The Company is a recruitment business which provides work-finding services to its clients
and work-seekers. The company must process personal data so that it can provide these
services – in doing so, the Company acts as a data controller for the purpose of data
protection law. This means that we are responsible for deciding how we hold and use your
personal data.
We are required by data protection law to give you the information in this privacy notice. This
privacy notice applies from 25th May 2018 when the General Data Protection Processing
Regulations come into force. It does not give you any contractual rights and we may update
this privacy notice at any time.

What is personal data?
Any information relating to a living individual who can be identified (directly or indirectly) by
reference to an identifier (e.g., name, NI number, email address, physical features). It can be
factual (e.g., date of birth), an opinion about an individual’s actions or behaviour, or
information that may otherwise impact the individual in a personal or business capacity.
Data protection law divides personal data into two categories: ordinary personal data and
special category data. Any personal data that reveals the racial or ethnic origin, political opinions,
religious or philosophical beliefs, trade union membership, physical or mental health
conditions, sexual life or sexual orientation, or biometric or genetic data that is used to identify
an individual is known as special category data. The rest is ordinary personal data.
You may give your personal details to the Company directly, such as on an application or
registration form or via our website, or we may collect them from another source such as a
jobs board. The Company must have a legal basis for processing your personal data.

Purpose of processing and legal basis
The Company will collect your personal data (which may include sensitive personal data) and
will process your personal data for the purposes of providing you with work-finding services.
This includes contacting you about job opportunities, assessing your suitability for those
opportunities, updating our databases, putting you forward for job opportunities, arranging
payments to you and developing and managing our services and relationship with you and
our clients.
In some cases, we may be required to use your data for the purpose of investigating, reporting
and detecting crime and also to comply with laws that apply to us. We may also use your
information during the course of internal audits to demonstrate our compliance with certain
industry standards.
The legal bases we rely upon to offer these services to you are:
Where we have a legitimate interest
To comply with a legal obligation that we have
To fulfil a contractual obligation that we have with you or our clients
Legitimate Interest – This is where the Company has a legitimate reason to process your data
provided it is reasonable and does not go against what you would reasonably expect from us.
Where the Company has relied on a legitimate interest to process your personal data our
legitimate interests include the following:
Managing our database and keeping work-seeker records up to date;
Providing work-finding services to you, including sending information to our clients;
Contacting you with information about similar services we can offer you;
Establishing compliance with contractual obligations with Clients or suppliers;

Exercising or defending any legal claims

Statutory/contractual requirement – Your personal data is required by law and/or a contractual
requirement (e.g., our client may require this personal data), and/or a requirement necessary
to enter into a contract. You are obliged to provide personal data. If you fail to do so, we
will not be able to provide work-finding services to you.

Recipient/s of data
We share your personal data and/or sensitive personal data that is relevant, where
appropriate, with the following recipients:

Home Office (to enable us to verify your right to work in the UK)
Parties who process data on our behalf, which may include:
Umbrella companies
IT Support
Storage service providers, including cloud providers
Any other third parties who carry out audits to ensure we run our business correctly or
in line with industry standards
Legal/professional advisers (to obtain legal or other professional advice about matters
relating to you or in the course of dealing with legal disputes)
Clients (Contractual obligation)
Insurers

Overseas Transfers

 The Company may transfer only the information you provide to us to countries outside the

European Economic Area (EEA) for the purpose of providing you with work-finding services.
We will take steps as far as is reasonably practicable to ensure adequate safeguards are in
place to ensure the security of your information. The EEA comprises the EU member states
plus Norway, Iceland, and Liechtenstein.

Data retention

The Company will retain your personal data only for as long as is necessary. Different laws
require us to keep different data for different periods of time. The Conduct of Employment
Agencies & Employment Businesses Regulations 2003, require us to keep work-seeker
records for at least one year from (a) the date of their creation or (b) after the date on which
we last provide you with work-finding services.
We must also keep your payroll records, holiday pay, sick pay, and pensions auto-enrolment
records for as long as is legally required by HMRC and associated national minimum wage,
social security and tax legislation.

References
If you give us details of referees, we require you to inform them what personal data of theirs
you are giving to us. You must also give them our contact details and let them know that they
should contact us if they have any queries about how we will use their personal data.
Your rights
Please be aware that you have the following data protection rights:
The right to be informed about the personal data the Company processes on you;
The right of access to the personal data the Company processes on you;
The right to rectification of your personal data;

The right to the erasure of your personal data in certain circumstances;

The right to restrict processing of your personal data;
The right to data portability in certain circumstances;
The right to object to the processing of your personal data that was based on a public or
legitimate interest;
The right not to be subjected to automated decision making and profiling; and
The right to withdraw consent at any time.

Complaints or queries
If you wish to complain about this privacy notice or any of the procedures set out in it, please
contact the Data Protection Officer at admin@realcomfortrecruitment.com. You also have the
right to raise concerns with the Information Commissioner’s Office on 0303 123 1113 or at
https://io.org.uk/concerns if you believe that your data protection rights have not been
adhered to.

To view any of our company policies please email admin@realcomfortrecruitment.com

Issue Date: 31/10/2021 V.1.0