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Privacy and Data Protection


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Company Name:

Strategic Resources European Recruitment Consultants Ltd.  Registered Company Number SC107007 (‘the Company’)


Privacy and Data Protection Policy


Privacy and data protection


15 August 2018


Version 3



The Company is committed to protecting the privacy of individuals and to provide information on how the data is collected and what it is used for.

The Company provides work finding services, contractor management services and outsourced payrolling on behalf of Clients and Hirers.  We require personal data to provide these services. 

The information conveyed to the Company will only be used for the purpose of these services or for legal and/or regulatory compliance.

The Company is the data controller for the information that provided to us unless we advise otherwise.  

The information may be held in electronic or physical formats.


  • Introduction
  • Definitions
  • Data processing under the Data Protection Laws
    1. The data protection principles 
    2. Legal bases for processing
    3. Privacy by design and by default
    4. The Company Website
  • Rights of the Individual
    1. Privacy notices
    2. Subject access requests
    3. Rectification
    4. Erasure
    5. Restriction of processing
    6. Data portability
    7. Object to processing
    8. Enforcement of rights
    9. Automated decision making
  • Personal data breaches
    1. Personal data breaches where the Company is the data controller
    2. Personal data breaches where the Company is the data processor
    3. Communicatingpersonal data breaches to individuals
  • The Human Rights Act 1998
  • Complaints
  • Appendix
  • Annex A
    • Legal bases for processing Personal Data
    • Retention of Individuals Personal Data
    • Retention and Processing of Contractor Personal Data

All organisations that process personal data are required to comply with data protection legislation.  This includes in particular the Data Protection Act 2018 (DPA 2018) and the EU General Data Protection Regulation (together the ‘Data Protection Laws’).  The Data Protection Laws give individuals (known as ‘data subjects’) certain rights over their personal data whilst imposing certain obligations on the organisations that process their data. 

The Company collects and processes both personal data and sensitive personal data.  It is required to do so in order to comply with other legislation.  It is also required to keep this data for different periods depending on the nature of the data.   

This policy sets out how the Company implements the Data Protection Laws. 


In this policy the following terms have the following meanings:

consent’ means any freely given, specific, informed and unambiguous indication of an individual’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of persona data relating to him or her;

data controller’ means an individual or organisation which, alone or jointly with others, determines the purposes and means of the processing of personal data;

data processor’ means an individual or organisation which processes personal data on behalf of the data controller;

personal data* means any information relating to an individual who can be identified, such as by a name, photo, image, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that person. 

personal data breach’ means a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data;

processing’ means any operation or set of operations performed on personal data, such as collection, recording, organisation, structuring, storage (including archiving), adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction. 

profiling’ means any form of automated processing of personal dataconsisting of the use of personal datato evaluate certain personal aspects relating to an individual, in particular to analyse or predict aspects concerning that person’s performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements;

pseudonymisation’ means the processing of personal data in such a manner that the personal data can no longer be attributed to an individual without the use of additional information, provided that such additional information is kept separately and is subject to technical and organisational measures to ensure that the personal data is not attributed to an identified or identifiable individual;

sensitive personal data* means personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data, data concerning health, an individual’s sex life or sexual orientation and an individual’s criminal convictions.

* For the purposes of this policy we use the term ‘personal data’ to include ‘sensitive personal data’ except where we specifically need to refer to sensitive personal data

Supervisory authority’ means an independent public authority which is responsible for monitoring the application of data protection. In the UK the supervisory authorityis the Information Commissioner’s Office (ICO).

All of these definitions are italicised throughout this policy to remind the reader that they are defined terms. 

Data Processing under the Data Protection Laws

The Company processes personal data in relation to its own staff, work-seekers, individuals and Client or Hirer contacts and is a data controller for the purposes of the Data Protection Laws. The Company has registered with the ICO and its registration number is Z4853226.

The Company shall hold personal data for the following purposes:

  • Proof of identification to validate the right to work in a particular country;
  • Permission to conduct criminal record checks if applicable;
  • Data to organise medical assessments, inoculations or pre-employment medicals;
  • Training, qualification and professional body certification;
  • Staff administration;
  • Advertising, marketing and public relations;
  • Company website Job Alerts;
  • Administration and processing of work-seekers’ personal data, including employment history (CV) for the purposes of providing work-finding services, including processing using software solution providers and back office support;
  • Administration and processing of clients’ personal data for the purposes of supplying/introducing work-seekers to Clients or Hirers or the provision of contractor management services and outsourced payrolling.

The Company, on successful placement of a work-seeker or a staff employee, may request additional information.  The Company will only ask for information which will be used in legitimate business interests to ensure that the applicable assignment can be undertaken lawfully.  This may include:

  • Data to ensure provision of insurances and welfare provisions;
  • Accounts, payroll, pension and banking records;
  • Data pertaining to HMRC and legal requirements;
  • Emergency contact details, including next of kin names, addresses, telephone and email details.

1. The data protection principles  

The Data Protection Laws require the Company acting as either data controller or data processor to process data in accordance with the principles of data protection. These require that personal data is: 

  1. Processed lawfully, fairly and in a transparent manner;
  2. Collected for specified and legitimate purposes and not further processed in a manner that is incompatible with those purposes;
  3. Adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed;
  4. Accurate and kept up to date; every reasonable step must be taken to ensure that personal data that is inaccurate, having regard to the purposes for which it is processed, is erased or rectified without delay;
  5. Kept for no longer than is necessary for the purposes for which the personal data is processed;
  6. Processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures; and that
  7. The data controller shall be responsible for, and be able to demonstrate, compliance with the principles.

2. Legal basis for processing

The Company will only process personal data where it has a legal basis for doing so (see Annex A). Where the Company does not have a legal reason for processing personal  data any processing will be a breach of the Data Protection Laws. 

The Company will review the personal data it holds on a regular basis to ensure it is being lawfully processed and it is accurate, relevant and up to date and those people listed in the Appendix shall be responsible for doing this.

Before transferring personal data to any third party (such as past, current or prospective employers, suppliers, customers, Clients, Hirers or intermediaries such as umbrella companies, persons making an enquiry or complaint and any other third party (such as software solutions providers and back office support), the Company will establish that it has a legal reason for making the transfer.

Requests may processed be from the following third parties:

  • Client or Hirer companies;
  • Referees for securing references;
  • Educational and training establishments;
  • Offshore mobilisation registration and/or security clearance;
  • Medical, pension, welfare organisations;
  • Government bodies and welfare organisations
  • HMRC, tax authorities, financial auditors.

3. Privacy by design and by default

The Company has implemented measures and procedures that adequately protect the privacy of individuals and ensures that data protection is integral to all processing activities. This includes implementing measures such as:

  • data minimisation (i.e. not keeping data for longer than is necessary); 
  • pseudonymisation;
  • documentation password protection;
  • anonymisation;
  • cyber security;
  • secure servers;
  • IT firewalls.

For further information please refer to the Company’s Information Security Policy which is available on request from the Managing Director.

4. The Company Website

The Company may collect and process the following data about the individual: 

  • record of correspondence;
  • Job Alerts;
  • voluntary surveys that the Company uses for research and improvement;
  • details and statistics of the individual's visits to the Company website.

All information individuals provide to us, is stored on secure servers.

Cookies are pieces of information stored on computers’ hard drives by web browsers. Please refer to the above Cookie Policy for full details.

Rights of the Individual

The Company shall provide any information relating to data processing to an individual in a concise, transparent, intelligible and easily accessible form, using clear and plain language. The information shall be provided in writing, or by other means, including, where appropriate, by electronic means. The Company may provide this information orally when requested to do so by the individual.

1. Privacy notices

Where the Company collects personal data from the individual, the Company will give the individual a privacy notice at the time when it first obtains the personal data.

Where the Company collects personal data other than from the individual directly, it will give the individual a privacy notice within a reasonable period after obtaining the personal data, but at the latest within one month.  If the Company intends to disclose the personal data to a third party, then the privacy notice will be issued when the personal data is first disclosed (if not issued sooner). 

Data will be collected and processed from sources including the following:

  • Company website;
  • Recruitment job boards;
  • Social media sites including Linkedin and Facebook;
  • Company employees and work-seeker telephone calls, email and hard copy correspondence.

Where the Company intends to further process the personal data for a purpose other than that for which the data was initially collected, the Company will give the individual information on that other purpose and any relevant further information before it carries out further processing.

2. Subject access requests

The individual is entitled to access their personal data on request from the data controller.  

3. Rectification

Where the individual or another data controller at the individual’s request, has the right to ask the Company to rectify any inaccurate or incomplete personal data concerning an individual. 

If the Company has given the personal data to any third parties it will inform those third parties that it has received a request to rectify the personal data unless this proves impossible or involves disproportionate or unreasonable effort. Those third parties should also rectify the personal data they hold - however the Company will not be in a position to audit those third parties to ensure that the rectification has occurred. 

4. Erasure

The individual or another data controller at the individual’s request, has the right to ask the Company to erase an individual’s personal data.  

If the Company receives a request to erase it will ask the individual if s/he wants his personal data to be removed entirely or whether s/he is happy for his or her details to be kept on a list of individuals who do not want to be contacted in the future (for a specified period or otherwise). The Company cannot keep a record of individuals whose data it has erased so the individual may be contacted again by the Company should the Company come into possession of the individual’s personal data at a later date.

If the Company has made the data public, it shall take reasonable steps to inform other data controllers and data processors processing the personal data to erase the personal data, taking into account available technology and the cost of implementation.

If the Company has given the personal data to any third parties it will tell those third parties that it has received a request to erase the personal data unless this proves impossible or involves disproportionate or unreasonable effort. Those third parties should also rectify the personal data they hold - however the Company will not be in a position to audit those third parties to ensure that the rectification has occurred. 

5. Restriction of processing

The individual or a data controller at the individual’s request,has the right to ask the Company to restrict its processing of an individual’s personal data where:

  • The individual challenges the accuracy of the personal data
  • The processing is unlawful and the individual opposes its erasure;
  • The Company no longer needs the personal data for the purposes of the processing, but the personal data is required for the establishment, exercise or defence of legal claims; or
  • The individual has objected to processing (on the grounds of a public interest or legitimate interest) pending the verification whether the legitimate grounds of the Company override those of the individual.

If the Company has given the personal data to any third parties it will tell those third parties that it has received a request to restrict the personal data unless this proves impossible or involves disproportionate or unreasonable effort. Those third parties should also rectify the personal data they hold - however the Company will not be in a position to audit those third parties to ensure that the rectification has occurred.

6. Data portability

The individual shall have the right to receive personal data concerning him or her, which he or she has provided to the Company, in a structured, commonly used and machine-readable format and has the right to transmit those data to another data controller in circumstances where:

  • The processing is based on the individual’sconsentor a contract; and
  • The processing is carried out by automated means.

Where feasible, the Company will send the personal data to a named third party on the individual’s request. 

7. Object to processing

The individual has the right to object to their personal data being processed based on a public interest or a legitimate interest. The individual will also be able to object to the profiling of their data based on a public interest or a legitimate interest.

The Company shall cease processing unless it has compelling legitimate grounds to continue to process the personal data which override the individual’s interests, rights and freedoms or for the establishment, exercise or defence of legal claims.

The individual has the right to object to their personal data for direct marketing.

8. Enforcement of rights

All requests regarding individual rights should be sent to the person whose details are listed in the Appendix.

The Company shall act upon any subject access request, or any request relating to rectification, erasure, restriction, data portability or objection or automated decision-making processes or profiling within one month of receipt of the request. The Company may extend this period for two further months where necessary, taking into account the complexity, legal and contractual requirements. 

Where the Company considers that a request under this section is manifestly unfounded or excessive due to the request’s repetitive nature the Company may either refuse to act on the request or may charge a reasonable fee for the administrative costs involved. 

9. Automated decision making

The Company will not subject individuals to decisions based on automated processing that produce a legal effect or a similarly significant effect on the individual, except where the automated decision:

  • Is necessary for the entering into or performance of a contract between the data controller and the individual; or
  • Is authorised by law; or
  • The individual has given their explicit consent.

The Company will not carry out any automated decision-making or profiling using the personal data of a child. 

Personal Data Breaches

Reporting personal data breaches

All data breaches should be referred to the persons whose details are listed in the Appendix.

1. Personal data breaches where the Company is the data controller:

Where the Company establishes that a personal data breach has taken place, the Company will take steps to contain and recover the breach. Where a personal data breach is likely to result in a risk to the rights and freedoms of any individual the Company will notify the ICO.

Where the personal data breach happens outside the UK, the Company shall alert the relevant supervisory authority for data breaches in the effected jurisdiction. 

2. Personal data breaches where the Company is the data processor:

The Company will alert the relevant data controller as to the personal data breach as soon as they are aware of the breach. 

3. Communicating personal data breaches to individuals

Where the Company has identified a personal data breach resulting in a high risk to the rights and freedoms of any individual, the Company shall inform all affected individuals without undue delay. 

The Company will not be required to inform individuals about thepersonal data breach where:

  • The Company has implemented appropriate technical and organisational protection measures to the personal data affected by the breach, in particular to make the personal data unintelligible to any person who is not authorised to access it, such as encryption;
  • The Company has taken subsequent measures which ensure that the high risk to the rights and freedoms of the individual is no longer likely to materialise;
  • It would involve disproportionate effort to inform all affected individuals. Instead, the Company shall make a public communication or similar measure to tell all affected individuals. 

Human Rights Act 1998

All individuals have the following rights under the Human Rights Act 1998 (HRA) and in dealing with personal data these should be respected at all times:

  • Right to respect for private and family life (Article 8);
  • Freedom of thought, belief and religion (Article 9);
  • Freedom of expression (Article 10);
  • Freedom of assembly and association (Article 11);
  • Protection from discrimination in respect of rights and freedoms under the HRA (Article 14). 


If you have a complaint or suggestion about the Company’s handling of personal data then please contact the person whose details are listed in the Appendix to this policy.

Alternatively, you can contact the ICO directly on 0303 123 1113 or at


The Company Data Controller is the Managing Director who shall be responsible for the management of the following:

  • adding, amending or deleting personal data;
  • responding to subject access requests/requests for rectification, erasure, restriction data portability, objection and automated decision-making processes and profiling; 
  • reporting data breaches/dealing with complaints.

Annex A

1. The lawfulness of processing conditions for personal data are:

  1. Consent of the individual for one or more specific purposes.
  2. Processing is necessary for the performance of a contract with the individual or in order to take steps at the request of the individual to enter into a contract.
  3. Processing is necessary for compliance with a legal obligation that the controller is subject to.
  4. Processing is necessary to protect the vital interests of the individual or another person.
  5. Processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the data controller.
  6. Processing is necessary for the purposes of legitimate interests pursued by the controller or a third party, except where such interests are overridden by the interests or fundamental rights or freedoms of the individual which require protection of personal data, in particular where the individual is a child.

2. The lawfulness of processing conditions for sensitive personal data are:

  1. Explicit consent of the individual for one or more specified purposes unless reliance on consentis prohibited by EU or Member State law.
  2. Processing is necessary for carrying out data controller’s obligations under employment, social security or social protection law, or a collective agreement, providing for appropriate safeguards for the fundamental rights and interests of the individual.
  3. Processing is necessary to protect the vital interests of the individual or another individual where the individual is physically or legally incapable of giving consent.
  4. In the course of its legitimate activities, processing is carried out with appropriate safeguards by a foundation, association or any other not-for-profit body, with a political, philosophical, religious or trade union aim and on condition that the processing relates only to members or former members (or those who have regular contact with it in connection with those purposes) and provided there is no disclosure to a third party without the consent of the individual.
  5. Processing relates to personal datawhich are manifestly made public by the individual.
  6. Processing is necessary for the establishment, exercise or defence of legal claims or whenever courts are acting in their judicial capacity.
  7. Processing is necessary for reasons of substantial public interest on the basis of EU or Member State law which shall be proportionate to the aim pursued, respects the essence of the right to data protection and provide for suitable and specific measures to safeguard the fundamental rights and interests of the individual.
  8. Processing is necessary for the purposes of preventative or occupational medicine, for assessing the working capacity of the employee (including Agency Workers), medical diagnosis, the provision of health or social care or treatment or the management of health or social care systems and services on the basis of EU or Member State law or a contract with a health professional and subject to the necessary conditions and safeguards. 
  9. Processing is necessary for reasons of public interest in the area of public health, such as protecting against serious cross-border threats to health or ensuring high standards of quality and safety of healthcare and of medicinal products or medical devices, on the basis of EU or Member State law which provides for suitable and specific measures to safeguard the rights and freedoms of the individual, in particular professional secrecy. 
  10. Processing is necessary for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes, which shall be proportionate to the aim pursued, respect the essence of the right to data protection and provide for suitable and specific measures to safeguard fundamental rights and interests of the individual. 

Retention of Individuals Personal Data

Several laws require the Company to keep various data for different periods of time.  The Company shall retain documentation relating to work finding services for a period of 2 years after registration as a work-seeker. Should there have been no contact with the individual in that period after registration, the records of the individual will be deleted from the Company system subject to the necessary relevant or regulatory requirements.

The Company will not hold Personal Data for longer than is deemed necessary for the purposes for which the data is processed.

Retention and Processing of Contractor Personal Data

Contractors are defined as:

Consultancy Staff - Individuals who provide services through a Limited Company

Agency Workers – Individuals who provide services through an Umbrella Company

PAYE Agency Workers – under a contract for services with the Company

The default standard retention period for HMRC records is 6 years plus the current financial year. Personal data (please see the Definition of Personal Data) of Contractors, Limited Companies and Umbrella Companies, shall be retained as per the HMRC default standard retention period.

Personal data will only be retained beyond the standard default HMRC retention period if the retention of personal data can be justified for statutory, regulatory, legal or security reasons or for their historic value.