RJW & Partners (“we”, “us”, “our”) collects, stores, and processes personal data about prospective and successful Payers (subject matter experts) (“you”, “your”). We are committed to protecting your privacy and personal data, and are therefore transparent regarding the data we collect, how the data are collected, where the data are stored, and how the data are processed. The following notice details all of the above, setting out our obligations under both the General Data Protection Regulations2016/679 (“GDPR”) and the Data Protection Act2018 (“DPA”).
i. THE DATA WE COLLECT
Information we may collect from you
- Basic personal details including but not limited to your name, email address, contact number(s), postal address, and preferred method of contact.
- Availability and preferred country of interest
- Documents you provide throughout the application process including but not limited to CVs, covering letters and professional certification. These documents may contain information on your employment history, academic qualifications/history, professional training/certifications, skills, and experiences.
- Bank account details and payment records
- Passport and travel information
- Dietary requirements
- Name and contact information of your secretary
- Records of electronic communications, including but not limited to the content and attachments of emails.
Information we collect/generate about you
- Application progress including but not limited to the stages you complete of the recruitment process, records of interviews, rejection reason, and acceptance details.
- Any preferences you may have in terms of work type and location
ii. HOW THE DATA ARE COLLECTED
Personal data may come from a combination of any of the following sources:
- Information you provide on application forms and other documents, in email and telephone conversations with us, and in interviews.
- Information we collect from publicly available sources online such as professional registers
- Information we generate following your interactions with our staff, systems, and processes.
- Information provided by third parties, such as referrals or references (references are not sought without your express prior permission).
iii. HOW THE DATA ARE STORED
All personal data provided, collected, generated, or obtained will be stored on our cloud-based data storage platform and email system.
We take appropriate measures to ensure that all personal data is kept secure, including security measures to prevent personal data from being accidentally lost, or used or accessed in an unauthorised way. Within RJW, we limit access to your personal data to only those who have a genuine need to access it.
We have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of electronically transmitted data. Any transmission therefore remains at your own risk.
iv. HOW THE DATA ARE PROCESSED
Lawful basis for processing
Our lawful basis for the collection and processing of your personal data during the application process is for taking steps to enter into a contract with you. We rely on legitimate business interest as the lawful basis on which we collect and use your personal data, specifically in the instances of collecting references and running background checks that may be necessary. Once appointed to our panel of experts our legal basis for processing your personal data is contract. We will also rely on legitimate interest to enable us to retain your data for the purpose of protecting ourselves from any litigation and for our own accounts and records.
Purposes of processing
We use information held about you in a number of ways, including but not limited to:
- Considering your application as a subject matter expert
- Communicating with you in respect of the recruitment process
- Enhancing any information that we receive from you with information collected, generated, or obtained throughout our recruitment processes.
- For the purpose of maintaining our database of experts
- Share your professional details with our clients for the purpose of allowing them to select a panel of experts
- To provide you with work. This may also include arranging your travel, accommodation and ensuring any specific requirements you may have, for example dietary, are passed to the appropriate party.
- Payment of your account
Rights of access, correction, and erasure
Under the GDPR, you have a number of important rights. It is important to understand that not all of these are absolute rights.
- Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
- Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
- Request erasure of your personal information. This enables you to ask us to delete or remove personal information 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 information where you have exercised your right to object to processing (see below).
- Object to processing of your personal information 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. You also have the right to object where we are processing your personal information for direct marketing purposes.
- Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
- Request the transfer of your personal information to another party.
In the event you make a request to access your data, RJW will provide you with a permeant within 30 days of the request. In some circumstances we may ask you for further information to allow us to identify the data you have requested. In most cases no fee will be charged.
In order to correct any inaccuracies in your personal data held by RJW, you must make a request to us, clearly indicating which information is in need of amendment, along with the correct information to take its place. RJW will act on personal data correction requests within five working days of receipt, and send a confirmation email to you upon resolution of the issue/s.
In order to request partial or full erasure of your personal data, you must make an explicit request to us. In the event you desire a partial erasure, you must clearly indicate which data points you would like to be erased. In the event you desire a full erasure, you must clearly indicate this in your request. RJW will act on partial and full erasure requests within five working days of receipt, however, no confirmation email will be sent following the completion of the request.
Please note that your right to have your personal data erased is not an absolute right, and we reserve the right to refuse such a request, where there is an appropriate legal justification for doing so. You will be notified accordingly in the event we are unable to process your data erasure request.
If, at any point, you would like to make a request for access, correction, or erasure of your personal data held by RJW, you should email email@example.com providing enough information for us to be able to identify you in our system and carry out your request.
How long we keep your personal data
If your application to become an expert is unsuccessful all data will be deleted within 6 months.
For active experts on our database, we will retain your data for as long as our business relationship remains active. At the end of this business relationship we will retain all accounts and records relating to the work you have undertaken for a period of 3 years.
How to complain
We hope that we can resolve any query or concern you raise about our use of your personal data, however, if you are not satisfied with our processes or approach, the GDPR gives you the right to file a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, live, or where any alleged infringement of data protection laws occurred. The supervisory authority in the UK is the Information Commissioner who may be contacted at http://ico.org.uk/concerns/or on 0303 123 1113.
Contacting RJW Partners
If you have any questions, queries, or issues relating to our recruitment policies and processes, or how they relate to our adherence to both the GDPR and DPA, then please contact firstname.lastname@example.org