INTRODUCTION
This privacy policy explains what we do with your personal data, whether we are in the process of helping you find a job, continuing our relationship with you once you have found a role, providing you with a service, receiving a service from you, using your data to ask for your assistance in relation to one of our Candidates, or you are visiting our website.
It describes how we collect, use and process your personal data, and how, in doing so, we comply with our legal obligations to you. Your privacy is important to us, and we are committed to protecting and safeguarding your data privacy rights.
This Privacy Policy applies to the personal data of our Website Users, Candidates, Clients, Suppliers and other people whom we may contact in order to find out more about our Candidates or whom they indicate is an emergency contact.
For the purpose of applicable data protection legislation (including but not limited to the General Data Protection Regulation (Regulation (EU) 2016/679 (the GDPR)), the company responsible for your personal data, Teaching Abroad Direct Limited (TAD), can be found in Annex 1.
We may amend and update this Privacy Policy from time to time, please visit this page if you want to stay up to date, as we will post any changes here.
If you are unhappy with any aspect of our Privacy Policy, you may have legal rights and, where relevant we have described these below.
For a more in-depth version see the Long Form Detailed Sections.
SECTION A
A1 - WHAT KIND OF PERSONAL DATA DO WE COLLECT?
(i) CANDIDATE DATA
In order to provide the best possible employment opportunities that are tailored to you, we need to process certain information about you.
We will only ask for details that will genuinely help us to help you, such as your name, age, contact details, education details and employment history, along with any other information you choose to share with us. For a more comprehensive list see Section B1 (i).
When you access our website we also collect certain data from you; if you would like more information about this see Section B10.
(ii) CLIENT DATA
If you are a customer of TAD we need to collect information about you or individuals at your organisation for the purpose of finding you Candidates who are a right fit for your organisation. For more detailed information on the data we collect see Section B1 (ii).
When you access our website we also collect certain data from you. If you would like more information about this see Section B10.
(iii) SUPPLIER DATA
We need a small amount of data from our Suppliers to ensure things run smoothly. We need contact details for relevant individuals at your organisation, so we can communicate with you. We also need information such as bank details, so we can pay for the services you provide.
For more detailed information on the data we collect see Section B1 (iii).
When you access our website we also collect certain data from you; if you would like more information about this see Section B10.
(iv) PEOPLE WHOSE DATA WE RECEIVE FROM CANDIDATES, SUCH AS REFEREES AND REFERRALS
In order to provide Candidates with suitable employment opportunities safely and securely and to provide for every eventuality for them and our employees, we need some basic background information. We only ask for very basic contact details, so we can have a further conversation in regard to a reference or to offer you the opportunity to become a Client or Candidate.
For more detailed information on the data we collect see Section B1 (iv).
(v) WEBSITE USERS
We collect a small amount of data from our Website Users which we use to help us improve your experience when using our websites and help us manage the services we provide. This includes information such as how you use our website and the frequency of your visits.
For more detailed information on the data we collect see Section B1 (v) and Section B10.
Depending on the type of personal data in question and the grounds on which we may be processing it, should you decline to provide us with such data, we may not be able to fulfil our contractual requirements or, in extreme circumstances, may not be able to continue with our relationship.
For details of the legal bases that we rely on to be able to use and process your personal data see Section B11.
A2 - HOW DO WE COLLECT YOUR PERSONAL DATA?
(i) CANDIDATE DATA
There are 2 main ways that we may collect your data;
Directly from you; or
From a third party.
For more detailed information on how we collect your data see Section B2 (i).
When you access our website, read or click on an email from us we also collect certain data from you; if you would like more information about this seeSection B2 (i) and Section B10.
(ii) CLIENT DATA
There are 2 main ways that we may collect your data;
Directly from you; or
From a third party (e.g. our Candidates) and other limited sources (e.g. online and offline media).
For more detailed information on how we collect your data see Section B2 (ii).
When you access our website, read or click on an email from us we also collect certain data from you; if you would like more information about this seeSection B2 (ii) and Section B10.
(iii) SUPPLIER DATA
We collect your personal data during the course of our work with you.
When you access our website, read or click on an email from us we also collect certain data from you; if you would like more information about this seeSection B10.
(iv) PEOPLE WHOSE DATA WE RECEIVE FROM CANDIDATES, SUCH AS REFEREES AND REFERRALS
We collect your contact details only where a Candidate or a Client passes this information to us as an emergency contact, referral or in order to obtain a reference.
(v) WEBSITE USERS
We collect your data automatically via cookies when you visit our website, in line with cookie settings in your browser. If you would like to find out more about cookies, including how we use them and what choices are available to you please see Section B10.
We will also collect data from you when you contact us via the website, for example by using the contact form.
A3 - HOW DO WE USE YOUR PERSONAL DATA?
(i) CANDIDATE DATA
The main reason for us using your personal data is to help you find employment that might be suitable for you. The more information we have about you, your skillset and your ambitions, the more bespoke we can make our service. Where appropriate, we may also use your personal data for things such as marketing, profiling and diversity monitoring. Where appropriate, we will seek your consent to undertake some of these activities.
For more details on how we use your personal data, please see Section B3 (i).
(ii) CLIENT DATA
The main reason for using information about Clients is to ensure that the contractual arrangements between us can be properly be implemented so that the relationship can run smoothly. This will involve identifying Candidates who we think will be the right fit for your organisation. The more information we have, the more bespoke service we can provide.
For more details on how we use your personal data, please see Section B3 (ii).
(iii) SUPPLIER DATA
The main reason for using information about Suppliers is to ensure that the contractual arrangements between us can be properly be implemented so that the relationship can run smoothly, and to comply with legal requirements.
For more details on how we use your personal data, please see Section B3 (iii).
(iv) PEOPLE WHOSE DATA WE RECEIVE FROM CANDIDATES, SUCH AS REFEREES AND REFERRALS
We use referees’ personal data to help our Candidates to find employment which is suited to them. If we are able to verify their details and qualifications, we can make sure that they are well matched with prospective employers. We may also use referees’ personal data to contact them in relation to recruitment activities that may be of interest to them. For more details on how we use your personal data, please see Section B3 (iv).
(v) WEBSITE USERS
We use your data to help us to improve your experience of using our website, for example by analysing your recent job search criteria to help us to present jobs to you that may be of interest to you. If you are also a Candidate or Client of TAD, we may use data from your use of our website to enhance other aspects of our communications with, or service to, you.
If you would like to find out more about cookies, including how we use them and what choices are available to you please see Section B10.
Please note that communications to and from TAD staff including emails may be reviewed as part of internal or external investigations or litigation.
A4 - WHO DO WE SHARE YOUR PERSONAL DATA WITH?
(i) CANDIDATE DATA
We may share your personal data with various parties, in various ways and for various reasons. Primarily we will share your information with prospective employers to increase your chances of securing the job you want. Unless you specify otherwise, we may also share your information with any of our subsidiary companies and associated third parties such as our service providers where we feel this will help us to provide you with the best possible service.
If you would like to see a list of who we may share your personal data with, please see Section B4.
(ii) CLIENT DATA
We will share your data to ensure that we provide you with a suitable pool of Candidates. Unless you specify otherwise, we may share your information with any of our subsidiary companies and associated third parties such as our service providers to help us meet this aim.
If you would like to see a list of who we may share your personal data with, please see Section B4.
(iii) SUPPLIER DATA
Unless you specify otherwise, we may share your information with any of our subsidiary companies and associated third parties such as our service providers and organisations to whom we provide services.
If you would like to see a list of who we may share your personal data with, please see Section B4.
(iv) PEOPLE WHOSE DATA WE RECEIVE FROM CANDIDATES, SUCH AS REFEREES AND REFERRALS
Unless you specify otherwise, we may share your information with any of our subsidiary companies and associated third parties such as our service providers and organisations to whom we provide services.
If you would like to see a list of who we may share your personal data with, please see Section B4.
(v) WEBSITE USERS
Unless you specify otherwise, we may share your information with the providers of web analytics services, marketing automation platforms and social media services to make sure any advertising you receive is tailored to you.
A5 - HOW DO WE SAFEGUARD YOUR PERSONAL DATA?
We care about protecting your information. That is why we put in place appropriate measures that are designed to prevent unauthorised access to, and misuse of, your personal data.
For more information on the procedures we put in place, please see Section B5.
A6 - HOW LONG DO WE KEEP YOUR PERSONAL DATA FOR?
If we have not had meaningful contact with you (or, where appropriate, the company you are working for or with) for a period of 5 years, we will delete your personal data from our systems unless we believe in good faith that the law or any other regulation requires us to preserve it (for example, in connection with any anticipated litigation).
For more information on our policy for the retention of personal data, please see Section B6.
A7 - HOW CAN YOU ACCESS, AMEND OR TAKE BACK THE PERSONAL DATA THAT YOU HAVE GIVEN TO US?
Even if we already hold your personal data, you still have various rights in relation to it. To get in touch about these, please contact us at [email protected]. We will seek to deal with your request without undue delay, and in any event in accordance with the requirements of any applicable laws. Please note that we may keep a record of your communications to help us to resolve any issues which you raise.
(i) Right to object: If we are using your data because we deem it necessary for our legitimate interests to do so, and you do not agree, you have the right to object. We will respond to your request within 30 days (although we may be allowed to extend this period in certain cases). Generally, we will only disagree with you if certain limited conditions apply.
(ii) Right to withdraw consent: Where we have obtained your consent to process your personal data for certain activities (for example profiling your suitability for certain roles), or consent to market to you, you may withdraw your consent at any time.
(iii) Data Subject Access Requests (DSAR): You have the right to ask us to confirm what information we hold about you at any time, and you may ask us to modify, update or delete such information. At this point we may comply with your request or additionally do one of the following:
We may ask you to verify your identity, or ask for more information about your request; and
Where we are legally permitted to do so, we may decline your request, but we will explain why if we do so.
(iv) Right to erasure: in certain situations (for example, where we have processed your data unlawfully), you have the right to request us to “erase” your personal data. We will respond to your request within 30 days (although we may be allowed to extend this period in certain cases) and will only disagree with you if certain limited conditions apply. If we do agree to your request, we will delete your data but will generally assume that you would prefer us to keep a note of your name on our register of individuals who would prefer not to be contacted. That way, we will minimise the chances of you being contacted in the future where your data is collected in unconnected circumstances. If you would prefer us not to do this, you are free to say so.
(v) Right of data portability: if you wish, you have the right to transfer your data from us to another data controller. We will provide you with a copy in a commonly used machine-readable format.
(vi) Right to lodge a complaint with a supervisory authority: you also have the right to lodge a complaint with your local supervisory authority, details of which can be found in Annex 2.
If your interests or requirements change, you can unsubscribe from part or all of our marketing content (for example job role emails or TAD Newsletters) by clicking the unsubscribe link in the email.
If you would like to know more about your rights in respect of the personal data we hold about you, please see Section B7.
A8 - HOW DO WE STORE AND TRANSFER YOUR DATA INTERNATIONALLY?
TAD has Clients that have a presence overseas; in order for us to offer the level of service that we do, we may have to transfer or store your data internationally.
For more information on the steps we take when we transfer and store your data internationally, please see Section B9.
A9 - WHAT ARE COOKIES AND HOW DO WE USE THEM?
A “cookie” is a bite sized piece of data that is stored on your device’s memory. They are used by nearly all websites and do not harm your system. We use them to track your activity to help ensure you get the smoothest possible experience when visiting our website. We can use the information from cookies to ensure we present you with options tailored to your preference on your next visit. We can also use cookies to analyse traffic and for advertising purposes.
If you want to check or change what types of cookies you accept, this can usually be altered within your browser’s settings.
If you want to find out more about cookies, including how we use them and what choices are available, please see Section B10.
A10 - HOW TO REJECT COOKIES
If you don’t want to receive cookies that are not strictly necessary to perform basic features of our site, you may choose to opt-out by changing your browser settings.
Most web browsers will accept cookies but if you had rather we didn’t collect data in this way you can choose to accept all or some or reject cookies in your browser’s privacy settings. However, rejecting all cookies means that you may not be able to take full advantage of all our website’s features. Each browser is different, so check the “help” menu of your browser to learn how to change your cookie preferences.
For more information generally on cookies, including how to disable them, please refer to www.aboutcookies.org.
Long Form Detailed Sections
SECTION B
B1 - WHAT KIND OF PERSONAL INFORMATION DO WE COLLECT?
Here is a more detailed look at the information we may collect. The information described below is, of course, in addition to any personal data we are required by law to process in any given situation.
(i) CANDIDATE DATA
Depending on the relevant circumstances, we may collect some or all of the information listed below to enable us to offer you employment opportunities which are tailored to your circumstances and your interests.
-Name;
-Age/Date of Birth;
- Sex/Gender;
-Photograph;
-Marital Status;
-Contact Details;
-Education Details;
-Employment History;
-Emergency contacts and details of any dependants;
-Referee details;
-Nationality/citizenship/place of birth;
-A copy of your driving licence and or passport;
-National Insurance Number ;
Diversity Information, including racial or ethnic origin, religious or other similar beliefs, and physical or mental health, including disability-related information;
-Details of any criminal convictions if this is required for a role that you are interested in applying for;
-Details about your current remuneration, pensions and benefits arrangements;
-Information on your interests and needs regarding future employment, both collected directly and inferred, for example from jobs viewed or articles read on our website;
-Extra information that you choose to tell us;
-Extra information that your referee chooses to tell us about you;
-Extra information that our Clients may tell us about you;
-IP address; and
-The dates, times and frequency with which you access our services.
Please note that the above list of categories of personal data we may collect is not exhaustive.
To the extent that you access our website we will also collect certain information from you. If you would like more information about this, please see Section B10.
(ii) CLIENT DATA
We generally only need to have your contact details or the details of individual contacts at your organisation (such as names, telephone numbers and email addresses) to enable us to ensure that our relationship runs smoothly. We may also hold extra information that someone in your organisation has chosen to tell us.
If we need any additional personal data for any reason, we will let you know.
To the extent that you access our website we will also collect certain data from you. If you would like more information about this, please see Section B10.
(iii) SUPPLIER DATA
We don’t collect much information about Suppliers – we simply need to make sure that our relationship runs smoothly. We will collect the details for our contacts within your organisation, such as names, telephone numbers and email addresses. We will also collect bank details, so that we can pay you. We may also hold extra information that someone in your organisation has chosen to tell us.
To the extent that you access our website we will also collect certain data from you. If you would like more information about this, please see Section B10.
(iv) PEOPLE WHOSE DATA WE RECEIVE FROM CANDIDATES, SUCH AS REFEREES AND REFERRALS
All we need from referees is confirmation of what you already know about our Candidate, so that they can secure a job. To ask for a reference, we will obviously need the referee’s contact details (such as name, email address and telephone number)
(v) WEBSITE USERS
We collect a limited amount of information from our Website Users which we use to help us improve your experience when using our website and to help us manage the services we provide. This includes information such as how you use our website, the frequency with which you access our website, your browser type, the location you view our website from, the language you choose to view it in and the time of day you visit. If you use our contact us function, we will collect any information you provide to us, for example you name and contact details.
If you would like to find out more information about what data we collect about you when you visit our website, please see Section B10.
B2 - HOW DO WE COLLECT YOUR PERSONAL DATA?
(i) CANDIDATE DATA
We collect Candidate personal data in three primary ways:
Personal data that you, the Candidate, give to us;
Personal data that we receive from other sources; and
Personal data that we collect automatically.
1. Personal Data you give us
TAD needs to know certain information about you in order to provide a bespoke service. This will enable us to provide you with the best opportunities and should save you time in not having to go through a lot of information about jobs and services that aren’t relevant to you.
There are numerous ways you can share your information with us, it all depends on what you prefer. These may include:
-Entering your details on our website or via an application form as part of the registration process;
-Giving a hard copy CV to one of our consultants or sending a copy to our office; or
-Emailing your CV to one of our consultants or being interviewed by them.
2. Personal data we receive from other sources
We also receive personal data about Candidates from other sources. Depending on the relevant circumstances these may include personal data received in the following situations:
-Your referees may disclose personal information about you with us; and
-Our Clients may share personal information about you with us.
3. Personal data we collect automatically
To the extent that you access our website or read or click on an email from us, where appropriate, we may also collect your data automatically or through you providing it to us. For more information please see Section B10.
(ii) CLIENT DATA
We collect Client personal data in three primary ways:
Personal data that we receive directly from you;
Personal data that we receive from other sources; and
Personal data that we collect automatically.
1. Personal data that we receive directly from you
We both share the same goal – to make sure you have the best staff for your organisation. We will receive data directly from you in 2 ways:
Where you contact us proactively, usually by phone or email; and/or
Where we contact you, either by phone or email, through our consultants’ business development activities more generally.
2. Personal data we receive from other sources
Where appropriate, we may seek more information about you or your colleagues from other sources generally by way of due diligence or other marketing intelligence including:
-From third party market research and by analysing online and offline media;
-From delegate lists at relevant events; and
-From other limited sources and third parties (for example from our Candidates to the extent that they provide us with your details to act as a referee for them).
3. Personal data we collect via our website
To the extent that you access our website or read or click and email from us, where appropriate, we may also collect your data automatically or through you providing it to us. For more information please see Section B10.
(iii) WEBSITE USERS
When you visit our website there is certain information that we automatically collect, whether or not you decide to use our services. This includes your IP address, the date and times and frequency with which you access our website and the way you browse its content. We will also collect data from you when you contact us via the contact form.
We collect your data automatically via cookies, in line with cookie settings in your browser. If you are also a Candidate or Client of TAD, we may use data from your use of our websites to enhance other aspects of our communications with or service to you. If you would like to find out more about cookies, including how we use them and what choices are available to you, please see Section B10.
B3 - HOW DO WE USE YOUR PERSONAL DATA?
Having obtained data about you, we then use it in a number of ways.
(i) CANDIDATE DATA: We generally use Candidate data in three ways:
Recruitment activities
Marketing activities
Equal opportunities monitoring and
To help us to establish, exercise or defend legal claims
Here are some more in-depth details about each:
(a) Recruitment Activities
Our main area of work is recruitment – matching the right Candidates with the right jobs. We’ve listed below various ways in which we may use and process your personal data for this purpose, where appropriate. Please note this is not an exhaustive list.
-collecting your data from you and from other sources ;
-Storing your details (and updating them when necessary) on our database, so that we can contact you in relation to recruitment.
-Providing you with our recruitment services and to facilitate the recruitment process;
-Assessing data about you against vacancies which we think may be suitable for you;
-Sending your information to Clients, in order to apply for jobs or to assess your eligibility for jobs;
-Enabling you to submit your CV, apply online for jobs or to subscribe to alerts about jobs we think may be of interest to you;
-Allowing you to participate in the interactive features of our services when you choose to do so;
-Carrying out our obligations arising from any contracts entered into between us;
-Carrying out our obligations arising from any contracts entered into between TAD and third parties in relation to your recruitment;
-Facilitating our invoicing processes;
-Carrying out customer satisfaction surveys;
-Verifying details you have provided, using third party resources (such as psychometric evaluations or skill tests), or to request information (such as references, qualifications and potentially and criminal convictions), to the extent that is appropriate;
-Complying with our legal obligations in connection with the detection of crime or the collection of taxes or duties; and
-Processing your data to enable us to send you targeted, relevant marketing materials or other communications which we think are likely to be of interest to you.
We may use your personal data for the above purposes if we deem it necessary to do so for our legitimate interests. If you want to know more about what this means, please see Section B11 (i) If you are not happy about this, in certain circumstances you have the right to object and can find out more about how to do this in Section B7 (a).
(b) Marketing Activities
We may periodically send you information that we think you may find interesting, or to ask for your help with connecting other Candidates with jobs. In particular, we may which to use your data for the purposes listed below, where appropriate. Please note that this list is not exhaustive. To:
-enable us to develop and market other products and services;
-market our full range or recruitment services -send you details of reports, promotions, offers, networking and Client events, and general information about positions we think might be of interest to you; and
-display promotional excerpts from your details on our website as a testimonial (only where we have obtained your express consent to do so).
We need your consent for some aspects of these activities which are not covered by our legitimate interests (in particular, the collection of data via cookies, and the delivery of direct marketing to you through digital channels) and depending on the situation, we’ll ask for this via an opt-in or soft opt-in.
Soft opt-in consent is a specific type of consent which applies where you have previously engaged with us (for example by submitting a job application or CV or registering a vacancy to be filled) and we are marketing other recruitment led services. Under ‘soft opt-in’ consent, we will take your consent as given unless or until you opt out. For most people, this is beneficial as it allows us to suggest other jobs to you alongside the specific one you applied for, significantly increasing the likelihood of us finding you a new position. For other types of e-marketing, we are required to obtain your explicit consent.
If you want to know more about how we obtain consent, please see Section B12. if you are not happy about our approach to marketing, you have the right to withdraw your consent at any time and can find out more about how to do this in Section B7 (b).
All our marketing is based on what we think will serve our Clients and Candidates best, but we know we won’t always get it right for everyone. We may use your information to show you advertisements and other content on other websites. If you do not want us to use your data in this way, please turn off the “Advertising Cookies” option (please refer to our Cookies Policy in Section B10). Even where you have turned off advertising cookies it is still possible that you may see TAD advertisements, but in this case, it won’t have been targeted at you personally, but rather at an anonymous audience.
(c) Equal opportunities monitoring and other sensitive personal data
We are committed to ensuring that our recruitment processes are aligned with our approach to equal opportunities. Some of the data we may (in appropriate circumstances) collect about you comes under the umbrella of “diversity information”. This could be information about your ethnic background, gender, disability, age, sexual orientation, religion or other similar beliefs, and/or social -economic background. Where appropriate, we’ll use this information on an anonymised basis to monitor compliance with our equal opportunities policy. We may also disclose this (suitably anonymised where relevant) data to our Clients where this is contractually required, or the Client specifically requests such information to enable them to comply with their own employment processes.
This information is categorised as ‘sensitive’ personal information and stricter data protection rules apply to it. We therefore need to obtain your explicit consent before we can use it. We’ll ask for your consent by offering you an opt-in; this means that you have to explicitly and clearly tell us that you agree to us collecting and using this information.
We may collect other sensitive personal data about you, such as health-related information, religious affiliation, or details of any criminal convictions if this is appropriate and is required for a role that you are interested in applying for. We will never do this without your explicit consent.
If you would like to find out more about consent, please see Section B12.
If you are not happy about this, you have the right to withdraw your consent at any time and you can find out how to do so in Section B7 (b).
(d) To help us to establish, exercise or defend legal claims
In more unusual circumstances, we may use your personal data to help us establish, exercise or defend legal claims.
(ii) CLIENT DATA
We use Client data for
a) Recruitment Activities;
b) Marketing Activities; and
c) To help us establish, exercise or defend legal claims.
Here are some more details about each
(a) Recruitment Activities
Our main area of work is recruitment, through providing you with Candidates.
We have listed below the various ways in which we use your data in order to facilitate this.
Storing your details (and updating them where necessary) on our database, so that we can contact you in relation to recruitment activities;
Keeping records of our conversations and meetings, so that we can provide targeted services to you;
Undertaking customer satisfaction surveys
Processing your data for the purpose of targeting appropriate marketing campaigns
We may use your personal data for these purposes if we deem this to be necessary for our legitimate interests. If you would like to know more about what this means, please see Section B11 (ii).
If you are not happy about this, in certain circumstances you have the right to object and can find out more about how to do this in Section B7 (a).
(b) Marketing Activities
We will not, as a matter of course, seek your consent when sending marketing materials to a corporate postal or email address.
If you are not happy about this, you have the right to opt-out of receiving marketing materials from us and can find out more about how to do so in Section B7 (b).
(c) To help us to establish, exercise or defend legal claims
In more unusual circumstances, we may use your personal data to help us establish, exercise or defend legal claims.
(iii) SUPPLIER DATA
We will only use your information:
To store (and update where necessary) your details on our database, so that we can contact you in relation to our agreements;
To offer services to you or to obtain support and services from you;
To perform certain legal obligations;
To help us target appropriate marketing campaigns; and
In more unusual circumstances, to help us establish, exercise or defend legal claims.
We may use your personal data for these purposes if we deem this to be necessary for our legitimate interests. If you want to know more about what this means, please see Section B11 (iii).
We will not, as a matter of course, seek your consent when sending marketing materials to a corporate postal or email address.
If you are not happy about this, in certain circumstances you have the right to object and can find out more about how to do so in Section B7 (a).
(iv) PEOPLE WHOSE DATA WE RECEIVE FROM CANDIDATES, SUCH AS REFEREES AND REFERRALS
We will only use the information that our Candidates give us about you for the following purposes:
-if you were nominated by our Candidate as a referee, we will contact you in order to take up a reference. This is an important part of our Candidate quality assurance process and could be the difference between the individual getting a job or not.
-if you were nominated by our Candidate as a referee, we may sometimes use your details to contact you in relation to recruitment activities that we think may be of interest to you, in which case we will use your data for the same purposes for which we use the data of Clients; if you would like to find out more about what this means, please see Section B3 (ii).
We may use your personal data for these purposes if we deem this to be necessary for our legitimate interests. If you would like to find out more about what this means, please see Section B11 (iv).
If you are not happy about this, you have the right to object and can find out more about how to do so in Section B7 (a).
(v) WEBSITE USERS
We use your data to help us improve your experience of using our website, for example by analysing your recent job search criteria to help us to present jobs or Candidates to you that we think you’ll be interested in.
If you would like to find out more about cookies, including how we use them and what choices are available to you, please see Section B10.
B4 - WHO DO WE SHARE YOUR PERSONAL DATA WITH?
Where appropriate, we may share your personal data, in various ways and for various reasons, with the following categories of people:
Our associated company, Teaching Jobs in London Limited;
Individuals and organisations who hold information related to your reference, such as current, past or prospective employers and educators and examining bodies;
Tax, audit, or other authorities, when we believe in good faith that the law or other regulation requires us to share this data (for example, because of a request by a tax authority or in connection with any anticipated litigation);
Third party service providers who perform functions on our behalf (including external consultants, business associates and professional advisors such as lawyers, auditors and accountants, technical support functions and IT consultants carrying out testing and development work on our business technology systems);
Third party outsourced IT and document storage providers where we have an appropriate processing agreement (or similar protections) in place;
Marketing technology platforms and Suppliers;
In the case of Candidates: potential employers to increase your chances of finding employment;
In the case of Candidates and our Candidates’ referees: third parties who we have retained to provide services such as reference, qualification and criminal conviction checks, to the extent that these checks are appropriate;
If TAD merges with or is acquired by another business or company in the future, (or is in meaningful discussions about such a possibility) we may share your personal data with the (prospective) new owners of the business or company.
B5 - HOW DO WE SAFEGUARD YOUR DATA?
We are committed to taking all reasonable and appropriate steps to protect the personal information that we hold from misuse, loss, or unauthorised access. We do this by having in place a range of appropriate technical and organisational measures. These include measures to deal with any suspected data breach.
If you suspect any misuse or loss of or unauthorised access to your personal information please let us know immediately. Details of how to contact us can be found in Annex 1.
B6 - HOW LONG DO WE KEEP YOUR PERSONAL DATA FOR?
We will delete your personal data from our systems if we have not had any meaningful contact with you (or where appropriate, the company you are working for or with) for 5 years; (or for such longer period as we believe in good faith that the law or relevant regulators require us to preserve your data) after this period, it is likely your data will no longer be relevant for the purposes for which it was collected.
When we refer to “meaningful contact”, we mean, for example, communication between us (either verbal or written), or where you are actively engaging with our online services. If you are a Candidate, we will consider there to be meaningful contact with you if you submit your updated CV onto our website. We will also consider it meaningful contact if you communicate with us about potential roles, either by verbal or written communication or click through from any of our marketing communications. Your receipt, opening or reading of an email or other digital message from us will not count as meaningful contact – this will only occur in cases where you click through or reply directly.
B7 - HOW CAN YOU ACCESS, AMEND OR TAKE BACK THE PERSONAL DATA THAT YOU HAVE GIVEN TO US?
One of the GDPR’s main objectives is to protect and clarify the rights of EU citizens and individuals in the EU with regards to data privacy. This means that you retain various rights in respect of your data, even once you have given it to us. These are described in more detail below.
To get in touch about these rights, please contact us at [email protected]. We will seek to deal with your request without undue delay, and in any event within one month (subject to any extensions to which we are lawfully entitled). Please note that we may keep a record of your communications to help us resolve any issues which you raise.
(a) Right to object: this right enables you to object to us processing your personal data where we do so for one of the following four reasons: (i) our legitimate interests; (ii) to enable us to perform a task in the public interest or exercise official authority; (iii) to send you direct marketing materials; and (iv) for scientific, historical, research, of statistical purposes.
The “legitimate interests” and “direct marketing” categories above are the ones most likely to apply to our Website Users, Candidates, Clients and Suppliers. If your objection relates to us processing your personal data because we deem it necessary for your legitimate interests, we must act on your objection by ceasing the activity in question unless:
-we can show that we have compelling legitimate grounds for processing which overrides your interests; or
-we are processing your data for the establishment, exercise or defence of a legal claim.
If your objection relates to direct marketing, we must act on your objection by ceasing this activity.
(b) Right to withdraw consent: where we have obtained your consent to process your personal data for certain activities (for example, for our marketing arrangements for automatic profiling), you may withdraw this consent at any time and we will cease to carry out the particular activity that you previously consented to, unless we consider that there is an alternative reason to justify our continued processing of your data for this purpose, in which case we will inform you of this condition.
(c) Data subject access requests (DSAR): you may ask us to confirm what information we hold about you at any time, and request us to modify, update or delete such information. We may ask you to verify your identity and for more information about your request. If we provide you with access to the information we hold about you, we will not charge you for this unless your request is “manifestly unfounded or excessive”. If you request further copies of this information from us, we may charge you a reasonable administrative cost where legally permissible. Where we are legally permitted to do so, we may refuse your request. If we refuse your request, we will always tell you the reason for doing so.
(d) Right to erasure: you have the right to request that we erase your personal data in certain circumstances. Normally, the information must meet one of the following criteria:
-the data is no longer necessary for the purpose for which we originally collected and/or processed it;
-where previously given, you have withdrawn your consent to us processing your data, and there is no other valid reason for us to continue processing;
-the data has been processed unlawfully (for example, in a manner which does not comply with GDPR);
-it is necessary for the data to be erased in order for us to comply with our legal obligations as a data controller; or
-if we process the data because we believe it necessary to do so for our legitimate interests, you object to the processing and we are unable to demonstrate overriding legitimate grounds for our continued processing.
We would only be entitled to refuse to comply with your request for one of the following reasons:
-to exercise the right of freedom of expression and information;
-to comply with legal obligations or for the performance of a public interest task or exercise of official authority;
-for public health reasons in the public interest;
-for archival, research or statistical purposes; or
-to exercise or defend a legal claim.
When complying with a valid request for the erasure of data we will take all reasonably practicable steps to delete the relevant data.
(e) Right to restrict processing: you have the right to request that we restrict our processing of your personal data in certain circumstances. This means that we can only continue to store your data and will not be able to carry out any further processing activities with it until either: (i) one of the circumstances listed below is resolved; (ii) you consent; or (iii) further processing is necessary for either the establishment, exercise or defence of legal claims, the protection of the rights of another individual, or reasons of important EU or Member State public interest.
The circumstances in which you are entitled to request that we restrict the processing of your personal data are:
-Where you dispute the accuracy of the personal data that we are processing about you. In this case, our processing of your personal data will be restricted for the period during which the accuracy of the data is verified;
-where you object to our processing of your personal data for our legitimate interests. Here, you can request that the data be restricted while we verify our grounds for processing your personal data;
-where our processing of your data is unlawful, but you would prefer us to restrict our processing of it rather than erasing it; and
-where we have no further need to process your personal data but you require the data to establish, exercise, or defend legal claims.
If we have shared your personal data with third parties, we will notify them about the restricted processing unless this is impossible or involves disproportionate effort. We will, of course, notify you before lifting any restriction on processing your personal data.
(f) Right to rectification: you also have the right to request that we rectify any inaccurate or incomplete data that we hold about you. If we have shared this personal data with third parties, we will notify them about the rectification unless this is impossible or involves disproportionate effort. Where appropriate, we will also tell you which third parties we have disclosed the inaccurate or incomplete personal data to. Where we think that it is reasonable for us not to comply with your request we will explain our reasons for this decision.
(g) Right of data portability: if you wish, you have the right to transfer your personal data between data controllers. In effect this means that you are able to transfer your details to another platform. To allow you to do so, we will provide you with your data in a commonly used machine-readable format so that you can transfer the data to another online platform. Alternatively, we may directly transfer the data for you. This right of data portability applies to: (i) personal data that we process automatically (for example without any human intervention); (ii) personal data provided by you; and (iii) personal data that we process based on your consent or in order to fulfil a contract.
(h) Right to lodge a complaint with a supervisory authority: you also have the right to lodge a complaint with your local supervisory authority. Details of how to contact them can be found in Annex 2.
If you would like to exercise any of these rights or withdraw your consent to the processing of your personal data (where consent is our legal basis for processing your personal data), details of how to contact us can be found in Annex 1. Please note that we may keep a record of your communications to help us resolve any issues which you raise.
You may ask to unsubscribe from job alerts at any time.
It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during the period for which we hold your data.
B8 - WHO IS RESPONSIBLE FOR PROCESSING YOUR PERSONAL DATA ON OUR WEBSITE?
You can find out which entity is responsible for processing your personal data and where it is located in Annex 1.
If you have any comments or suggestions concerning this Privacy Policy, please contact us via the details in Annex 1. We take privacy very seriously so we’ll get back to you as soon as possible.
B9 - HOW DO WE STORE AND TRANSFER YOUR DATA INTERNATIONALLY?
In order to provide you with the best service and carry out the purposes described in this Privacy Policy, your data may be transferred:
-to third parties (such as advisors or other Suppliers to TAD);
-to overseas Clients;
-to a cloud based storage provider; and
-to other third parties, as referred to in Section B4.
We want to make sure that your data is stored and transferred in a way which is secure. We will therefore only transfer data outside of the European Economic Area or EEA (the Member States of the European Union, together with Norway, Iceland and Liechtenstein) where it is compliant with data protection legislation and the means of transfer provides adequate safeguards in relation to your data, for example:
-by way of data transfer agreement, incorporating the current standard contractual clauses adopted by the European Commission for the transfer of personal data by data controllers in the EEA to data controllers and processors in jurisdictions without adequate data protection laws; or
-where you have consented to the data transfer.
To ensure that your personal information receives an adequate level of protection, we have put in place appropriate procedures with the third parties we share your personal data with to ensure that your personal information is treated by those third parties in a way that is consistent with and which respects the law on data protection.
B10 - COOKIES POLICY
(i) What is a cookie?
A cookie is a piece of information that is stored on your device’s hard drive and which records your navigation of a website so that, when you revisit that website, it can present tailored options based on the information stored about your last visit. Cookies can also be used to analyse traffic and for advertising and marketing purposes.
Cookies are used by nearly all websites and do not harm your device. If you want to check or change what types of cookies you accept, this can usually be altered within your browser settings.
(ii) How do we use cookies?
We use cookies to do two things:
- to track your use of our website. This enables us to understand how you use the site and track any patterns that emerge individually or from larger groups. This helps us to develop and improve our website and services in response to what our visitors want and need; and
-to help us advertise jobs to you that we think you’ll be interested in. Hopefully this means less time for you searching through never ending pages of adverts and will get you into the employment you want more quickly.
Cookies are either:
Session cookies: these are only stored on your computer during your web session and are automatically deleted when you close your browser – they usually store an anonymous session ID allowing you to browse a website without having to log into each page, but they do not collect any information from your computer; or
Persistent cookies: a persistent cookie is stored as a file on your computer and it remains there when you close your web browser. The cookie can be read by the website that created it when you visit that website again. We use persistent cookies for Google Analytics and for personalisation.
Cookies can also be categorised as follows:
-Strictly necessary cookies: these cookies are essential to enable you to use the website effectively, such as when applying for a job, and therefore cannot be turned off. Without these cookies, the services available to you on our website cannot be provided. These cookies do not gather information about you that could be used for marketing or remembering where you have been on the internet.
-Performance cookies: these cookies enable us to monitor and improve the performance of our website. For example, they allow us to count visits, identify traffic sources and see which parts of our website are most popular.
-Functionality cookies: these cookies allow our website to remember choices you make (such as your username, language and region you are in) and provide enhanced features. For instance, we may be able to provide you with news or updates relevant to the services you use. These cookies can also be used to remember changes you have made to text size, font and other parts of web pages that you can customise. They may also be used to provide services you have requested such as viewing a video or commenting on a blog. The information these cookies collect is usually anonymised.
-Personalisation cookies: these cookies help us to advertise details of potential job opportunities that we think may be of interest. These cookies are persistent (for as long as you are registered with us) and mean that when you log in or return to the website, you may see advertising for jobs that are similar to jobs you have previously browsed.
OUR LEGAL BASES FOR PROCESSING YOUR DATA
B11 - LEGITIMATE INTERESTS
Article 6(1)(f) of the GDPR is the one that is relevant here – it says that we can process your data where it “is necessary for the purposes of the legitimate interests pursued by [us] or by a third party, except where such interests are overridden by the interests or fundamental rights or freedoms of [you] which require protection of personal data”.
We don’t believe that any of the following activities prejudice individuals in any way – in fact, they help us to offer you a more tailored and efficient service. However, you do have the right to object to us processing your personal data on this basis. If you would like to know more about how to do so, please contact us at [email protected].
(i) CANDIDATE DATA
We think that it is reasonable to expect that if you are looking for employment, you are happy for us to collect and otherwise use your personal data to offer or provide our recruitment services to you, share that information with prospective employers and assess your skills against our bank of vacancies. Once it’s looking like you might get the job, your prospective employer may also want to double check any information you have given to us or to confirm your references, qualifications and criminal record, to the extent that this is appropriate. We need to do these things so that we can function as a profit-making business and to help you and other Candidates get the jobs you deserve.
We want to provide you with tailored job recommendations and relevant articles to read to help you on your job hunt. We therefore think it’s reasonable for us to process your data to make sure that we send you the most appropriate content.
We have to make sure our business runs smoothly, so that we can carry on providing services to Candidates like you. We therefore also need to use your data for our internal administrative activities.
We also have a legitimate interest in meeting our own legal obligations. If we believe in good faith that it is necessary, we may therefore share your data in connection with crime detection, or actual or anticipated litigation.
(ii) CLIENT DATA
To ensure that we provide you with the best service possible, we store your personal data or the personal data of individual contacts at your organisation as well as keeping records of our conversations, meetings, registered jobs and placements. From time to time, we may also ask you to undertake a customer satisfaction survey. We think this is reasonable – we deem these uses of your data to be necessary for our legitimate interest as an organisation providing various recruitment services to you.
(iii) SUPPLIER DATA
We use and store the personal data of individuals within your organisation in order to facilitate the receipt of services from you as one of our Suppliers. We also hold your financial details, so that we can pay you for your services. We deem all such activities to be necessary within the range of our legitimate interests as a recipient of your services.
(iv) PEOPLE WHOSE DATA WE RECEIVE FROM CANDIDATES , SUCH AS REFEREES, REFERRALS AND EMERGENCY CONTACTS
If you have been nominated by a Candidate as one of their referees, we will use your personal data in order to contact you for a reference. This is a part of our quality assurance procedure and so we deem this to be necessary for our legitimate interests as an organisation offering recruitment services.
If a Candidate has given us your details as an emergency contact, we will use these details in the case of an accident or emergency. We are sure you will agree that this is a vital element of our people-orientated organisation, and so is necessary for our legitimate interests.
B12 - CONSENT
In certain circumstances, we are required to obtain your consent to the processing of your personal data in relation to certain activities. Depending on exactly what we are doing with your information, this consent will be opt-in consent or soft opt-in consent.
Article 4(11) of the GDPR states that (opt-in) consent is “any freely given, specific, informed and unambiguous indication of the data subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her”; in plain language, this means that:
-you have given us your consent freely, without us putting you under any type of pressure;
-you have to know what you are consenting to – so we’ll make sure we give you enough information;
-you should have control over which processing activities you consent to and which you don’t;
-you need to take positive and affirmative action in giving us your consent – we’re likely to provide a tick box for you to check so that this requirement is met in a clear and unambiguous fashion.
we will keep records of the consents that you have given in this way.
We have already mentioned that, in some cases, we will able to rely on soft opt-in consent. We are allowed to market services to you which are related to the recruitment services we provide, as long as you do not actively opt-out from these communications.
As we have mentioned, you have the right to withdraw your consent to these activities. You can do so at any time, and details of how to do so can be found in Section B7 (b).
B13 - ESTABLISHING, EXERCISING OR DEFENDING LEGAL CLAIMS
Sometimes it may be necessary for us to process personal data and, where appropriate, sensitive personal data in connection with exercising or defending legal claims. Article 9(2)(f) of the GDPR allows this where the processing is “necessary for the establishment, exercise or defence of legal claims or whenever courts are acting in their judicial capacity.”
This may arise for example where we need to take legal advice in relation to legal proceedings or are required by law to preserve or disclose certain information as part of the legal process.
ANNEXES
ANNEX 1 – HOW TO CONTACT US
-Country in which you use TAD services or supply TAD with services: United Kingdom
-Entity responsible for processing the personal data of Website Users: Teaching Abroad Direct Limited
-Entity responsible for the processing of personal data of Candidates, Clients, Suppliers and the emergency contacts and referees of Candidates: Teaching Abroad Direct Limited
How to get in touch with us:
- To access, amend or take back the personal data you have given to us;
-If you suspect any misuse or loss or unauthorised access to your personal information;
-To withdraw your consent to the processing of your personal data;
-With any comments or suggestions regarding this privacy policy.
You can write to us at the following address:
Teaching Abroad Direct Limited,
36 Alie Street,
London,
E1 8DA
Alternatively you can send an email to: [email protected]
To get in touch regarding updating your marketing preferences:
You can send an email to [email protected] or you can click on the unsubscribe link in any marketing email we send you.
ANNEX 2 – HOW TO CONTACT YOUR LOCAL SUPERVISORY AUTHORITY
Details of your local supervisory authority:
The Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Phone: 0303 123 1113
Email: [email protected]
GLOSSARY
Candidates: includes applicants for all roles advertised or promoted by TAD including people who have supplied a speculative CV to TAD which is unrelated to any specific job.
Clients: this category covers our customers, clients and others to whom TAD provides services in the course of its business.
General Data Protection Regulation (GDPR): is a legal framework that sets guidelines for the collection and processing of personal information of individuals within the European Union. It has an effective date of 25 May 2018, and any references to it should be construed accordingly to include any national legislation implementing it.
Suppliers: refers to partnerships and companies (including sole traders) and atypical workers such as independent contractors and freelance workers, who provide services to TAD.
Website Users: any individual who accesses our website.
