hackajob Limited Privacy Notice
HACKAJOB LTD. (“we” “us” ‘our” “the Company” ”hackajob”) provides customers with access to certain career services (for “Candidates”) and recruitment management services (for “Employers”, “Clients”) through the www.hackajob.com website (“Website”). hackajob must process personal data (including special categories or ‘sensitive’ personal data) so that it can provide these services. In so doing, hackajob acts as a data controller.
You may give your personal details to hackajob directly, such as on an application or registration form, CV, or via our website, or we may collect them from another source, such as a jobs board. hackajob must have a legal basis for processing your personal data. See below for more details. We will only use your personal data in accordance with the terms of this notice for the purposes of providing you with work-finding services and/or information relating to roles relevant to you.
2. What Does This Notice Cover?
This Privacy Notice explains how we use client and candidate personal data: how it is collected, how it is held, and how it is processed. It also explains your rights under the law relating to your personal data.
3. What Is Personal Data?
Personal data is defined by the UK GDPR and the Data Protection Act 2018 as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier'.
In this Privacy Notice “the Data Protection Legislation” means the General Data Protection Regulation (Regulation (EU) 2016/679) (“GDPR”) (where applicable to the storage, retention and processing of European Union member’s personal data) and the Data Protection Act 2018, the retained European Union law version of the GDPR (the “UK GDPR”), as it forms part of the law of England and Wales, Scotland, and Northern Ireland by virtue of section 3 of the European Union (Withdrawal) Act 2018, the Data Protection Directive (95/46/EC), the Regulation of Investigatory Powers Act 2000, the Telecommunications (Lawful Business Practice) (Interception of Communications) Regulations 2000 (SI 2000/2699), the Electronic Communications Data Protection Directive (2002/58/EC), the Privacy and Electronic Communications (EC Directive) Regulations 2003 (SI 2426/2003) and all applicable laws and regulations relating to the processing of personal data and privacy whether now or in the future in force, including where applicable the guidance and codes of practice issued by the Information Commissioner;
Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.
The personal data that we use is set out in Part 5, below.
4. What Are My Rights?
Under the Data Protection Legislation, you have the following rights, which we will always work to uphold:
- The right to be informed about our collection and use of your personal data. This Privacy Notice should tell you everything you need to know, but you can always contact us to find out more or to ask any questions using the details in Part 11.
- The right to access the personal data we hold about you. Part 10 will tell you how to do this.
- The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in Part 11 to find out more.
- The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we hold. Please contact us using the details in Part 11 to find out more.
- The right to restrict (i.e. prevent) the processing of your personal data.
- The right to object to us using your personal data for a particular purpose or purposes.
- The right to withdraw consent. This means that, if we are relying on your consent as the legal basis for using your personal data, you are free to withdraw that consent at any time.
- The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.
- Rights relating to automated decision-making and profiling. Part 6 explains more about how we use your personal data, including automated decision-making and profiling.
For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Part 11.
It is important that your personal data is kept accurate and up-to-date. If any of the personal data we hold about you changes, please keep us informed as long as we have that data.
Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.
If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office. We would welcome the opportunity to resolve your concerns ourselves, however, so please contact us first, using the details in Part 11.
5. What Personal Data Do You Collect and How?
The Company may collect and hold some or all of the following personal data and special category or ‘sensitive’ personal data:
- Name, title, address, telephone number, personal email address, date of birth, gender, employment history, qualifications, experience, personal statement, aspirations, account password, and profile photo.
How We Collect the Data:
- provided to us by you on our website;
- which we obtain through third-party sources such as publicly-accessible job boards;
- provided to us by email;
- information you provide to us during an interview or telephone call;
- information provided during a challenge or survey;
- information you provide by signing in or sharing from, or linking to, social networking sites (such as Facebook, LinkedIn, GitHub, and Google);
- analytics providers, such as Google, and search information providers;
- identity and contact data brokers and aggregators.
- IP address, login data, browser type and version, time zone setting and location, browser plugin types and versions, operating system and platform, and other technology on the devices you use to access our website. Usage data about how you use our website, products, and services, e.g. what pages you access on the Service (and when and for how long), what links or elements you click, mouse movements, and scrolling behaviours. Marketing and communications data including your preferences in receiving marketing from us and our 3rd parties, and your communications preferences.
How We Collect the Data:
- your use of our website.
- We may collect, store and use the following "special categories" of more sensitive personal information which you actively provide to us:
- Information about your race or ethnicity, religious beliefs, sexual orientation, and political opinions.
- Information about your health, including any medical condition, health, and sickness record, and any disabilities.
How We Collect the Data:
- provided to us by you on our website;
- provided to us by email or other written correspondence;
- information you provide to us during an interview or telephone call.
When you use our website, we also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
You are under no obligation to provide hackajob with data. However, if you do not provide certain information, we will not be able to provide work-finding services.
6. How Do You Use My Personal Data?
The Company needs to collect and process data in order to:
- Offer work-finding services to candidates and clients.
- Assess a candidate’s skills, qualifications, and suitability to match a candidate to available opportunities.
- Notify and correspond with clients who we think will be interested in a particular client.
- Make available your details as a candidate on our website for our clients to view.
- Communicate with candidates and clients about the recruitment process. Keep records related to our services.
- Comply with legal or regulatory requirements.
- Monitor and improve our website and services.
7. Sensitive Personal Data
We will use information about your disability status to consider whether we need to notify clients that they will need to provide appropriate adjustments during the recruitment process, for example, whether adjustments need to be made during a test or interview and to notify such clients where appropriate.
8. Accuracy of Data
If you fail to provide information when requested, which is necessary for us to provide our services (such as evidence of qualifications or work history), we will not be able to provide our services properly or make your details available to suitable clients.
9. Processing of your Data
It is in our legitimate interests to provide our services to you, including making available your details to appropriate clients and, generally, on our website, as we are paid by our clients for introducing suitable candidates to them.
hackajob will process your personal data for the purpose of providing you with work-finding services. This includes, for example, contacting you about job opportunities, assessing your suitability for those opportunities, updating our databases, putting you forward for job opportunities, and developing and managing our services and relationship with you and our clients.
In some cases, hackajob may be required to collect and process 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.
We use algorithms to match you to suitable opportunities. If at any point you wish to query any action that we take on the basis of this or wish to request ‘human intervention’ (i.e. have someone review the action themselves, rather than relying only on the automated method), the Data Protection Legislation gives you the right to do so. Please contact us to find out more using the details in Part 19. If you object to the use of the algorithms, we will not be able to provide you with our services.
The legal bases we rely upon to offer our services to you are:
- Your consent (e.g. to register you as a new candidate or to manage our relationship with you);
- Where we have a legitimate interest (e.g. managing our database and keeping work records up to date, providing work-finding services to you and our clients, and contacting you to seek your consent where it is needed);
- To comply with a legal obligation that we are subject to (e.g. in order to check your entitlement to work in the UK or to comply with safeguarding requirements).
hackajob will only use your personal data for the purposes for which it was originally collected unless we reasonably believe that another purpose is compatible with those original purposes and need to use your personal data for that purpose. If we do use your personal data in this way and you wish us to explain how the new purpose is compatible with the original, please contact us using the details in Part 19.
If we need to use your personal data for a purpose that is unrelated to, or incompatible with, the purposes for which it was originally collected, we will inform you and explain the legal basis which allows us to do so.
In some circumstances, where permitted or required by law, we may process your personal data without your knowledge or consent. This will only be done within the bounds of the Data Protection Legislation and your legal rights.
10. How Long Will You Keep My Personal Data?
hackajob will only hold your personal data for as long as is necessary to fulfill the purposes for which we collected it.
Your data will only be made available to clients while your profile is “live” on our system. At all other times, your data will be stored, but not used, by us, unless you have opted into our marketing.
If you ask us to delete your data, we will not be able to provide you with the Company’s services.
Different laws may also require us to keep data for different periods of time.
The Conduct of Employment Agencies and Employment Businesses Regulations 2003 require us to keep work-seeker records for at least one year from:
- the date of their creation; or
- after the date on which we last provide you with work-finding services.
Where hackajob has obtained your consent to process your personal and sensitive data, we will do so in line with our Data Protection Policy. Upon the expiry of the period to which you have consented, hackajob will seek further consent from you. Where consent is not granted, we will not continue to process your data.
11. How and Where Do You Store or Transfer My Personal Data?
Data is stored in a range of different places, including on your application record, in the Company's candidate management systems, and in other IT systems (including the Company's email system).
We will store your personal data within the European Economic Area (“EEA”). The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein. This means that your personal data will be fully protected under the GDPR and/or to equivalent standards by law. Transfers of personal data to the EEA from the UK are permitted without additional safeguards.
We may transfer or store some or all of your personal data in countries outside of the UK. These are known as “third countries”. We will take additional steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the Data Protection Legislation as follows:
We will use specific approved contracts which ensure the same levels of personal data protection that apply under the Data Protection Legislation. For further information, please refer to the Information Commissioner’s Office or the equivalent organisation responsible for upholding information rights in the public interest, in your country.
Please contact us using the details below in Part 19 for further information about the particular data protection safeguards used by us when transferring your personal data to a third country.
The security of your personal data is essential to us, and to protect your data, we take a number of important measures, including the following:
- limiting access to your personal data to those employees, agents, contractors, and other third parties with a legitimate need to know and ensuring that they are subject to duties of confidentiality;
- procedures for dealing with data breaches (the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, your personal data) including notifying you and/or the Information Commissioner’s Office where we are legally required to do so;
12. Do You Share My Personal Data?
hackajob will process your personal data and/or sensitive personal data with the following recipients:
- Clients of the Company either directly or by putting a candidate’s details on our website, which is accessible by our clients;
- Any applicable legal or government authorities;
- Previous employers of candidates (e.g. in respect of references);
- Third-party service providers, which we use to provide our services.
When your personal data is shared with a third party, as described above, we will take steps to ensure that your personal data is handled safely, securely, and in accordance with your rights, our obligations, and the third party’s obligations under the law, as described above in Part 11. However, our clients will be controllers of your personal information once we have disclosed it to them, as they will be reviewing it and using it for their own purposes. They will be covered by the Data Protection Legislation as controllers of that data unless they are in a Third Country. We recommend you review the Client’s privacy policies for details of how they will store and use your personal information.
If any personal data is transferred outside of the UK, we will take suitable steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the Data Protection Legislation, as explained above in Part 11.
13. How Can I Access My Personal Data?
If you want to know what personal data we hold about you, you can ask us for details of that personal data and for a copy of it. This is known as a “subject access request”.
All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 19.
There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.
We will respond to your subject access request within two weeks and, in any case, not more than one month after receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
15. Promotional offers from us
We may use your Identity, Contact, Technical, Usage, and Profile Data to form a view of what we think you may want or need, or what may be of interest to you. This is how we decide which products, services, and offers may be relevant for you.
You will receive marketing communications from us if you have requested information from us or if we have provided services to you in the past, and, in each case, you have not opted out of receiving that marketing.
16. Third-party marketing
We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
17. Opting out
You can ask us or third parties to stop sending you marketing messages at any time by logging into the website and checking or unchecking relevant boxes to adjust your marketing preferences or by following the opt-out links on any marketing message sent to you or by emailing us email@example.com at any time.
19. How Do I Contact You?
To contact us about anything to do with your personal data and data protection, including making a subject access request, please use the following details :
Email address: firstname.lastname@example.org.
Postal Address: 63 Gee Street, Second Floor, London, England EC1V 3RS, United Kingdom.
20. Changes to this Privacy Notice
We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection. Any changes will be made available via our website.