Privacy Policy
HeadWay Resources Consultancy Limited (the “Company”, “HeadWay”, “we” or “us”) is a recruitment business which provides work finding services to its clients and work-seekers. HeadWay must process personal data (including sensitive personal data) so that it can provide these services - in doing so, the Company acts as a data controller. Headway is committed to protecting, safeguarding and respecting your privacy.
This Policy (together with other documents referred to herein) describes what personal information we collect from you, or that you provide us and how we process your personal information when you use the headwayrc.com website (“Website”).
You may give your personal details to the Company directly, such as on an application or registration form or via our website, or we may collect them from another source such as a jobs board. The Company must have a legal basis for processing your personal data. For the purposes of providing you with work-finding services and/or information relating to roles relevant to you we will only use your personal data in accordance with the terms of the following statement.
Collection and use of personal data
Purpose of processing and legal basis
HeadWay Resources Consultancy Limited will collect your personal data (which may include sensitive personal data) and will process your personal data for the purposes of providing you with work-finding services. This includes 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.
In some cases we may be required to use your data for the purpose of investigating, reporting and detecting crime and also to comply with laws that apply to us. We may also use your information during the course of internal audits to demonstrate our compliance with certain industry standards.
The legal bases we rely upon to offer these services to you are:
- Your consent
- Where we have a legitimate interest
- To comply with a legal obligation that we have
- To fulfil a contractual obligation that we have with you
Legitimate interest
This is where HeadWay Resources Consultancy Limited has a legitimate reason to process your data provided it is reasonable and does not go against what you would reasonably expect from us. Where HeadWay Resources Consultancy Limited has relied on a legitimate interest to process your personal data our legitimate interests is/are as follows:
- Where HeadWay Resourcest Consultancy Limited will process your personal data and/or sensitive personal data in order to provide work finding services
- Managing our database and keeping work-seeker’s records up to date
- Contacting you to seek your consent where we need it
Recipient/s of data
The Company will process your personal data and/or sensitive personal data with the following recipients:
- HeadWay Resources Consultancy Limited's clients (whom we may introduce or supply you to)
- Former employers whom we may seek references from
- Other recruitment agencies in the supply chain
Statutory/contractual requirement
Your personal data is required by law and/or a contractual requirement (e.g. our client may require this personal data), and/or a requirement necessary to enter into a contract. You are obliged to provide the personal data and if you do not the consequences of failure to provide the data are that HeadWay Resources Consultancy Limited will not be able to provide you with work finding services.
Overseas transfers
HeadWay Resources Consultancy Limited may transfer only the information you provide to us to countries outside the European Economic Area (‘EEA’) for the purposes of providing you with work-finding services. 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.
Data retention
HeadWay Resources Consultancy Limited will retain your personal data only for as long as is necessary. Different laws require us to keep different data for different periods of time. The Conduct of Employment Agencies and Employment Businesses Regulations 2003, require us to keep work-seeker records for at least one year from (a) the date of their creation or (b) after the date on which we last provide you with work-finding services. We must also keep your payroll records, holiday pay, sick pay and pensions auto-enrolment records for as long as is legally required by HMRC and associated national minimum wage, social security and tax legislation. Where the Company has obtained your consent to process your personal and sensitive personal data, we will do so in line with our retention policy. Upon expiry of that period the Company will seek further consent from you. Where consent is not granted the Company will cease to process your data.
Log Files
We use IP addresses to analyse trends, administer the site, track users’ movements, and to gather broad demographic information for aggregate use. IP addresses are not linked to personally identifiable information.
Links to external websites
The Company’s website may contain links to other external websites. Please be aware that the Company is not responsible for the privacy practices of such other sites. When you leave our site we encourage you to read the privacy statements of each and every website that collects personally identifiable information. This privacy statement applies solely to information collected by the Company’s website.
Sale of business
If the Company’s business is sold or integrated with another business your details may be disclosed to our advisers and any prospective purchasers and their advisers and will be passed on to the new owners of the business.
Your rights
Please be aware that you have the following data protection rights:
- The right to be informed about the personal data HeadWay Resources Consultancy Limited processes on you;
- The right of access to the personal data HeadWay Resources Consultancy Limitedt processes on you;
- The right to rectification of your personal data;
- The right to erasure of your personal data in certain circumstances;
- The right to restrict processing of your personal data;
- The right to data portability in certain circumstances;
- The right to object to the processing of your personal data that was based on a public or legitimate interest;
- The right not to be subjected to automated decision making and profiling; and
- The right to withdraw consent at any time.
Where you have consented to the HeadWay Resources Consultancy Limited processing your personal data and sensitive personal data you have the right to withdraw that consent at any time by contacting Sophie Sell, Managing Director, 0208 092 6254 or [email protected].
There may be circumstances where HeadWay Resources Consultancy Limited will still need to process your data for legal or official reasons. We will inform you if this is the case. Where this is the case, we will restrict the data to only what is necessary for the purpose of meeting those specific reasons.
If you believe that any of your data that HeadWay Resources Consultancy Limited processes is incorrect or incomplete, please contact us using the details above and we will take reasonable steps to check its accuracy and correct it where necessary.
You can also contact us using the above details if you want us to restrict the type or amount of data we process for you, access your personal data or exercise any of the other rights listed above.
Complaints or queries
If you wish to complain about this privacy notice or any of the procedures set out in it please contact: Sophie Sell, Managing Director, telephone 0208 0926254 or email [email protected].
You also have the right to raise concerns with Information Commissioner’s Office on 0303 123 1113 or at https://ico.org.uk/concerns/, or any other relevant supervisory authority should your personal data be processed outside of the UK, if you believe that your data protection rights have not been adhered to.
Changes to this Policy
The terms of this Policy may change from time to time. We shall publish any material changes to this Policy through appropriate notices either on this Website or contacting you using other communication channels.
