Privacy Policy

ASL International Recruitment Limited (a company with company number 95590) is the controller and responsible for your personal data (collectively referred to as “ASL”, “we”, “us” or “our” in this privacy notice).

This privacy notice makes reference to our “Clients”, being businesses that seek our services to source and recruit individuals on their behalf, and our “Candidates” who are individuals that we source in order to fulfil our Clients’ personnel requirements (on a temporary, contract or permanent basis as well as fixed term basis for non-executive director status). We also offer other consultancy services to our Clients which could mean that we obtain additional information on the individual “Delegates” over and above our normal business services of recruitment such as training, psychometric testing, or HR consultancy services. In addition, we use other providers of services to us “Suppliers”.

ASL respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data which you provide to us, or which we obtain, when you are a Client, a Candidate, a Delegate or Supplier, when you use our website (www.asl-jersey.co.uk), or when we deal with you in the course of our business. We may update this privacy policy from time to time – you can find our latest policy on our website (www.asl-jersey.co.uk) or by asking us for a copy.

We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below.

Data Privacy Manager
ASL International Recruitment Limited
22 – 24 Seale Street
St Helier
Jersey
Telephone Number: +44 1534 500000
Email: lindsay@asl-jersey.co.uk

Third-party links

Our website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

Types of Information We Collect:

We collect, use, store and transfer:

  • Identity and Contact Data: personal and identity data, which may include name, job titles, postal address, work or home email address, telephone numbers, job titles, and in relation to Candidates, information relating to date of birth, copies of ID immigration status, police records and right to work information along with referees and emergency contact details;

  • Recruitment Data: references and other information included in a CV, covering letter and employment history and in relation to Candidates’ further data such as pre-screening, and/or police records. Candidates’ should refer to our Candidate Privacy statement for further in-depth information;

  • Financial Data: information regarding bank accounts for Customers, Suppliers, or Delegates and in relation to Candidates remuneration packages offered to Candidates by our Clients including information regarding salary, fee rates, bonus, expenses and benefits in kind, and, in the case of Candidates applying for temporary positions only, information regarding bank accounts, pensions and tax details;

  • Special Category/Sensitive Data: in relation to Candidates and/or Delegates only, information concerning your race or ethnicity, gender, any health concerns including any medical condition, or disability;

  • Technical Data: information we collect automatically when you visit our website or interact with us by email, including your IP address, browser details, and device details;

  • Transaction Data: details of services we provide to you;

  • Marketing and Communications Data: includes your preferences in receiving marketing from us and your communication preferences.

How We Collect The Data:

We collect your data from different sources such as:

  • Directly from you when you interact with us;

  • From documents you provide us;

  • From professional contacts or third parties who send us your details as prospective Candidates or Clients or Delegates;

  • From other third parties such as referees, interviewers, website and social media feeds, (such as LinkedIn, Twitter, Facebook, Instagram), online job boards or testing, and screening providers;

  • When you interact with our website or email us or unsubscribe from our mailing list, by using cookies and other similar technologies.

How We Use Your Personal Data:

We will only use your personal data when the law allows us to.

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the lawful processing conditions we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note: we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us using the details above if you need details about the specific legal ground, we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/Activity

Lawful basis for processing including basis of legitimate interest

To register you as a new Client, Delegate or Candidate

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to build our database where you have requested to be included or made your details available for inclusion).

To provide services to you and carry out your instructions in connection with our services

Performance of a contract with you

To undertake pre-screening requirements, including reference checking, police checks, testing

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to inform our Clients of Candidates who are interested in roles with those Clients)

(c) Consent, (where you have provided positive consent)

To provide your details as a Candidate to our Clients

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to inform our Clients of Candidates who are interested in roles with those Clients)

(c) Consent, (where you have provided positive consent)

To send updates to you about vacancies that may be of interest to you

(a) Consent (where you have provided positive consent)

(b) Necessary for our legitimate interests (to develop our products/services and grow our business)

To carry out administration in connection with the provision of services to you, or from you including:

(a) Managing payments, fees and charges

(b) Collect and recover money owed to us

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to recover debts due to us)

To manage queries relating to services we have provided to you historically

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to be able to respond to queries about our services)

To manage our relationship with you as a Client, Candidate, Delegate or Supplier, which will include:

(a) Notifying you about changes to our terms or privacy policy

(b) Asking you to leave a review or take a survey

(a) Performance of a contract with you

(b) Necessary to comply with a legal obligation

(c) Necessary for our legitimate interests (to keep our records updated and to study how Clients, Candidates or Delegates use our products/services)

To enable you to partake in a competition or complete a survey

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to study how Clients, Candidates and Delegates use our products/services, to develop them and grow our business)

To administer and protect our business and our website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) 

(a) Necessary to comply with a legal obligation

(b) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)

To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you

Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)

To use data analytics to improve our website, products/services, marketing, customer relationships and experiences

Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform on marketing strategy)

To invite you to networking and professional events, and to inform you about developments in our business or recruitment/ HR more widely. 

(a) Consent (where you have provided positive consent)

(b) Necessary for our legitimate interests (to develop our products/services and grow our business).

We will only use your personal data for the purposes for which we collect it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the origional purpose. 

In addition, we may process your personal data without your knowledge or consent, where this is required or permitted by law. 

Automated individual decision-making

As our recruitment services require human involvement throughout the process, there won’t be any instances where a decision is made based solely on automated decision making.

Marketing 

We may use your personal data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which of our services and vacancies may be relevant for you. 

You will receive marketing communications from us in respect of our business and our services/vacancies if you have requested information from us, enlisted with us and, in each case, you have not opted out of receiving that marketing. 

You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by using the details above at any time. 

Cookies when using our website

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see the cookie policy on our website. 

Who Has Access To Your Information

We may have to share your personal data with the parties set out below for the purposes set out in the table above:

  • Prospective Employers and Candidates

  • Third parties who we interact with on your behalf including Clients’ employees and staff, and Law At Work (CI) Limited, a support service that we use to administer payroll for our Candidates in temporary positions.

  • Service providers based within the Channel Islands, UK, wider European Economic Area (“EEA”) or outside the EEA who provide IT and system administration services.

  • Event Partners who assist us with organising events and marketing those events, based in the Channel Islands, UK, wider EEA or outside the EEA.

  • Our professional advisers including HR & H&S advisors, lawyers, bankers, auditors and insurers based in the Channel Islands, UK or EEA who provide consultancy, banking, legal, insurance and accounting services.

  • Government of Jersey including tax, social security, regulators and other authorities based in the Channel Islands or the UK who require reporting of our processing activities in certain circumstances.

  • Third parties who provide background checks and references

  • Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.

We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

International Transfers:

We may transfer your personal data to third parties providing services to us who are based outside of the EEA. This includes parties providing IT administration services and hosting services, and parties providing assistance with managing our marketing databases (including Mailchimp).

Whenever we transfer your personal data outside of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

  • you have expressly consented to the transfer of data;

  • transferring data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission;

  • using specific contracts approved by the European Commission which give personal data the same protection it has in Europe; or

  • for providers based in the US, we may transfer data to them if they are part of the Privacy Shield.

Data Retention:

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, contractual, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

For more details of our specific retention periods, please contact our Data Privacy Manager.

Accuracy, Security and Your Legal Rights:

We aim to ensure that we only process accurate and up to date information, and we require your assistance to do so, therefore if your information changes (for example you have found alternative employment) please let us know.

We have put in place appropriate security measures to prevent your information from being accidently lost, used or accessed in an unauthorised way. In addition, we limit access to your information to those employees, agents, contractors and other third parties who have a business need to know.

ASL has put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where it is legally required to do so.

Under certain circumstances, you have rights under data protection laws in relation to your personal data. These rights are set out below. If you wish to exercise any of the rights set out above, please contact our Data Privacy Manager.

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

Your legal rights are as follows:

  • Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

  • Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected.

  • Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below).

  • Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes.

  • Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in certain circumstances, for example, if you want us to establish its accuracy or the reason for processing it.

  • Request the transfer of your personal data to you or to a third party.

  • Withdraw consent at any time where we are relying on consent to process your personal data. If you withdraw your consent, we may not be able to provide our services to you.

Complaint to the Officer of the Information Commissioner

You have the right to make a complaint at any time with the Data Protection Authority through the Officer of the Information Commissioner on +44 1534 716530.

We would, however, appreciate the chance to deal with your concerns before you approach the OIC so please contact us in the first instance.

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