We take your privacy seriously
Abrecco Limited (”Abrecco”) are committed to protecting and respecting your privacy.
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)
The General Data Protection Regulation (GDPR) (Regulation (EU) 2016/679) (“GDPR”) is a new regulation which replaces the Data Protection Regulation (Directive 95/46/EC). The Regulation 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.
Your rights under GDPR are set out in this notice and apply from 25 May 2018.
Please read the following carefully to understand our views and practices regarding your personal data and how Abrecco will treat it.
For the purposes of data protection legislation in force from time to time the Data Controller is Abrecco Limited of 91 George Street, Edinburgh, EH2 3ES.
Our nominated Data Protection Officer is our Operations Director.
Who is Abrecco and what do we do
We are an IT recruitment agency and recruitment business as defined in the Employment Agencies and Employment Businesses Regulations 2003 (our business). Abrecco collect the personal data of the following types of people to allow us to undertake our business:
Abrecco collects information about you to carry out our core business and ancillary activities.
Information you supply to us or we collect about you
This is information about you that you give us by visiting our website https://www.abrecco.com (“Website”) or by corresponding with us by phone, e-mail, SMS or otherwise. It includes information you provide when you:
The information you give us or Abrecco collects 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 (or career profile) and photograph and data that may be held on your professional profile available in the public domain e.g. LinkedIn, Twitter, business Facebook or corporate website.
Information Abrecco collects about you when you visit our Website
When you visit our Website Abrecco may automatically collect the following information:
Technical information, including the Internet Protocol (IP) address used to connect your computer to the Internet, browser type and version, operating system and platform.
Information about your visit, including the full Uniform Resource Locators (URL) of each page visited, clickstream to and through our Website including date and time, jobs visited and searched for, download errors, length of visits to pages, and any information submitted through forms.
Information Abrecco obtains from other sources
This is information Abrecco obtains about you from other sources such as LinkedIn, corporate websites, job board websites, online CV libraries, your business card, personal recommendations and any relevant social media sites. In this case Abrecco will inform you, by sending you this privacy notice, within a maximum of 30 days of collecting the data of the fact Abrecco holds personal data about you the source the personal data originates from and whether it came from publicly accessible sources, and for what purpose we intend to retain and process your personal data.
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, professional advisors. We may receive information about you from them for the purposes of our recruitment services and ancillary support services.
Purposes of information processing and the legal basis for the processing
Abrecco uses information held about you in the following ways:
To carry out our obligations arising from any contracts Abrecco intends to enter into or have entered into between you and Abrecco to provide you with the information and services that you request from us or Abrecco 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 services or jobs that Abrecco offer that are similar to those that you have already been provided with or enquired about.
The core service Abrecco offers to our candidates and clients is the introduction of candidates to our clients for the purpose of temporary or permanent recruitment. 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 our legitimate interests, described in more detail below, although Abrecco will also rely on contract, legal obligation and consent for specific uses of data.
Abrecco will rely on any existing contract if Abrecco 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.
Abrecco will rely on legal obligation if Abrecco are legally required to hold information on you to fulfil our legal obligations.
Abrecco will in some circumstances rely on your consent for particular uses of your data and you will be asked for your express consent, if legally required e.g. when gaining your permission to introduce you to a client (if you are a candidate).
We’ll also make sure that the other businesses we work with are just as careful with your data as far as possible and we will request that any and all Personal Data passed to a client by Abrecco during the recruitment process is deleted by the client at the end of that process unless such information is required to be held for the purposes of satisfying any legal, accounting, regulatory or reporting requirements.
Our Legitimate Interest
Our legitimate interest in collecting and retaining your personal data is described below:
As a recruitment business and recruitment agency Abrecco introduce candidates to clients for permanent employment or independent professional contracts. The exchange of personal data of our candidates and our client contacts is a fundamental and essential part of this process.
In order to support our candidates’ career aspirations and our clients’ resourcing needs Abrecco requires to operate a database of candidate and client personal data containing historical information as well as current resourcing requirements.
To maintain, expand and develop our business Abrecco needs to record the personal data of prospective candidates and client contacts.
Should Abrecco want or need to rely on consent to lawfully process your data Abrecco will request your consent orally, by email, by SMS or by completing an online process for the specific activity (e.g. when registering a vacancy or as a candidate or when you apply for a job) when Abrecco will require your consent for and to record your response on our system. Where consent is the lawful basis for our processing you have the right to withdraw your consent to this particular processing at any time.
Other Uses Abrecco will make of your data:
Abrecco will use this information:
to administer our Website and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposesto improve our Website to ensure that content is presented in the most effective manner for you and for your computerto allow you to participate in any interactive features of our service, when you choose to do so;as part of our efforts to keep our Website safe and secureto measure or understand the effectiveness of the information, news and job advertising Abrecco serve to you and others, and to deliver relevant information, news and job advertising to youto make suggestions and recommendations to you and other users of our Website about goods or services that may interest you or them.
Abrecco does 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.
Disclosure of your information inside and outside of the EEA
Abrecco will share your personal information with:
Selected third parties including:
Abrecco will disclose your personal information to third parties:
The lawful basis for the third-party processing will include:
Where Abrecco stores and process your personal data
The data that Abrecco collects 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 services. It may 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. Abrecco 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 Abrecco have given you (or where you have chosen) a password which enables you to access certain parts of our Website, you are responsible for keeping this password confidential. Abrecco ask you not to share a password with anyone.
Unfortunately, the transmission of information via the internet is not completely secure. Although Abrecco will do our best to protect your personal data, Abrecco cannot guarantee the security of your data transmitted to our Website; any transmission is at your own risk. Once Abrecco has received your information, Abrecco will use strict procedures and security features to try to prevent unauthorised access.
Notification of a Data Breach
All personal data breaches must be reported immediately to the Company’s data protection officer.
If a personal data breach occurs and that breach is likely to result in a risk to the rights and freedoms of Data Subjects (e.g. financial loss, breach of confidentiality, discrimination, reputational damage, or other significant social or economic damage), the data protection officer must ensure that the Information Commissioner’s Office is informed of the breach without delay, and in any event, within 72 hours after having become aware of it.
In the event that a personal data breach is likely to result in a high risk to the rights and freedoms of Data Subjects, the data protection officer must ensure that all affected Data Subjects are informed of the breach directly and without undue delay.
Data breach notifications shall include the following information:
The details of the measures taken, or proposed to be taken, by the Company to address the breach including, where appropriate, measures to mitigate its possible adverse effects.
Retention of your data
Abrecco will retain your personal data for seven years, or as long as necessary in order to provide the recruitment service to you and for the purposes of satisfying any legal, accounting, regulatory or reporting requirements
Abrecco do the following to try to ensure our data is accurate:
prior to making an introduction Abrecco check that we have accurate information about youwe keep in touch with you so you can let us know of changes to your personal datawe make use of external websites (e.g. LinkedIn, Law Society) to verify the information about you.
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 dataits perceived accuracyour legal obligationswhether Abrecco has been active with you as part of our general recruitment service (e.g. discussing roles with you, arranging interviews or placing you in a new role)our recruitment expertise and knowledge of the industry by country, sector and job role
Abrecco may archive part or all of your personal data or retain it on our financial systems only, deleting all or part of it from our systems. We may use pseudonyms for 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.
You have the right to ask us not to process your personal data for marketing purposes. Abrecco will usually inform you (before collecting your data) if we intend to use your data for such purposes or if Abrecco intends 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
Our website may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that Abrecco does not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
The GDPR provides you with the following rights
Access to information:
The Data Protection Act 1998 and the GDPR give you the right to access information held about you. Abrecco also encourages you to contact us to ensure your data is accurate and complete.
A subject access request should be submitted by email to GDPR@abrecco.com
Changes to our privacy notice
Any changes Abrecco makes 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.
Questions, comments and requests regarding this Privacy Notice are welcomed and should be addressed to The Data Protection Officer, Abrecco Limited, 91 George Street, Edinburgh, EH2 3ES or via email to GDPR@abrecco.com