1. Introduction
Hampshire Barnes Ltd respects your privacy and is committed to protecting your personal information.
This Privacy Notice explains how we collect, use, disclose, retain and protect personal information relating to:
- Candidates and prospective Candidates;
- people applying for employment opportunities;
- people identified through professional networks, job boards or referrals;
- employers and prospective clients;
- employer representatives;
- referees and other contacts;
- suppliers and professional advisers; and
- visitors to our Website.
This Notice applies to information collected through:
- www.hampshirebarnes.com;
- email;
- telephone;
- video meetings;
- professional networking platforms;
- job boards;
- recruitment services; and
- other business communications.
2. Who we are
The data controller is:
Hampshire Barnes Ltd provides permanent recruitment and Candidate introduction services.
Questions about this Notice or our use of personal information should be sent to:
Email: talent@hampshirebarnes.com
or by post to:
Hampshire Barnes Ltd
Boundary House
Cricket Field Road
Uxbridge
Greater London
England
UB8 1QG
3. Personal information we collect
The information we collect depends on your relationship with us.
3.1 Candidate information
We may collect:
- name;
- postal address;
- email address;
- telephone number;
- CV and employment history;
- professional profile;
- qualifications;
- training records;
- licences and professional memberships;
- skills and experience;
- current and desired job title;
- current and expected remuneration;
- benefits and allowances;
- notice period and availability;
- preferred location;
- mobility and travel preferences;
- preferred working arrangements;
- interview availability;
- reasons for leaving employment;
- references and referee details;
- right-to-work and immigration information;
- nationality where relevant to lawful right-to-work requirements;
- information concerning applications, interviews and offers;
- communications with us;
- information supplied by employers, referees and recruitment sources;
- publicly available professional information;
- technical information generated when using our Website; and
- other information voluntarily provided to us.
3.2 Sensitive and special-category information
Where necessary and lawful, we may process information concerning:
- health or disability;
- reasonable adjustments;
- racial or ethnic origin;
- religious or philosophical beliefs;
- trade-union membership;
- sexual orientation;
- criminal convictions or alleged offences; and
- other special-category information.
We will process this information only where:
- a valid lawful basis applies;
- an additional legal condition applies where required; and
- the information is necessary for a legitimate recruitment, legal, safeguarding or equality-related purpose.
You should not provide special-category or criminal-offence information unless it is relevant and necessary.
3.3 Employer and client information
We may collect:
- name;
- job title;
- employer or organisation;
- business address;
- email address;
- telephone number;
- vacancy information;
- recruitment requirements;
- interview feedback;
- hiring decisions;
- business correspondence;
- recruitment history;
- contractual information;
- billing information; and
- payment records.
3.4 Referee and other contact information
Candidates may provide information relating to:
- referees;
- emergency contacts;
- previous employers; or
- other relevant individuals.
Candidates must ensure that they are entitled to provide this information and should direct those individuals to this Privacy Notice.
3.5 Website and technical information
When you use our Website, we may collect:
- IP address;
- approximate location derived from the IP address;
- browser type;
- operating system;
- device type;
- referring website;
- pages viewed;
- date and time of access;
- Website interactions;
- cookie identifiers;
- form submissions;
- diagnostic information; and
- security logs.
Further information will be provided in our Cookie Policy.
4. How we collect personal information
We may collect personal information:
- directly from you;
- through Website forms;
- when you submit a CV;
- when you apply for a vacancy;
- through email, telephone or video communications;
- from employers and prospective employers;
- from referees;
- through professional networking platforms;
- through recruitment websites and job boards;
- through recommendations and referrals;
- from publicly available professional sources;
- from organisations within a client's corporate group;
- from screening and verification providers where lawful; and
- through cookies and similar technologies.
Where we obtain personal information from another source, we will provide relevant privacy information within the period required by law unless an exemption applies.
5. How we use personal information
We may use personal information to:
- register and communicate with Candidates;
- assess a Candidate's skills, experience and suitability;
- identify potential employment opportunities;
- match Candidates with vacancies;
- discuss vacancies with Candidates;
- obtain Candidate approval before submissions;
- submit Candidate information to prospective employers;
- arrange and manage interviews;
- support offer and salary negotiations;
- monitor applications and placements;
- obtain references where authorised;
- communicate with employers and prospective clients;
- understand employer recruitment requirements;
- provide permanent recruitment services;
- administer recruitment agreements;
- manage invoices and payments;
- maintain recruitment and business records;
- prevent fraud and protect our systems;
- comply with legal and regulatory obligations;
- establish, exercise or defend legal claims;
- manage complaints and disputes;
- analyse and improve our Website and services;
- send relevant vacancy alerts or recruitment communications;
- send lawful business-to-business marketing communications; and
- carry out activities reasonably connected with our recruitment services.
6. Lawful bases for processing
We process personal information only where a lawful basis applies.
6.1 Steps before entering into a contract and performance of a contract
We may process information where necessary to:
- consider a request to provide recruitment services;
- represent a Candidate in relation to potential employment;
- provide services under an agreed arrangement;
- administer an employer recruitment agreement; or
- fulfil our contractual obligations.
6.2 Legitimate interests
We may process information where necessary for our legitimate interests or those of another organisation, provided those interests are not overridden by the individual's rights.
Our legitimate interests may include:
- operating a permanent recruitment business;
- identifying and communicating with suitable Candidates;
- identifying potential employers and vacancies;
- matching Candidates with relevant positions;
- maintaining professional recruitment relationships;
- managing and improving our services;
- protecting our business and systems;
- preventing fraud;
- maintaining appropriate recruitment records;
- establishing or defending legal rights; and
- communicating with business contacts about relevant services.
Where appropriate, we will undertake a legitimate-interests assessment.
6.3 Legal obligations
We may process information to comply with:
- recruitment legislation;
- data-protection law;
- tax and accounting requirements;
- court orders;
- regulatory requirements;
- fraud-prevention obligations; and
- other legal duties.
6.4 Consent
We may rely on consent where appropriate, including for:
- certain marketing communications;
- non-essential cookies;
- specific disclosures requested by the individual; or
- certain sensitive information where another legal basis is not appropriate.
Consent may be withdrawn at any time.
Withdrawal of consent will not affect processing lawfully carried out before withdrawal.
6.5 Special-category information
Where we process special-category information, we will identify:
- a lawful basis under Article 6 of the UK GDPR; and
- an additional condition under Article 9 of the UK GDPR or Schedule 1 of the Data Protection Act 2018.
Depending on the circumstances, this may include:
- explicit consent;
- employment and social-protection obligations;
- protecting vital interests;
- information manifestly made public by the individual;
- establishing, exercising or defending legal claims;
- substantial public interest; or
- equality monitoring.
6.6 Criminal-offence information
We will process criminal-offence information only where authorised by law and where an appropriate legal condition applies.
7. Candidate submissions to employers
7.1 We may share Candidate information with prospective employers for recruitment purposes.
7.2 Where reasonably practicable, we will obtain the Candidate's approval before sending an identifiable CV or profile to a prospective employer.
7.3 Candidate approval may be obtained by:
- email;
- telephone;
- electronic message;
- Website form; or
- another recorded communication.
7.4 Once Candidate information has been disclosed to an employer, the employer will normally process that information as an independent data controller under its own privacy notice.
7.5 Candidates should review the prospective employer's privacy information where available.
8. Who we share information with
Where necessary and lawful, we may share information with:
- employers and prospective employers;
- companies within an employer's corporate group;
- referees;
- professional advisers;
- accountants and auditors;
- legal advisers;
- insurers;
- recruitment software and CRM providers;
- applicant-tracking and vacancy-management providers;
- Website hosting and technical-support providers;
- cloud-storage providers;
- email and communications providers;
- electronic-signature providers;
- job boards and professional networking platforms;
- background or qualification-checking providers;
- analytics providers;
- cybersecurity and fraud-prevention providers;
- debt-recovery providers;
- courts, regulators and law-enforcement authorities;
- prospective purchasers or investors in our business; and
- other parties where you request or authorise the disclosure.
We require service providers handling personal information on our behalf to:
- use it only for authorised purposes;
- maintain confidentiality; and
- apply appropriate technical and organisational safeguards.
We do not sell Candidate personal information to advertisers or data brokers.
9. International transfers
9.1 Some suppliers, employers, group companies or technology providers may be located outside the United Kingdom.
9.2 Where personal information is transferred outside the United Kingdom, we will use an appropriate lawful transfer mechanism where required.
This may include:
- a transfer to a country covered by UK adequacy regulations;
- the UK International Data Transfer Agreement;
- the UK Addendum to approved standard contractual clauses;
- another legally recognised safeguard; or
- a permitted legal exception.
9.3 You may contact us for further information about safeguards applying to a particular transfer.
10. Retention of personal information
10.1 We retain personal information only for as long as reasonably necessary for the purpose for which it was collected.
10.2 We also consider:
- legal obligations;
- regulatory requirements;
- tax and accounting requirements;
- contractual obligations;
- potential disputes; and
- the establishment or defence of legal claims.
10.3 Candidate records
Candidate records will normally be retained for up to 24 months after our last meaningful contact, unless:
- the Candidate asks us to retain them for longer;
- the Candidate remains actively registered;
- a placement, dispute or legal issue requires longer retention;
- legislation requires a different period; or
- continued retention is otherwise justified and lawful.
We may contact Candidates before the end of the retention period to confirm whether they wish to remain registered.
10.4 Successful placements
Information relating to a successful placement, recruitment agreement, invoice or transaction may be retained for up to six years after the relevant transaction or contractual relationship ends.
Information may be retained for longer where required by law or reasonably necessary for legal claims.
10.5 Employer and business records
Employer contracts, invoices, payment records and material business correspondence may normally be retained for up to six years after the relevant transaction or business relationship.
10.6 Unsuccessful enquiries
General enquiries that do not lead to a recruitment or commercial relationship may normally be retained for up to 12 months.
10.7 Website and security records
Technical and security logs will be retained for a period proportionate to their purpose, normally between 30 days and 12 months, unless a security incident requires longer retention.
10.8 Deletion and anonymisation
When personal information is no longer required, we will:
- delete it;
- anonymise it; or
- securely dispose of it.
11. Accuracy of information
11.1 We take reasonable steps to keep personal information accurate and current.
11.2 Candidates, Clients and business contacts should promptly inform us if their information:
- changes;
- is inaccurate; or
- is incomplete.
11.3 We may contact individuals periodically to confirm that information remains current.
12. Data security
12.1 We use appropriate technical and organisational measures intended to protect personal information against:
- unauthorised access;
- unlawful use;
- accidental loss;
- destruction;
- alteration; and
- unauthorised disclosure.
12.2 Measures may include:
- access controls;
- passwords;
- multifactor authentication;
- encryption where appropriate;
- secure cloud systems;
- staff confidentiality obligations;
- backups;
- supplier due diligence;
- security monitoring; and
- incident-response procedures.
12.3 No internet transmission or electronic-storage system can be guaranteed to be completely secure.
13. Marketing communications
13.1 We may send relevant:
- vacancy alerts;
- Candidate communications;
- recruitment updates;
- industry information; and
- business-to-business marketing communications,
where permitted by law.
13.2 You may unsubscribe from marketing communications at any time by:
- using an unsubscribe link in the communication; or
- contacting talent@hampshirebarnes.com.
13.3 Even where marketing communications are declined, we may continue to send necessary:
- service communications;
- application updates;
- interview communications;
- placement communications;
- contractual notices; and
- legal or regulatory communications.
14. Cookies and similar technologies
14.1 Our Website may use:
- cookies;
- pixels;
- local storage;
- scripts; and
- similar technologies.
14.2 Strictly necessary technologies may be used where required for:
- Website operation;
- security;
- fraud prevention; or
- maintaining user preferences.
14.3 Where legally required, non-essential technologies will not be activated until consent has been provided.
14.4 You can manage your cookie choices through the cookie settings facility displayed on our Website.
14.5 Further information is provided in our Cookie Policy.
15. Automated tools and artificial intelligence
15.1 We may use software to help:
- organise Candidate information;
- search CVs;
- identify keywords;
- filter information; or
- match Candidate information with vacancies.
15.2 We will not make a decision producing legal or similarly significant effects based solely on automated processing unless:
- it is legally permitted;
- appropriate safeguards are in place; and
- any legally required notice is provided.
15.3 Where artificial-intelligence tools are used, Hampshire Barnes Ltd remains responsible for ensuring that personal information is processed lawfully and appropriately.
15.4 You may contact us for further information about automated tools used in a particular recruitment process.
16. Your data-protection rights
Depending on the circumstances and the lawful basis used, you may have the right to:
- request access to your personal information;
- request correction of inaccurate or incomplete information;
- request erasure of personal information;
- request restriction of processing;
- object to processing based on legitimate interests;
- object to direct marketing;
- request transfer of certain information in a portable format;
- withdraw consent where processing is based on consent;
- request information about international-transfer safeguards;
- challenge certain solely automated decisions; and
- complain to the Information Commissioner's Office.
These rights are not absolute and may be subject to legal exemptions.
17. Right to object
17.1 You have the right to object at any time to the processing of your personal information for direct-marketing purposes.
17.2 You may also object to processing based on legitimate interests.
17.3 Where you object to processing based on legitimate interests, we will stop the processing unless:
- we can demonstrate compelling legitimate grounds which override your interests, rights and freedoms; or
- the processing is required for the establishment, exercise or defence of legal claims.
17.4 To exercise this right, contact:
talent@hampshirebarnes.com
18. Exercising your rights
18.1 Requests should be sent to:
Email: talent@hampshirebarnes.com
or by post to:
Hampshire Barnes Ltd
Boundary House
Cricket Field Road
Uxbridge
Greater London
England
UB8 1QG
18.2 We may request information needed to verify your identity.
18.3 We will respond within the period required by applicable data-protection law.
18.4 There is normally no fee for exercising data-protection rights.
18.5 We may charge a reasonable fee or refuse a request where the law permits us to do so, including where a request is manifestly unfounded or excessive.
19. Complaints
19.1 We encourage you to contact us first so that we can try to resolve your concern.
19.2 You also have the right to complain to the UK supervisory authority:
19.3 You may also have the right to complain to another relevant supervisory authority where applicable.
20. Children
20.1 Our recruitment services are intended for adults seeking professional employment and for employer representatives.
20.2 We do not knowingly collect personal information from children through the Website.
20.3 If you believe that a child has provided personal information to us, contact:
talent@hampshirebarnes.com
21. Third-party websites
21.1 Our Website may link to third-party websites.
21.2 We are not responsible for third-party privacy practices.
21.3 You should review the third party's privacy notice before providing personal information.
22. Changes to this Privacy Notice
22.1 We may update this Privacy Notice to reflect changes to:
- our services;
- our data-processing activities;
- our technology;
- our suppliers; or
- applicable legal requirements.
22.2 The latest version will be published on our Website and identified by its last-updated date.
22.3 Where changes materially affect individuals, we may provide an additional notice where appropriate.
23. Contact us
Questions, requests or complaints concerning personal information should be sent to: