Keeping your personal data safe
The privacy and protection of your personal data is important to us. Our Privacy Notice describes how we collect and use personal data about you during and after your working relationship with us, in accordance with the data protection legislation (including but not limited to the General Data Protection Regulation 2016/679; the UK Data Protection Act 2018, any amending or implementing regulations or legislation and all other relevant EU and UK data protection legislation).It applies to all clients, candidates, employees, workers, contractors, suppliers, referees and individuals utilising the services of Eden Scott, including website users.
Personal data means any data that identifies or can be used to identify, an individual. This Privacy Notice explains how we collect, use and store your personal data, the purpose for which it is collected, who we share it with and what rights you have in relation to our handling of your personal data.
This Privacy Notice applies to all personal data processed by us.
It will apply to you, if, for example, you request our employment services or any of our other services (including assessment centres); or where you contact us, including via our website (www.edenscott.com); or if we process your personal data for any other purpose.
Who is Eden Scott Ltd
Eden Scott is a Recruitment Business and Employment Agency, delivering recruitment solutions specialising in professional, technical and executive markets across permanent, contract and temporary roles. We work within specialist market areas and have offices in 4 locations, Edinburgh, Glasgow, Aberdeen and Belfast.
Eden Scott is a private limited company (company number SC243605) registered at its office at 26 St Andrew Square, Edinburgh, EH2 1AF.
Under the data protection laws, an organisation that decides how the personal data it collects and holds is used is called a data controller. We are the data controller of all personal data collected and used for the purposes set out in this Privacy Notice and we are responsible for looking after your personal data in line with data protection laws.
This Privacy Notice forms part of our website Terms & Conditions. Please read its terms carefully. If you have any queries or concerns, you may contact us through the means set out in the Contact us section below.
To ensure we comply with our legal obligations we have detailed the following:
- Data processed
- What categories of personal data we collect
- Purpose of the processing
- The legal basis for the processing
- Recipient or categories of recipients of the personal data
- Retention period for data
- Security of personal data
- Special categories of data
- Sharing of data
- Details of transfers outside of the UK and EEA
- Data subjects rights
- Right to withdraw consent at any time[client confidentiality]
- The right to lodge a complaint
- Changes to the notice
- Contact us
What data is processed?
Eden Scott Ltd is a “Data Controller” and “Data Processor”. This means that we are accountable for deciding how we hold and use personal data about you. We are required under data protection legislation to notify you of the data contained in this privacy notice.
We will comply with the data protection law. This says that the personal data we hold about you must be:-
- Used lawfully, fairly and in a transparent way.
- Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
- Relevant to the purposes we have told you about and limited only to those purposes.
- Accurate and kept up to date.
- Kept only as long as necessary for the purposes we have told you about.
- Kept securely and protected against unauthorised or unlawful use and against loss, destruction or damage using appropriate technology and procedures.
We collect data from people who apply for employment with Eden Scott or people who register to use our services via the website, application forms, submitting a C.V., telephone or by contacting the business directly in order that we can provide a recruitment service as outlined above and in accordance with our client’s instructions.
We also process data as part of the Assessment Centre service we offer to clients. Where applicable we will notify candidates beforehand and is in order that we can provide an assessment service in accordance with our client’s instructions. Screening providers may be used as sub-processors to carry out on-line personality assessments.
We will only use your personal data where there are lawful reasons to do so. Most commonly, we will use your personal data in the following circumstances:
- Where we need to perform the contract we have entered into with you.
- Where we need to comply with a legal obligation.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
We do not sell your personal data, nor will we share it with any other person unless it is necessary for a legitimate purpose or where you have provided your consent.
What data do we collect, the purpose, why we collect it, the level of access and retention of my data?
We have outlined how we will collect, store and use personal data about you in the relevant links provided below. These links provide detailed data on what categories we collect, the purpose of the processing, recipients of the personal data, who has access and the retention periods. Generally, we keep personal data for as long as we provide you with our services or to achieve the purposes for which it was collected (unless you have asked us to retain your personal data for longer).
We will keep the personal data in accordance with our internal retention procedures, which are determined in accordance with our statutory obligations and good practice after which time we will securely erase or delete the personal data. These retention periods depend on the nature of the data (for example, we apply different retention periods to our employees data as opposed to data on our applicants), and are subject to change
We may process both personal data and special categories of personal data about the following categories of data subject:
- Permanent candidate data
- Temporary/Interim candidate data
- Client data
- Employee, worker, contractor data
How do you keep my personal data secure?
We have technical and operational security policies and procedures in place to protect the personal data we collect, use and store, against unauthorised or unlawful access or disclosure, improper use, alteration and unlawful or accidental destruction or loss.
Within Eden Scot we limit access to your personal data to those who have a business need to know and they will only process your data on our instructions and under strict conditions of confidentiality. All Eden Scott staff who handle personal data are aware of their responsibilities under this Privacy Notice and are adequately trained and supervised. In addition we have in place internal policies and procedures including the following:
- We encourage a clear desk policy and do not use or retain paper files and records except where this is necessary;
- Our staff are well trained in the requirements of the data protection laws; and
- We use all appropriate encryption and password protection and up to date anti-virus software on our systems.
What is “special categories” of personal data?
"Special categories" of particularly sensitive personal data require higher levels of protection. We need to have further justification for collecting, storing and using this type of personal data (outlined in the data sets above). We may process special categories of personal data in the following circumstances:
- In limited circumstances, with your explicit written consent.
- In order to perform pre-employment background checks, such as financial history, criminal history as requested by our clients
- Less commonly, we may process this type of data where it is needed in relation to legal claims or where it is needed to protect your interests (or someone else's interests) and you are not capable of giving your consent, or where you have already made the data public.
We ensure that we meet all legal requirements in relation to the collection, use and storage of personal data including any additional protections or measures that may be required for any special category personal data.
Who do you share my data with?
We will share your personal data with third parties: where lawfully required to do so; where it is necessary to administer the working relationship with you or, where we have another legitimate interest in doing so.
"Third parties" includes third-party service providers (including contractors and designated agents) and other entities within our group. The following activities are carried out by third-party service providers: Pension Administration, Benefits Provision, Screening providers, IT Services, Legal Services.
All our third-party service providers [and other entities in the group] are required to take appropriate security measures to protect your personal data in line with our policies. We do not allow our third-party service providers to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions. We ensure that we have written agreements in place with all such service providers who process any personal data on our behalf which require that they will comply with obligations that meet the terms of this Privacy Notice.
We may share your personal data with other third parties, for example in the context of the possible sale or restructuring of the business. We may also need to share your personal data with a regulator or to otherwise comply with the law.
Legal obligations – We may be under a duty to disclose or share personal data to comply with any legal obligation or regulatory compliance. This may include where for example we are subject to a court order to disclose your personal data, or if we believe a crime or fraud is being committed, or assets are being used to fund terrorism or bribery, or where we believe that the safety of another person is at risk.
Enforcing our website Terms & Conditions and/or contracts and agreements – To enforce or apply our website Terms & Conditions or our contracts and client agreements, we may pass your personal data to a third party to assist us in this enforcement, for example in relation to the provision of professional advice.
Do you transfer my data outside the United Kingdom?
All personal data we collect from you or about you is stored on our secure servers. Our CRM servers are hosted in Frankfurt.
We may from time to time require to transfer personal data outside the UK but will only do so where either you request it or provide consent. We may also do so where it is necessary to:
- perform our services including when acting in relation to a matter where the laws of a foreign jurisdiction may apply
- use the services of suppliers or providers who are or whose staff may be based overseas for the essential support of our business
- track and record website use, as set out in our Cookies Policy
- comply with any legal requirement
Do you transfer my data outside of the EEA?
In order to perform our services to you, it may be required to transfer your data outside of the EEA the reasons of which are outlined below:-
- Background screening checks – if you have worked out with the EU.
- Overseas recruitment – some of our divisions recruit for organisations out with the EEA.
- Software providers – we as much as possible use software providers who have services in the EEA, however it maybe in some cases we liaise with a provider out with the EEA.
We may transfer personal data outside the EEA in the following circumstances:
- any data that is transferred out with the EEA we will take steps to ensure that the country is compliant with data protection legislation and there are appropriate means in place to safeguard your data.
- you have instructed us to do so or provided consent
- the transfer is made to a company, corporate group or organisation which has signed up to Binding Corporate Rules or
- the transfer is made on the basis of standard contractual clauses approved by the European Commission.
Other than in the limited circumstances set out above we will not transfer or store personal data outside the UK or European Economic Area (EEA).
What are my rights?
Changes in personal data
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data change by contacting us to allow our records to be updated.
Your rights in connection with personal data
Under certain circumstances, by law you have the right to make the following requests:
Request access to your personal data (commonly known as a "data subject access request").
This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it including the right to be allowed access to that data and to be provided with a copy of that data along with the right to obtain the following data:
- the purpose of the processing
- the categories of personal data
- the recipients to whom personal data has been disclosed or which will be disclosed
- the period for which the personal data will be retained
- the right to lodge a complaint with the Information Commissioner’s Office
- the source of the data if not collected direct from you, and
- the existence of any automated decision making.
Request correction of the personal data that we hold about you.
This enables you to have any incomplete or inaccurate data we hold about you corrected.
Request erasure of your personal data.
This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it, and to have confirmation of deletion. You also have the right to ask us to delete or remove your personal data where you have exercised your right to object to processing (see below).
Object to processing of your personal data
where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground unless, we can demonstrate compelling legitimate grounds for the processing which override your individual interests or for the establishment, exercise or defence of legal claims . You also have the right to object where we are processing your personal data for direct marketing purposes.
Request the restriction of processing of your personal data.
This enables you to ask us to suspend the processing of personal data about you, for example if you want us to establish its accuracy or the reason for processing it.
Request the transfer of your personal data.
This enables you to move, copy or transfer your personal data to another party where we are processing your personal data either with your consent or for the purpose of performing a contract.
For the avoidance of doubt, we do not use automated decision making in the processing of personal data.
How do I exercise my rights?
If you want to review, verify, correct or request erasure of your personal data, object to the processing of your personal data, or request that we transfer an electronic copy of your personal data to another party, please contact Lindsey Boxall, Director – firstname.lastname@example.org, 26 St Andrew Square, Edinburgh, EH2 1AF in writing.
All requests will be considered without undue delay and within one month of receipt as far as possible .No fee is usually required, however, we may charge a reasonable fee if your request for access is requires extreme or unique measures. Please note that we may in limited circumstances refuse a request, where we have compelling legitimate grounds or where prevented by obligations of confidentiality or legal privilege.
What if I wish to withdraw my consent?
In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal data for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact Lindsey Boxall, Director. Once we have received notification that you have withdrawn your consent, we will no longer process your data for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.
How do I remove my consent to electronic marketing?
If you’ve given us your consent, we may use the data we’ve collected about you to send you marketing offers and news about our services using various channels such as mail, phone, email and SMS. We won’t sell your personal data to other organisations outside of Eden Scott for marketing purpose.
If you prefer not to receive any future marketing communications you can remove your consent at any time by writing to or sending an email to our Director, Lindsey Boxall.
Nothing in this notice affects our professional obligation to keep the affairs of our clients confidential.
Changes to the Privacy Notice
This Privacy Notice was last updated on 10 June 2019. It is published on our website https://www.edenscott.com. Your continued use of our website indicates your consent to any changes we make to this notice but please continue to visit this page to view any updates.
How do I make a complaint?
You have the right to make a complaint about anything regarding the processing, storage, retention of your data. We would hope to resolve any complaint internally and if you would like to lodge a complaint with us in the first instance please contact Lindsey Boxall, email@example.com.
However, you also have the right to lodge a complaint at any time to the Information Commissioner (ICO) in respect of our processing of your personal data. Information can be found at www.ico.org.uk.
If you have any queries regarding this notice please email firstname.lastname@example.org or write to Lindsey Boxall, Eden Scott, 26 St Andrew Square, Edinburgh, EH2 1AF