top of page
ClemenineLogo.png

GDPR Policy

Privacy Notice

Notes of Refinement 

Clementine Recruitment 

                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                        
                                                                                                                           is committed to safeguarding your personal information. This privacy notice explains how we collect, use, and protect your personal data in compliance with UK data protection laws, including the UK GDPR. Please read it carefully.

 

  1. We ensure your personal information is:

  2. Processed lawfully, fairly, and transparently.

  3. Collected for specific, legitimate purposes and not used incompatibly.

  4. Limited to what is necessary for those purposes.

  5. Accurate and kept up to date.

  6. Retained only as long as necessary.

  7. Stored securely.

 

For any questions about this notice or how we handle your data, please contact us using the details in Section 1.

 

1. ABOUT US

 

1.1 Clementine Recruitment is a recruitment agency. Our registered office is at [Insert Registered Office Address], and our company registration number is 15089886.

1.2 Contact Details:

2. CONTRACTS AND CORRESPONDENCE

 

2.1 When you engage with us (e.g., as a client, candidate, or supplier), we collect personal information such as your name, contact details, contract details, and related correspondence.

 

2.2 Mandatory Information: To enter or fulfill a contract, you must provide:

 

  • Name and contact details.

  • Address (for service delivery, if applicable).

  • Payment details (if applicable).

  • Identity verification data for anti-money laundering checks (if required).

 

Failure to provide this information may prevent us from fulfilling our contract with you.

 

2.3 Other Interactions: We collect personal data from communications (e.g., emails, calls, website inquiries) including names, contact details, and details of inquiries, complaints, or disputes.

 

2.4 Call Data: We may record phone numbers, call dates, times, and durations. If calls are recorded, we will inform you.

 

2.5 Purpose and Legal Basis: We use this information to:

 

  • Perform our contract with you.

  • Comply with legal obligations (e.g., record-keeping, identity checks).

  • Pursue our legitimate interests, such as managing accounts, resolving complaints, and improving our services through analysis and research.

 

2.6 Retention:

  • Contract-related data: Kept for up to 6 years post-contract for after-sales, claims, or tax purposes.

  • Other correspondence: Kept for up to 6 years.

 

3. MARKETING

 

3.1 We may collect your name and contact details (e.g., email, phone, address) to send you information about our services, such as job opportunities or recruitment updates. This may be collected directly from you or via third parties (with your consent).

 

3.2 Opting Out: You can opt out of marketing at any time by contacting us or using the unsubscribe link in our emails. Opting out adds you to our suppression list to prevent further marketing, though we may still contact you for administrative purposes.

 

3.3 Legal Basis:

 

  • For existing clients or businesses: We use your details for our legitimate interests in marketing and client management.

  • For non-clients (individuals): We only send marketing with your consent.

 

3.4 We do not share your data with third parties for their marketing. Our third-party service providers may send marketing on our behalf, but they are bound by confidentiality and security obligations.

 

3.5 Retention: Marketing data is kept until you opt out, after which your details are retained indefinitely on our suppression list to comply with legal obligations.

 

4. WEBSITE DATA

 

4.1 We collect data about your website usage via cookies and analytics tools (e.g., page visits, interactions) to ensure our website operates effectively and securely.

 

4.2 See our Cookie Notice for details on cookies and their purposes.

 

4.3 Retention: Website data is kept for 12 months or until the relevant cookie expires.

 

4.4 Our website may link to third-party sites or applications. We are not responsible for their privacy practices, so please review their policies.

5. EMPLOYEE AND BUSINESS PARTNER DATA

 

5.1 If you work for a client, supplier, or partner, we may collect your contact details, employment details, or relationship information, either directly from you or your organization.

 

5.2 Purpose: We use this for our legitimate interests in managing business relationships.

 

5.3 Retention: Data is kept for up to 7 years after our relationship with your organization ends.

 

6. VISITOR DATA

 

6.1 We collect visitor information at our premises, including name, employer, contact details, visit details (e.g., date, time, person visited), and vehicle registration. If an accident occurs, we may record details of the incident.

 

6.2 Purpose: Used for our legitimate interests in managing visits, site security, and safety.

 

6.3 Retention:

 

  • Visitor data: Kept for up to 2 years.

  • Accident records: Kept for up to 7 years.

 

7. JOB APPLICANTS

 

7.1 We collect data from job applicants, including application details, recruitment agency data, and referee information.

 

7.2 Purpose: Used to evaluate candidates, fulfill employment contracts, comply with employment law, and manage recruitment records.

 

7.3 Mandatory Information: You must provide name, contact details, and professional/educational history. Incomplete information may prevent us from considering your application.

 

7.4 Retention:

 

  • Successful applicants: Data is kept per our internal privacy policy (available on request).

  • Unsuccessful applicants: Data is kept for 12 months post-recruitment.

  • Referee data: Kept alongside the applicant’s data.

  • Emergency contacts: Kept until updated by the employee or no longer needed.

 

8. LEGAL CLAIMS

 

8.1 We may retain your data to defend or pursue legal claims, sharing it with insurers or legal advisors as needed. Retention depends on the claim’s nature and risk.

 

9. DATA FROM THIRD PARTIES

 

9.1 We may receive your data from:

  • Service providers (e.g., payment or delivery partners).

  • Acquired businesses (if they held your data).

  • Public sources, e.g., Companies House (director details), LinkedIn (professional history).

 

10. WHY WE USE YOUR DATA

 

10.1 We use your data:

 

  • To perform contracts with you.

  • To comply with legal obligations.

  • For our legitimate interests (e.g., business operations, service improvement), provided your rights do not override these.

  • To protect your or others’ vital interests (rare).

 

10.2 Change of Purpose: We only use your data for the purposes stated unless a new, compatible purpose arises. We will notify you if we use your data for an unrelated purpose.

 

11. SHARING YOUR DATA

 

11.1 We may share your data with:

 

  • Third-party service providers (e.g., for IT, payment processing) acting as data processors under our instructions.

  • Group entities for reporting, restructuring, or system maintenance.

  • Regulators or others to comply with legal obligations, enforce agreements, or protect rights, property, or safety.

 

11.2 We never sell your data. All recipients must protect your data and comply with data protection laws.

 

12. DATA STORAGE AND TRANSFERS

 

12.1 Our headquarters and main data centre are in the UK. However, your data may be transferred or processed outside the UK/EU for contract performance or business purposes.

 

12.2 We ensure data security through appropriate safeguards (e.g., EU-approved model clauses) for transfers to countries without an EU adequacy decision. Contact us for details.

13. DATA SECURITY

 

13.1 We use robust security measures to prevent unauthorized access, loss, or disclosure of your data. Access is limited to authorized personnel who process data under strict confidentiality.

 

13.2 We have procedures to address suspected data breaches and will notify you and regulators as required.

 

14. DATA RETENTION

 

14.1 Retention periods are outlined above. We keep data only as long as necessary for the stated purposes, legal requirements, or legitimate interests.

 

14.2 We may anonymize data for further use without identifying you.

 

15. YOUR RIGHTS

Under UK data protection law, you have the right to:

 

  • Be informed about how we use your data (this notice).

  • Access your personal data.

  • Correct inaccurate or incomplete data.

  • Erase your data (where no legal basis for retention exists).

  • Object to processing based on legitimate interests or for marketing.

  • Restrict processing in certain cases (e.g., to verify accuracy).

  • Data portability (for automated data provided by consent or contract).

  • Withdraw consent where applicable.

  • Complain to the Information Commissioner’s Office (ICO).

 

To exercise these rights, contact us. We may need to verify your identity. Responses are typically provided within one month, but complex requests may take longer. No fee is usually charged, but we may charge or refuse excessive/unfounded requests.

 

16. CHANGES TO THIS NOTICE

 

We may update this notice and will post changes here. Significant updates will be communicated to you (e.g., via email). Please check back regularly.

 

Company Details: Placeholder text ([Insert Address], etc.) is used for Clementine Recruitment’s details. Please provide the registered office address, company number, and contact information to complete these sections.

 

Streamlined Language: Simplified complex sentences and removed repetitive phrasing while preserving legal accuracy and clarity.

 

Recruitment Focus: Tailored language to emphasize recruitment activities (e.g., job applicants, candidate data) while keeping the structure broad enough for other interactions (e.g., clients, suppliers).

 

UK GDPR Compliance: Ensured alignment with UK data protection laws, referencing the ICO and avoiding EU-specific terms where possible.

 

Retention Periods: Kept retention periods consistent but generalized where possible to avoid overly specific commitments without further context.

 

Cookies and Website: Retained references to a Cookie Notice and website data, assuming Clementine Recruitment has an online presence. If not applicable, Section 4 can be removed.

 

Third-Party Sources: Kept references to Companies House and LinkedIn as likely sources for a recruitment agency but can adjust based on specific practices.

bottom of page