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PRIVACY POLICY

Privacy Policy for Clementine Recruitment

Last Updated: July 24, 2025

 

Clementine Recruitment ("we," "us," or "our") is committed to protecting the privacy and security of your personal data. This Privacy Policy explains how we collect, use, store, and share personal data in compliance with the UK General Data Protection Regulation (UK GDPR), the Data Protection Act 2018, and other applicable laws. This policy applies to candidates, clients, suppliers, and visitors to our website (www.clementinerecruitment.co.uk).

 

1. Who We Are

 

Clementine Recruitment is a UK-based recruitment agency specializing in connecting candidates with employers. Our registered office is at Red Parrot Accounting Pentax House South Hill Avenue, South Harrow, Middlesex, United Kingdom, HA2 0DU, and we are registered with the Information Commissioner’s Office (ICO) under registration number [Insert ICO Registration Number].

 

For the purposes of data protection laws, we are the "data controller" responsible for the personal data we collect and process. You can contact our Data Protection Officer at:

 

 

2. What Personal Data We Collect

 

We collect and process personal data to provide recruitment services, including:

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Candidates

 

  • Identity and Contact Data: Name, address, email, phone number, date of birth, and nationality.

  • Professional Data: CV, employment history, qualifications, skills, and references.

  • Application Data: Job preferences, salary expectations, and interview notes.

  • Sensitive Data: Health information, criminal conviction data (where required for specific roles), and diversity data (e.g., ethnicity or disability, only with your explicit consent).

 

Clients

 

  • Business Contact Data: Name, job title, business email, and phone number.

  • Recruitment Data: Job specifications, hiring requirements, and contract details.

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Website Visitors

 

  • Technical Data: IP address, browser type, device information, and browsing activity (via cookies, see Section 7).

  • Contact Data: Information submitted via contact forms or inquiries.

 

Suppliers

 

  • Business Contact Data: Name, email, phone number, and payment details.

 

We may also collect data from third parties, such as job boards, LinkedIn, or referees, with your consent or where permitted by law.

 

3. How We Collect Your Data

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We collect personal data through:

 

  • Direct interactions (e.g., submitting a CV, filling out forms, or contacting us).

  • Job applications or registrations via our website or third-party platforms.

  • Client or supplier communications (e.g., emails, contracts, or meetings).

  • Automated technologies (e.g., cookies on our website).

  • Publicly available sources (e.g., professional profiles on LinkedIn).

  • Third parties (e.g., references or background check providers, with your consent).

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4. How We Use Your Personal Data

 

We process personal data for the following purposes, based on the lawful bases outlined in the UK GDPR:

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Purpose                   

 

  • Matching candidates to job opportunities

  • Communicating with candidates and clients

  • Managing client and supplier relationships

  • Conducting background checks (where applicable)

  • Improving our services and website

  • Complying with legal obligations

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Data Used         

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  • Identity, professional, application, and sensitive data

  • Contact data

  • Business contact and recruitment data

  • Identity, sensitive data

  • Technical and browsing data

  • Identity, professional, and sensitive data

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Lawful Basis

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  • Consent, legitimate interests (recruitment services)

  • Consent, performance of a contract

  • Performance of a contract, legitimate interests

  • Consent, legal obligation

  • Legitimate interests, consent (for cookies)

  • Legal obligation

 

We will only process sensitive personal data (e.g., health or criminal records) with your explicit consent or where required by law for specific roles.

 

5. How We Share Your Personal Data

 

We may share your personal data with:

 

  • Clients: Candidate details (e.g., CVs, interview notes) shared with potential employers, only with your consent.

  • Third-Party Providers: Service providers such as IT hosting, background check agencies, or payment processors, who act as data processors under strict contracts.

  • Legal Authorities: Where required by law (e.g., HMRC, law enforcement).

  • Professional Advisors: Our lawyers, accountants, or auditors, bound by confidentiality.

 

We do not sell your personal data or share it with third parties for marketing purposes.

 

6. International Data Transfers

 

If we transfer personal data outside the UK (e.g., to clients or providers in the EEA or other countries), we ensure appropriate safeguards, such as:

 

  • Adequacy decisions by the UK government.

  • Standard Contractual Clauses (SCCs) approved by the ICO.

  • Other mechanisms permitted under the UK GDPR.

 

7. Cookies and Website Tracking

 

Our website uses cookies to enhance user experience and analyse performance. Cookies may collect technical data, such as your IP address or browsing behaviour.

 

You can manage cookie preferences through your browser settings or our website’s cookie consent tool.

 

For more details, please see our Cookie Policy.

 

8. Data Security

 

We implement appropriate technical and organizational measures to protect your personal data, including:

 

  • Encryption of sensitive data.

  • Secure servers and access controls.

  • Regular security audits and staff training.

 

Despite our efforts, no system is completely secure, and we cannot guarantee absolute security.

 

9. Data Retention

 

We retain personal data only for as long as necessary for the purposes outlined in this policy:

 

  • Candidates: CVs and application data are retained for 2 years]= after your last interaction with us, unless you request deletion.

  • Clients/Suppliers: Contact and contract data are retained for 6 years  to comply with legal obligations (e.g., tax records).

  • Website Visitors: Technical data is retained for 12 months for analytics purposes.

 

We securely delete or anonymize data when it is no longer needed.

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10. Your Data Protection Rights

 

Under the UK GDPR, you have the following rights:

 

  • Access: Request a copy of your personal data.

  • Rectification: Correct inaccurate or incomplete data.

  • Erasure: Request deletion of your data (subject to legal obligations).

  • Restriction: Limit how we process your data.

  • Portability: Receive your data in a structured, machine-readable format.

  • Objection: Object to processing based on legitimate interests.

  • Withdraw Consent: Withdraw consent at any time (where processing relies on consent).

 

To exercise your rights, contact us at info@clementinerecruitmentlondon.co.uk We will respond within one month, though complex requests may take longer. There is no fee unless your request is manifestly unfounded or excessive.

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11. How to Complain

 

If you are unhappy with how we handle your personal data, please contact our Data Protection Officer.

 

You also have the right to lodge a complaint with the ICO:

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  • Website: www.ico.org.uk

  • Phone: 0303 123 1113

  • Address: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF

 

12. Changes to This Privacy Policy

 

We may update this Privacy Policy to reflect legal or operational changes. Updates will be posted on our website, and significant changes will be communicated to you directly where required.

 

13. Contact Us

 

 

Thank you for trusting Clementine Recruitment with your personal data.

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