PRIVACY POLICY.

Sunrise Recruitment (“We”) is part of Worldwide Emigration Ltd and we are committed to protecting and respecting your privacy

Our Group means our subsidiaries, our ultimate holding company and its subsidiaries, our associated companies as defined in section 1159 of the UK Companies Act 2006 (our Group)

This notice, together with our terms and conditions, sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. This notice applies to candidates.

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.

GDPR  is  applicable in the UK from 25th May 2018. GDPR is 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: 

Sunrise Recruitment of AW House, 6-8 Stuart St, Suite 500, Luton, LU1 2SJ, United Kingdom.

Our nominated representative is S. Rizvi.

Who we are and what we do

We are an international recruitment agency and recruitment business as defined in the Employment Agencies and Employment Businesses Regulations 2003 (our business) and online exam review provider. We will use your personal information in the following circumstances (further detail outlined below);

• Where we need to perform or take preparatory steps to perform the contract we have entered/shall enter into with you;
• Where we need to comply with a legal obligation; and
• 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 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;
• Prospective and live client contacts;
• Supplier contacts to support our services;
• Employees, consultants, temporary workers;

We collect information about you to carry out our core business and ancillary activities.

Information you give to us or we collect about you

This is information about you that you give us by filling in forms on our website (www.sunriserec.com) or by corresponding with us by phone, e-mail or otherwise. It includes information you provide when you register to use our site, send us CVs (resume), download resources, entering information in our database, subscribe to our services, attend our events, participate in discussion boards or other social media functions on our site, enter a competition, promotion or survey, and when you report a problem with our site.

The information you give us or we collect about you may include your name, address, private and corporate e-mail address and phone number, financial information, compliance documentation and references verifying your qualifications and experience and your right to work in the United Kingdom, curriculum vitae and photograph, links to your professional profiles available in the public domain e.g. LinkedIn, Twitter, business Facebook or corporate website, passport details, job history, interview notes and correspondence.

Information we obtain from other sources

This is information we obtain about you from other sources such as LinkedIn, corporate websites, job board websites, online CV libraries, your business card, personal recommendations, and referrals.

In this case we will inform you we are holding your data and for what purpose we intend to retain and process it, by sending you this privacy notice, within a reasonable time. This is the earliest of;

• The first communication with you; or
• If the personal data is to be disclosed to someone else, before it is disclosed; or
• One calendar month from the date you obtained the data

We may work closely with third parties including sub-contractors in technical, professional, payment and other services, analytics providers, search information providers, credit reference agencies, and professional advisors. We may receive information about you from them for the purposes of our recruitment services and ancillary support services.

Purposes of the processing and the legal basis for the processing

We use information held about you in the following ways:

• To carry out our obligations arising from any contracts we intend to enter into or have entered into between you and us and to provide you with the information, products and services that you request from us or we think will be of interest to you because it is relevant to your career or to your organisation
• To provide you with information about other goods and services we offer that are similar to those that you have already purchased, been provided with or enquired about
• 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 required 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.  Examples of when consent may be the lawful basis for processing include permission to introduce you to a client (if you are a candidate).

Our Legitimate Business Interests

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. Your personal data may be used for email marketing purposes to keep you informed about related industry news and articles, career advice, events, surveys, activities and services.

Consent

Should we want or need to rely on consent to lawfully process your data we will request your consent orally, by email or by an online process for the specific activity we require consent for and record your response on our system. 

Where consent is the lawful basis for our processing you have the right to withdraw your consent to this particular processing at any time.

Other uses we will make of your data:

• use of our website;
• to notify you about changes to our service;
• to ensure that content from our site is presented in the most effective manner for you and for your computer

We will use this information:

• to administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
• to improve our site to ensure that content is presented in the most effective manner for you and for your computer;
• to allow you to participate in interactive features of our service, when you choose to do so;
• as part of our efforts to keep our site safe and secure;
• to make suggestions and recommendations to you and other users of our site about goods or services that may interest you or them

We do not undertake automated decision making or profiling. We do use our computer systems to search and identify personal data in accordance with parameters set by a person. A person will always be involved in the decision-making process.

Disclosure of your information inside and outside of the EEA

We will share your personal information with:

Any member of our group both in the EEA and outside of the EEA.

Selected third parties including:

• Relevant Government agencies for the purpose of visa processing;
• Lawyers and visa processors who will process you and your dependants immigration application;
• Employers for the purposes of the job application and interview, immigration processing and subsequent employment;
• Travel, relocation and acclimatisation companies to help you travel and settle in the various countries ;clients, business partners, suppliers and sub-contractors for the performance and compliance obligations of any contract we enter into with them or you;
• candidates for the purpose of arranging interviews and engagements;
• subcontractors including email marketing specialists, event organisers, payment and other financial service 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 Sunrise Recruitment or substantially all of our 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 in order to enforce or apply our terms and conditions of supply of services and other agreements; or to protect the rights, property, or safety of 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.

All information you provide to us is stored internally on our secure servers and externally on our cloud servers secured by third party cloud storage specialist providers such as Microsoft ; any information that is stored on our CRM (Customer Relationship Management) software is also secured by a third party. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our sites, 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 and will hold your personal data for up to 7 years after your last contact. We run data routines to remove data that we no longer have a legitimate business interest in maintaining.

We do the following to try to ensure our data is accurate:

• Our website enables you to manage your data and to review whether the details we hold about you are 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 Manager (CRM) system.
• We may pseudonymise parts of your data, particularly following a request for suppression or deletion of your data, to ensure that we do not re-enter your personal data on to our database, unless requested to do so.

For your information, Pseudonymised Data is created by taking identifying fields within a database and replacing them with artificial identifiers, or pseudonyms.

Our current retention notice is available upon request.  

Your rights  

You have the right to ask us not to process your personal data for marketing purposes. As above and where possible, we will usually inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes and we will collect express consent from you if legally required prior to using your personal data for marketing purposes.

You can exercise your right to accept or prevent such processing by checking certain boxes on the forms we use to collect your data. You can also exercise the right at any time by contacting us on gdpr@thebusinessanalyst.co.uk

Our site may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. 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.

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 (see below).
• 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/

Right to withdraw consent

If you do grant consent, please note you can withdraw your consent to all or any one of the above purposes at any time by gdpr@thebusinessanalyst.co.uk.  Please note that all processing of your personal data will cease once you have withdrawn consent but this will not affect any personal data that has already been processed prior to this point. Please allow up to 7 days to process.

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 Act (and the GDPR once it is in force). Prior to 25th May 2018 any access request under the Data Protection Act will be subject to a fee of £10 to meet our costs in providing you with details of the information we hold about you.

A subject access request should be submitted to gdpr@thebusinessanalyst.co.uk. No fee will apply once the GDPR comes into force.

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 our GDPR working group on gdpr@thebusinessanalyst.co.uk

Copyright:

All contents of this site are copyright of Worldwide Emigration Ltd. unless otherwise indicated.

Disclaimer:

The contents of this website, including the downloadable content (such as PDF’s) are intent for information and neither we nor the author will accept responsibility for damage caused as a result of reading the web pages or documents. All information is as accurate as possible, but the occasional error may be present. Worldwide Emigration Ltd. does not take any responsibility for any mistakes that are made on this website, but will do our best to correct any that are found. If you find anything that causes concern please let us know.

email: gdpr@sunriserec.com

Links disclaimer:

We include links from our website to other web pages to improve your understand of the various processes involved in emigration. Many of the links from our site lead to sites that are owned by other organizations or individuals; we are not responsible for the contents or the reliability of the linked website and does not necessarily endorse the views expressed within them. Listing the link shall not be taken as endorsement of any time. As such we cannot deal with any queries arising from any external website – please contact the owner of the website if you have any queries.

Broken links:

We cannot guarantee that links will work all of the time and we have no control over availability of linked pages.

If your browser reports that it cannot contact the site, there is probably a fault at the website and it may be worth trying again later. However, if you receive a Document Not Found (error 404) message, our link is wrong – please tell our contact: info@thebusinessanalyst.co.uk so that we can correct it.

If you would like us to link to your site, or another site you find useful, please contact us at info@thebusinessanalyst.co.uk with the URL and we will consider adding a link. Please suggest where in our site you think the link should be placed. Note – we will not consider paid sponsored links or spam links, so please do not email us with such requests.

Links to this Site:

You are welcome to make a link to any page on our site if you think it is useful.

However, please do not copy any text or graphics from our pages onto your own, or include any graphics on our site within your pages, without contacting us for permission.

Cookies:

This website uses cookies to better the users experience while visiting the website. Where applicable this website uses a cookie control system allowing the user on their first visit to the website to allow or disallow the use of cookies on their computer / device. This complies with recent legislation requirements for website’s to obtain explicit consent from users before leaving behind or reading files such as cookies on a user’s computer / device.
Cookies are small files saved to the users device (for example, the hard drive of your PC) that track, save and store information about the users interactions and usage our website. This is so that we can improve the browsing experience for our users, and better understand what parts of our web site need improving. It also allows us to better understand and improve your own browsing experience.
Users may prevent cookies from being downloaded onto this computer by following the specific instructions for their internet web browser.
We also employ the use of Google Analytics to track the visitor’s behaviour on our website. This tracking stores no personal data about you, and is used solely for the purposes of improving browsing experience and better understanding our viewers.  More information on Google’s Privacy Policy can be read from their official website –  http://www.google.com/privacy.html .
Due to our website linking with various other websites (including ones that we do not control) they may also store their own cookies on your system. These cookies typically expire after a period of 30 days, but please refer to their own privacy policies for more information on this