Privacy Notice
GTC Recruitment know how vital it is to respect and protect your privacy.
This notice sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us.
GDPR
The General Data Protection Regulation (GDPR) (Regulation (EU) 2016/679) is a new regulation which replaces the Data Protection Regulation (Directive 95/46/EC) The Regulation aims to harmonise data protection legislation across EU member states, enhancing privacy rights for individuals and providing a strict framework within which commercial organisations can legally operate.
Even though the UK has expressed its intention to leave the EU in March 2019, the GDPR will be applicable in the UK from 25th May 2018. The Government intends for the GDPR to continue in UK law post Brexit and has also introduced a Data Protection Bill to replace the current Data Protection Act in due course.
Your new rights under the GDPR are set out in this notice but will only apply once the GDPR becomes law on 25th May 2018.
Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.
For the purposes of data protection legislation in force from time to time the data controller is GTC Recruitment.
What GTC do
We are a recruitment agency and recruitment business as defined in the Employment Agencies and Employment Businesses Regulations 2003 (our business). For some clients, we also act as a managed service provider. We collect the personal data of the following types of people to allow us to undertake our business;
-Prospective and placed candidates for permanent or temporary roles;
-Client contacts;
Supplier contacts to support our services;
-Employees, consultants, temporary workers;
-Website Users;
-Referees and Emergency contacts.
We collect information about you to carry out our core business and ancillary activities.
This is information about you that you give us by filling in forms on our site www.gtcrecruitment.co.uk or by corresponding with us by phone, e-mail or otherwise.
It includes information you provide when you engage with us for recruitment services.
Your information
The information we collect may include your name, email address(es), telephone number, CV’s, identification and right to work documents, educational records, work history, employment and references.
In general, we will not ask you about sensitive personal data but there may be times that it is necessary for information to be disclosed to us and for us to share that with potential employers. We will only share the information where you have provided your explicit consent.
The core service we offer to our candidates and clients is the introduction of candidates to our clients for the purpose of temporary or permanent engagement. However, our service expands to supporting individuals throughout their career and to supporting businesses’ resourcing needs and strategies.
Our legal basis for the processing of personal data is our legitimate business interests, described in more detail below, although we will also rely on contract, legal obligation and consent for specific uses of data.
We will rely on contract if we are negotiating or have entered into a placement agreement with you or your organisation or any other contract to provide services to you or receive services from you or your organisation.
We will rely on legal obligation if we are legally requires to hold information on to you to fulfil our legal obligations.
We will in some circumstances rely on consent for particular uses of your data and you will be asked for your express consent, if legally required.
Our legitimate interests in collecting and retaining your personal data is described below:
As a recruitment business and recruitment agency we introduce candidates to clients for permanent employment, temporary worker placements or independent professional contracts. The exchange of personal data of our candidates and our client contacts is a fundamental, essential part of this process.
In order to support our candidates’ career aspirations and our clients’ resourcing needs we require a database of candidate and client personal data containing historical information as well as current resourcing requirements.
To maintain, expand and develop our business we need to record the personal data of prospective candidates and client contacts.
Disclosure of your information inside and outside of the EEA
We will share your personal information with:
-clients for the purpose of introducing candidates to them ;
-clients for the purpose of arranging interviews and engagements;
-clients, suppliers and sub-contractors for the performance and compliance obligations of any contract we enter into with them or you;
-subcontractors including digital marketing specialists and payment providers;
-analytics and search engine providers that assist us in the improvement and optimisation of our site;
-credit reference agencies, our insurance broker, compliance partners and other sub-contractors for the purpose of assessing your suitability for a role where this is a condition of us entering into a contract with you.
We will disclose your personal information to third parties:
-In the event that we sell or buy any business or assets, in which case we will disclose your personal data to the prospective seller or buyer of such business or assets.
-If GTC or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
-If we are under a duty to disclose or share your personal data in order to comply with any legal obligation or to protect the rights, property, or safety of GTC, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
The lawful basis for the third party processing will include:
-Their own legitimate business interests in processing your personal data, in most cases to fulfil their internal resourcing needs;
-satisfaction of their contractual obligations to us as our data processor;
-for the purpose of a contract in place or in contemplation;
-to fulfil their legal obligations.
Where we store and process your personal data
The data that we collect from you may/will be transferred to, and stored at, a destination outside the European Economic Area (”EEA”). It may be transferred to third parties outside of the EEA for the purpose of our recruitment services. It may/will also be processed by staff operating outside the EEA who work for us or for one of our suppliers. This includes staff engaged in, among other things, our recruitment services and the provision of support services. By submitting your personal data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy notice. In the event that we do need to make transfers to countries outside the EEA, we will ensure the appropriate safeguards are in place.
Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
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 your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
Retention of your data
We understand our legal duty to retain accurate data and only retain personal data for as long as we need it for our legitimate business interests and that you are happy for us to do so. Accordingly, we have a data retention notice.
We do the following to try to ensure our data is accurate:
Prior to making an introduction we check that we have accurate information about you
We keep in touch with you so you can let us know of changes to your personal data.
We may archive part or all of your personal data or retain it on our financial systems only, deleting all or part of it from our main Customer Relationship Management (CRM) system. We may anonymise parts of your data, particularly following a request for suppression or deletion of your data.
For your information, anonymised data is created by taking identifying fields within a database and replacing them with artificial identifiers.
Retention notice
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 six years (or for such longer period as we believe in good faith that the law or relevant regulators require us to preserve your data).
By “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. Or if you communicate with us about potential roles, either by verbal or written communication or click through from any of our recruitment related communications.
Please note that we may need to continue to process your personal information in certain circumstances for specified periods up to seven years. This includes, but is not limited to, ensuring you have the right to work in the UK; allowing us to comply with HMRC reporting requirements regarding payroll information; or to establish, exercise or defend a legal claim.
Your rights
For the purpose of providing you our full recruitment services we may occasionally send email communication such as specific job opportunities or relevant industry recruitment trends. You can manage your email communication preferences by contacting a GTC consultant, completing relevant boxes on our registration form, or updating your preferences on our website.
To clarify, contacting you about specific job opportunities or industry recruitment trends is not marketing because we are not advertising or marketing our services.
Our site may, from time to time, contain links to and from the websites of our partner suppliers. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
The GDPR provides you with the following rights. To:
-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.
-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 certain formats, if practicable.
-Make a complaint to a supervisory body which in the United Kingdom is the Information Commissioner’s Office. The ICO can be contacted through this link: https://ico.org.uk/concerns/
Access to information
The Data Protection Act 1998 and the GDPR give you the right to access information held about you. We also encourage you to contact us to ensure your data is accurate and complete.
Your right of access can be exercised in accordance with the GDPR.
A subject access request should be submitted to: [email protected]
Changes to our privacy notice
Any changes we make to our privacy notice in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our privacy notice.
Contact
Questions, comments and requests regarding this privacy notice are welcomed and should be addressed to:
Data Protection who can be contacted at [email protected]
Standard Terms & Conditions for Temporary Workers
Temporary Workers are engaged by GTC, under a contract for services, the terms of which are set out below and which apply to each and every assignment.
Assignment means work performed by the Temporary Worker for the client for a period of time during which the Temporary Worker is supplied by GTC to work temporarily for and under the supervision and direction of the Client;
AWR means the Agency Workers Regulations 2010;
Calendar Week means any period of seven days starting on a Sunday and ending on the following Saturday which counts towards the Qualifying Period;
Client means the person, firm or corporate body together with any subsidiary or associated person, firm or corporate body (as the case may be) to whom the Temporary Worker is supplied or introduced;
Pay means any sums payable to a worker in connection with the worker’s Assignment including, basic gross salary, any fee, bonus attributable to individual performance, commission, paid holiday entitlement including statutory paid holiday and any additional contractual paid holiday entitlement, vouchers with a cash value, overtime, dangerous of difficult work or other shift premium and any other emolument referable to the Assignment but excluding any payments within Regulation 6 (3) of the AWR;
Qualifying Period means 12 continuous (as defined by Regulation 7 of the AWR) Calendar Weeks during the whole or part of which the Temporary Worker is supplied to work for and under the direction and control of the Client in the same role by GTC or other temporary work agency (as defined by Regulation 4 of the AWR);
Temporary Worker means the worker supplied by GTC to provide services to the Client under the direct control, supervision and direction of the Client;
1. All and any business undertaken by GTC is transacted subject to these terms and conditions. GTC is operating in the capacity of an employment business.
2. GTC will endeavour to obtain suitable Assignments for the Temporary Worker with Clients requiring such a Temporary Worker. The types of work and expected rates of pay to be sought on behalf of the Temporary Worker are outlined in the candidate registration schedule, provided to the Candidate on first registering with GTC. Final terms and conditions will be issued at the commencement of an assignment, detailing the actual rate of pay and the type of work to be undertaken.
3. GTC reserves the right to offer any Assignment to such Temporary Worker as it may elect where that Assignment is suitable for several Temporary Workers. The Temporary Worker is under no obligation to accept such an offer but, if accepted, he/she owes the normal common law duties of a worker as far as they are reasonably applicable.
4. It is a condition of this Agreement that the Temporary Worker shall, before the commencement of any assignment, have provided GTC with:
(i) details of any work since 1 October 2011 the Temporary Worker has performed for the Client in the same or a similar role to the Assignment via any third party which may count towards the Qualifying Period to enable GTC to comply with its obligations under the AWR;
(ii) satisfactory evidence of the Temporary Worker’s identity (which shall include, but not be limited to, a certified copy of the Temporary Worker’s passport or birth certificate and National Insurance documentation);
(iii) confirmation of the Temporary Worker’s right to work in the UK or other location as specified by the Client. For the avoidance of doubt, GTC shall be entitled to terminate, cancel or withdraw any assignment, without any liability to the Temporary Worker in the event that the Temporary Worker’s right to work is cancelled or expires for any reason or in the event that the Temporary Worker is not able to satisfy GTC requirements under this clause .
If, in respect of any assignment, the Temporary Worker is required by law, any professional body or by the Client to hold any qualifications and/or authorisations, the Temporary Worker shall provide GTC with: (a) up to date copies of such qualifications or authorisations; and (b) the names of two referees (who are not relatives of the Temporary Worker) who the Temporary Worker agrees that GTC may approach for the purpose of obtaining references about the Temporary Worker. The Temporary Worker also consents to the disclosure of such qualifications, authorisations and/or references by GTC to the Client.
6. (a) Concept shall pay to the Temporary Worker wages calculated at an hourly/daily/weekly/monthly rate, to be determined prior to the commencement of the assignment, subject to deductions for the purpose of National Insurance, PAYE, or any other purpose for which GTC is required by law to make deductions. The standard payment interval will be weekly or as otherwise agreed prior to the Assignment commencing. The Temporary Worker shall be required to provide time sheets duly authorised by the Client, as directed by GTC, agreeing the hours worked by the Temporary Worker on a weekly basis.
(b) The Temporary Worker shall promptly comply with any other rule or request (either from the Client or GTC) to provide information and/or documentation in respect of the hours worked by the Temporary Worker. Failure by the Temporary Worker to provide any evidence of hours worked may delay payment for such hours. GTC will not withhold payment of the Temporary Worker’s wages through reason of non-receipt of payments from the Client.
(c) The Temporary Worker becomes entitled under the AWR to Pay after the end of the Qualifying Period. Pay is calculated by GTC in consultation with the Client prior to the start of each Assignment. For the avoidance of doubt Pay as defined in these terms will be the remuneration the Temporary Worker would have received had the Temporary Worker been directly engaged by the Client at the start of the Qualifying Period.
(d) The Temporary Worker is not obliged to work any particular number of hours per day or week. However if the Client requests the Temporary Worker to perform any work outside the normal working hours of the Client’s business it will be entirely at the Temporary Worker’s discretion whether s/he performs such work. If the Temporary Worker agrees to perform work outside the Client’s normal working hours the Temporary Worker will be paid for those hours at the rate s/he would have received had the Temporary Worker been directly engaged by the Client at the start of the Qualifying Period.
7. (a) The holiday year runs from 1 January to 31 December each year. The Temporary Worker will have a statutory annual entitlement to 5.6 weeks paid holiday per year. If the statutory paid holiday entitlement is subsequently decreased or increased then entitlement to leave under this clause will be decreased or increased accordingly for any period in which work is carried out. The Temporary Worker’s holiday pay for the 4 week statutory minimum holiday entitlement under the Working Time Directive will be calculated on their basic pay rate together with any additional payment intrinsically linked to tasks the Temporary Worker is required to carry out on Assignment.
(b) Entitlement to payment for holiday accrues in proportion to the amount of time worked continuously by the Temporary Worker on Assignment during the leave year. Payment is calculated on the basis of rates paid during the Client’s normal working hours. The Temporary Worker is paid for holiday entitlement either at the time the holiday is taken by the Temporary Worker during the course of an Assignment or on termination of an Assignment. Any bank or statutory holidays taken as paid holiday will be included within this entitlement;
(c) In addition to the statutory minimum paid holiday entitlement under the Working Time Regulations 1998, the Temporary Worker is entitled under AWR to any additional contractual paid holiday applicable to the role at the end of the Qualifying Period. Any additional contractual entitlement will be accounted for in the Temporary Worker’s Pay in accordance with the provisions of clause 6(c).
(d) Any holiday not taken by the end of the holiday year in which the entitlement arises is forfeited. It may not be carried forward and GTC will not make any payment in lieu;
(e) Where a Temporary Worker wishes to take holiday during the course of an Assignment he/she should notify GTC of the intended holiday dates giving notice of at least twice the length of the period of leave he/she wishes to take. In certain circumstances GTC may give written counter-notice to the Temporary Worker to postpone or reduce the amount of leave that the Temporary Worker wishes to take giving the Temporary Worker at least the same length of notice as the period of leave that it wishes to postpone or reduce it by.
8. The Temporary Worker shall at all times when services are due to a Client comply with the following conditions:
(a) Not to engage in any conduct detrimental to the interests of the Client;
(b) To be present during the times or for the total number of hours during each day and/or week as may be agreed with the Client. The Temporary Worker agrees that in accordance with Regulation 5 of the Working Time Regulations 1998, the provisions contained in Regulation 4, stating that working time shall not exceed an average of 48 hours for each seven day period (running Sunday to Saturday) should not apply. The Temporary Worker may withdraw from this option on giving 14 days written notice. If the Temporary Worker provides services through a limited company, these terms constitute consent for the purpose of Regulation 5 unless consent is withdrawn on notice and in writing to both the limited company and to GTC.
(c) To take all reasonable steps to safeguard his/her own safety and the safety of any other person who may be affected by his/her actions at work;
(d) To comply with any rules or obligations relating to discipline and/or health and safety in force from time to time at the premises where services are performed to the extent that they are reasonably applicable;
(e) To comply with all reasonable instructions and requests regarding the scope of the agreed services made by the Client;
(f) Not to at any time during or after any assignment divulge or make known to any person or any competitor of the Client, nor use for his/her own or any other person’s benefit any confidential information (which shall remain the property of the Client) in relation to the trade secrets, operations and business affairs of the Client. Further to immediately surrender all documents, samples, tools and equipment provided by the Client on the cessation of the assignment.
9. All intellectual property conceived or made by the Temporary Worker (either alone or with others) in the course of any Assignment shall belong to the Client and the Temporary Worker agrees to assign all his/her interest in any such intellectual property to the Client or its nominee. If requested to do so, the Temporary Worker shall execute any documentation which the Client shall deem necessary to give effect to this provision.
10. The Temporary Worker shall immediately inform GTC should he/she become aware of any reason or circumstances under which it would be detrimental to the interests of GTC, the Client or the Temporary Worker for the Assignment to continue.
11. GTC shall be under no obligation to provide work for the Temporary Worker and this Agreement creates no obligation on GTC to provide the Temporary Worker with a specified number of hours work in any day or any week.
12. Either GTC or the Client may terminate an Assignment without notice or liability at any time and for any reason and instruct the Temporary Worker to leave the Assignment accordingly. Equally the Temporary Worker may terminate an Assignment at any time without prior notice or liability.
13. The Temporary Worker should not engage in any conduct, which is detrimental to the interests of GTC, would negatively affect GTC’s relationship with the Client or is likely to bring GTC into disrepute.
14. The Temporary Worker having any complaint in connection with the temporary work, or the conduct or relations with GTC or the Client or any employee of GTC or the Client shall have the right to present a complaint in writing to a Director or Senior Manager of GTC.
15. The Temporary Worker and GTC acknowledge and agree that this Agreement constitutes a contract for services and shall not create an employer/employee relationship between GTC and the Temporary Worker.
16. GTC does not accept any responsibility and shall not be liable for any loss or damage suffered by the Temporary Worker as a result of this Assignment being terminated by either GTC or the Client.
17. Unless agreed otherwise in writing the Temporary Worker shall be paid on a PAYE basis. For the avoidance of doubt, the Temporary Worker shall not be treated as an employee of a limited company until all the required documentation has been provided by the Temporary Worker and/or the limited company to the satisfaction of GTC.
Standard Conditions and Guidance for Permanent Candidates
1. All and any business undertaken by GTC is transacted subject to the terms and conditions hereinafter set out. GTC is acting in the capacity of an Employment Agency.
2. Upon provision by the work-seeker (“Candidate”) of a full and accurate Curriculum Vitae, GTC shall, at its sole discretion, search for suitable employment positions on behalf of the Candidate. The type of employment sought for the Candidate will be as detailed on the Candidate Registration Schedule.
3. Before any work finding services are provided the Candidate shall provide GTC with satisfactory evidence of the Candidate’s identity which shall include, but not be limited to, a certified copy of the Candidate’s passport or birth certificate.
If, in respect of any prospective employment, the Candidate is required by law, any professional body or by the hirer (“Client”) to hold or have any experience, training qualifications and/or authorisations, the Candidate shall provide GTC with:
(a) up to date copies of such qualifications and/or authorisations; and
(b) the names of two referees (who are not relatives of the Candidate) who the Candidate agrees that GTC may approach at any time for the purpose of obtaining references about the Candidate.
4. The Candidate consents to the disclosure of all relevant information (which is reasonably required to progress any application) including but not limited to copies of qualifications, authorisations and/or references by GTC to the Client.
5. The Candidate shall immediately inform GTC should there be any reason or circumstances of which he/she is aware under which it would be detrimental to the interests of GTC, the Client or the Candidate for the Candidate to take up a particular position with the Client.
6. GTC shall be under no obligation to find employment for the Candidate.
7. The Candidate should not engage in any conduct which is detrimental to the interests of GTC, would negatively affect GTC’s relationship with the Client or is likely to bring GTC into disrepute.
8. The Candidate having any complaint in connection with the work finding services shall have the right to present a complaint in writing to a Senior Manager or Director of GTC.
9. An offer of employment is not made until written details are received from the Client. GTC does not accept any responsibility and shall not be liable for any loss suffered by the Candidate by reason of the Candidate’s decision to resign from his/her current employment or engagement before or after receipt of the client’s written offer. Furthermore, GTC does not accept any responsibility and shall not be liable for any loss suffered by the Candidate by reason of the Client withdrawing the offer of employment at any time for any reason.
10. An offer of employment made by the Client may be subject to the Client obtaining satisfactory references or background checks on the Candidate.
Modern Slavery Safeguarding
GTC has taken steps to ensure that slavery and human trafficking is not taking place in any part of our business.
What is modern slavery?
Modern slavery is an international crime, affecting millions of people around the world – a growing global issue that transcends age, gender and ethnicities. Sadly, vulnerable people from overseas as well as across the UK, are forced to work illegally against their will across many different sectors from agriculture, construction, hospitality, retail, manufacturing, and more.
Our policies in relation to slavery and human trafficking
GTC has established a zero-tolerance position on violations to the UK’s anti-human trafficking and anti-modern slavery laws.
We seek to treat everyone fairly and consistently, creating a workplace and business environment that is open, transparent and trusted.
Our employment policies protect our people from unfair treatment and promote a fair and inclusive workplace.
We utilise robust recruitment processes in line with relevant employment laws.
Modern Slavery & Human Trafficking Statement
Introduction
This Modern Slavery and Human Trafficking Statement is a response to Section 54 (1) Part 6 of the Modern Slavery Act 2015 and relates to actions and activities for the financial year ending 31st March 2024.
GTC Recruitment Limited (‘the Company’, ‘we’, ‘us’ or ‘our’) is committed to preventing slavery and human trafficking violations in its own operations, supply chain and its products. We have a zero-tolerance towards slavery and require our supply chain to comply with our values.
Organisational Structure
GTC Recruitment Limited is based and has business operations in the United Kingdom. We operate in the recruitment sector. The nature of our supply chain is as follows:
We work with a number of key customers who we source and provide recruitment services across several business sectors including IT, Sales, Engineering, Financial Services and Admin/Clerical sectors.
For more information about the Company, please visit our website: https://gtcrecruitment.co.uk
Policies
We operate a number of internal policies to ensure that we are conducting business in an ethical and transparent manner. These include the following:
• Recruitment and selection policy- To comply with employment legislation and the Equality Act 2010, it is important that all staff involved in recruitment, selection and redundancy situations apply consistent and impartial criteria which are free from discrimination at all stages.
• Whistleblowing policy – This seeks to prevent modern day slavery by ensuring children are not neglected in any way and are protected and mechanisms are in place to report any form of abuse.
• Staff code of conduct – GTC Recruitment Limited’s code makes it clear to employees the actions and behaviour expected of them when representing the company. GTC Recruitment Limited strives to maintain the highest standards of employee conduct and ethical behaviour when operating and managing its supply chain.
Due Diligence
As part of our efforts to monitor and reduce the risk of slavery and human trafficking occurring in our supply chain, we have adopted the following due diligence procedures:
• Internal supplier audits
Our due diligence procedures aim to:
• Identify and action potential risks in our business and supply chains.
• Monitor potential risks in our business and supply chains
• Reduce the risk of slavery and human trafficking occurring in our business and supply chains.
• Provide protection for whistleblowers.
Risk and Compliance
The Company have evaluated the nature and extent of its exposure to the risk of slavery and human trafficking occurring in its UK supply chain through:
• Reviewing on a regular basis all aspects of the supply chain based on supply chain mapping.
We do not tolerate slavery and human trafficking within our supply chains. Where there is evidence of failure to comply with our policies and procedures by any of our suppliers, we will require that supplier to remedy the non-compliance.
Effectiveness
The Company uses Key Performance Indicators (KPIs) to measure its effectiveness and ensure that slavery and human trafficking is not taking place in its business and supply chains, and we train our staff about modern slavery issues within the Company.
Training Staff
The Company uses the Government’s ‘Modern Slavery Awareness’ booklet’ to advise on how to identify signs of slavery, human trafficking and the steps the be taken is slavery or human trafficking is suspected.
The statement was approved by the board of Directors.
GTC Recruitment Limited
16/04/2024