Radley James is a recruitment company specialising in Finance and Technology in the UK, USA, APAC, and Europe.
This policy covers all Radley James group entities including Radley James Holdings, Radley James Ltd, Radley James Inc, Radley James Europe Ltd and Radley James Pte Ltd.
This Policy is used to inform website visitors regarding how we collect, use, and disclose any personal information we receive should you decide you want to use the services we provide,
If you decide you would like to use our services, then you agree to the collection and use of information in relation with this policy. The Personal Information that we collect are used for providing and improving the service we offer. We will not use or share your information with anyone except those mentioned in this Privacy Policy.
The terms used in this Privacy Policy have the same meanings as in our Terms and Conditions, which is accessible at (www.radleyjames.com), unless otherwise defined in this Privacy Policy.
All Radley James employees responsible for processing Personal Data are aware of the conditions for processing, which are, Consent, Legitimate Interest, Contract, Legal Obligation, Vital Interest or Public Task.
What are the lawful bases for processing?
As set out in Article 6 of the UK/EU GDPR, at least one of the following must apply when processing personal data:
- Consent – the individual has given clear consent to process their personal data for a specific purpose.
- Contract – the processing is necessary for a contract with the individual
- Legal obligation – the processing is necessary to comply with the law (not including contractual obligations).
- Vital Interests – the processing is necessary to protect someones life.
- Public Task – the processing is necessary to perform a task in the public interest or for official functions, and the task or function has a clear basis in law.
- Legitimate interests – the processing is necessary for our legitimate interests or the legitimate interests of a third party, unless these is a good reason to protect the individual’s personal data which overrides those legitimate interests.
Radley James will ensure that any personal data collected serves it’s specific requirement and is done so following the appropriate lawful basis.
When is processing ‘necessary’?
Radley James will only collect and process personal data when it will be used as a way of achieving a specific purpose, i.e., collecting relevant information from an individual for the needs of a client when put forward for a specific role.
How is personal data collected?
Personal Information is collected about you from Radley James when you visit our website, use our services, or provide it in another way, i.e., via LinkedIn, email, etc.
What Personal Data do Radley James collect?
Work Finding Services (legitimate interest)
- Contact Information – Name, date of birth, e-mail, telephone number, address, emergency contacts you provide.
- Career Information – this may include your CV and employment history including company name and length of service
- References – any reference information given whether through work experience, education or personal will be confirmed by you. Radley James will not contact any referee until we have received your consent it is ok to do so.
- Career Planning Information – this may include salary expectation, career interests, desired work location, whether you would like to work Hybrid, etc.
- Qualifications – any educational or specialist certificates
- Work-related Skills deemed relevant for the role
If you are employed or engaged by Radley James (contract and legal obligation)
- Right to Work and Identification documents
- Proof of address
- Contracts
- Next of Kin and emergency contact details
- Healthcare and pension records (if applicable)
- Bank and National Insurance Details
- Training Records
- HR, Holiday, and Sickness Records (if applicable)
- Record of Payments and Invoices
- Record of PAYE and Salary
- Information we obtain from third parties:
- Background check providers
- References
- Third party websites and services, i.e., LinkedIn
Sensitive Personal Data
You may be asked for personal data that can be deemed in some countries as sensitive, this may include information regarding race or ethnicity, religious beliefs, physical or mental health conditions and any unrelated legal actions.
Any sensitive personal data that is required will be processed in accordance with applicable data protection laws.
International transfers of Personal Data
The UK GDPR imposes restrictions on the transfer of personal data outside the EEA, to non-EEA countries or international organisations, to ensure that the level of protection of individuals granted by the GDPR remains the same.
Radley James Ltd will only transfer outside of the EEA in compliance with the conditions for such transfers laid down in Chapter V of the GDPR if;
specific safeguards are in place to make the transfer lawful under EU GDPR
Safeguards for Restricted transfers
The UK GDPR contains rules on the transfer of personal data to receivers located outside the UK, which are separate controllers or processors and legally distinct from you. These rules apply to all transfers, no matter the size of transfer or how often you carry them out.
We refer to a transfer of personal data to these receivers located outside the UK as a ‘restricted transfer’.
- Adequacy –where a similar level of data protection standards is in place with the receiving country as per the sender country. (An adequacy decision therefore allows personal data to be transferred without any additional safeguards.
- EU-US Privacy Framework – this is for the transfer of data between the EU and US. Personal data can flow freely to organisations in the US who are certified and meet the principles of the DPF.
- Transfers from the UK – personal data can be transferred between the UK and EEA and any country awarded adequacy by the EC.
- Radley James will follow any changes made by the UK government regarding personal data transferred from the UK to countries deemed adequate.
Purposes for Collection and Use of your Personal data
Radley James primary purpose for collecting and processing personal data is to perform statutory tasks related to the services we provide, e.g., to provide relevant candidate details to a client.
What are your rights regarding personal data and why is it important?
All individuals will be provided with clear and concise information about what will be done with your personal data.
Under data protection laws, you have certain rights regarding any personal data Radley James holds about you, this includes the following:
- Right to be informed of what we will do with your data
- Right of access to your personal data – you have the right to request certain information Radley James holds about you. You have the right to request access to copies of this information. Please note you are entitled to request one copy of all personal data at no cost, however any further copies requested can incur a reasonable administrative fee). For further information on this, please contact datacontroller@radleyjames.com.
- Right to rectify and inaccurate Personal Data
- Right to erasure unless there are overriding legitimate grounds to not do so
- Right to restrict processing
- Right to data portability
- Right to object – you have the right to object to our use of your personal data including where it may be used for marketing purposes or for our legitimate interests.
Who will have access to the data?
The recipients of personal data are limited to Radley James brands as detailed above. We may also share data with a third parties, for example, end clients. Your data will not be shared with any third parties outside of the EEA unless appropriate safeguards are in place.
How long will the data be kept for?
Radley James will retain Personal Data for no longer than is necessary for the purpose for which it is processed.
We must keep certain financial records for 6 years from the end of the last company financial year they relate to, or longer if: they show a transaction that covers more than one of the company’s accounting periods. HMRC can carry out financial audits at any time and we have a legal obligation to be able to produce the documentation requested. After 6 years this information can be deleted.
Radley James must keep Right To Work documents for 2 years after a worker or employee ceases working either as an employee or a contractor.
Radley James are required to deactivate personal data, whichever is the earlier of, the relevant retention period, or when in receipt of a data subjects request to do so, unless there are overriding legitimate grounds to not do so.
For more information regarding this, please contact the Radley James Data Protection Officer (datacontroller@radleyjames.com)
Who controls my personal data?
The Data Controller is Radley James Limited (UK Company Number 7039305) 57a Broadway, Leigh-On-Sea, England, SS9 1PE
The Data Protection Officer representative is the HR team at Radley James.
datacontroller@radleyjames.com
Radley James Limited is registered as a Data Controller with the Information Commissioner’s Office Certificate Number Z3000175
You can also make a complaint to the Information Commissioner, who is an independent regulator.
Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF. Telephone: 0303 123 1113. Textphone: 01625 545860