Privacy Policy
This privacy policy explains how CoulterPepper Limited (company number 5697283) “CoulterPepper ” uses the information it collects about you, how you can instruct CoulterPepper if you prefer to limit the use of that information and what procedures CoulterPepper has in place to safeguard your privacy.
This policy covers candidates who have approached CoulterPepper:
- directly or through any of our channels (such as LinkedIn); and/or
- indirectly through placing their details on a third party’s website and CoulterPepper has then independently made contact with you.
Data derived from Third Party Sources
As is common in the recruitment sector, data that is provided by candidates is shared among agencies. If CoulterPepper is processing data which CoulterPepper has discovered from a third party database, then CoulterPepper is processing your data on the assumption that when you uploaded your CV onto the third party’s website you did so on the understanding that recruitment agencies will be able to access and download your personal data.
We will also from time to time, place advertisements on third party recruitment sites and by responding with your CV it is understood that you wish us to review your details and experience against the position advertised.
Lawful Basis for processing Data
CoulterPepper processes personal data with the justification being that the processing is in CoulterPepper ’s legitimate interest. The processing of personal data that CoulterPepper carries out is purely to meet the obligations it owes candidates who directly and indirectly disclose to CoulterPepper their personal data with a view to using CoulterPepper ’s services. CoulterPepper will not process data beyond those parameters and will always respect the rights of data subjects to control the processing of their data by CoulterPepper.
Key Points of This Privacy Policy
Please read the entire document, however please note:
- CoulterPepper is the data controller.
- Should you have any queries then please contact Joan Coulter [joan@coulterpepper.co.uk]. The ultimate source of redress if CoulterPepper cannot resolve issues is the Information Commissioner’s Office.
- CoulterPepper is committed to ensuring that your information is secure. In order to prevent unauthorised access or disclosure CoulterPepper has put in place suitable physical, electronic and managerial procedures to safeguard and secure the information that CoulterPepper collects.
- CoulterPepper will not transfer your data to outside the European Economic Area or make decisions which rely on automation.
- Personal details will not be sold to third parties and will not be used for marketing purposes.
The information/data CoulterPepper collects and how CoulterPepper uses it:
The purpose of CoulterPepper ’s processing of data is to introduce you to prospective employers. CoulterPepper will match your details with its client requirements and in order to assist you in securing a position, CoulterPepper will send your personal information (including sensitive personal information) to its clients
You would have either forwarded your personal data directly to CoulterPepper or you would have disclosed your personal data to a third party which has then been legitimately accessed by Coulterpepper. Regardless of how the data has been obtained the purpose of the data processing is the same.
If required to do so CoulterPepper may also release personal information to regulatory or law enforcement agencies. CoulterPepper will also disclose your information where CoulterPepper is permitted and requested to do so by law.
CoulterPepper may also seek your consent to collect, hold, use and disclose your personal information for any other purpose not listed above.
CoulterPepper will not send your CV or personal details to a client or any other third party without your written permission to do so. CoulterPepper will not share your personal or sensitive details with any party other than to make an agreed representation to a client
Data Retention
CoulterPepper operates across a limited number of niche markets and therefore only handles roles applicable to a limited range of candidates. CoulterPepper may not be able to immediately introduce candidates to opportunities and so CoulterPepper will retain candidate's personal details for up to 8 years. This enables CoulterPepper to make contact with you if relevant opportunities arise. It is your decision as to whether you update the details that CoulterPepper holds.
Candidates have the right to ask that their personal data be erased from CoulterPepper’s records. Otherwise CoulterPepper will retain your personal information for a period of 8 years from the initial date of your interaction with us.
