’s no compelling reason for us to keep it. This is not an absolute right to erasure; there are exceptions.
5. Right to restrict processing
You have rights to ‘block’ or suppress further use of your personal data in certain circumstances. When processing is restricted, we can still store your personal data, but may not use it further. [We keep lists of people who have asked for further use of their personal data to be ‘blocked’ to make sure the restriction is respected in the future.
6. Right to data portability
You have the right to obtain and reuse your personal data in a structured, commonly used and machine readable format in certain circumstances. In addition, where certain conditions apply, you have the right to have such information transferred directly to a third party.
7. Right to object to processing
You have the right to object to certain types of processing, in certain circumstances. In particular, the right to object to the processing of your personal data based on our legitimate interests or on public interest
The Data Protection Act 1998 and the GDPR give you the right to access information held about you. We also encourage you to contact us to ensure your data is accurate and complete.
If a subject access request is required, a full disclosure of the information we have stored on you will be provided. Please note that we will require confirmation of your identity to provide this information. The information will be provided within one month of receipt of the formal request – this is in accordance with legislation and ICO guidance:
A subject access request should be submitted to email@example.com. No fee will apply for access requests.
Any changes we make to our privacy notice in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our privacy notice
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