Privacy Policy

INTRODUCTION

First Call Recruitment Limited (“First Call” “us”, “we”, or “our) understands that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of all our candidates and will only collect and use your personal data in ways that are described within this Policy. We shall only process your data in accordance the Data Protection (Bailiwick of Guernsey) Law 2017 (“the Law”) and other data protection laws as applicable.

WHAT IS PERSONAL DATA?

“Personal Data” is any information relating to a Data Subject (i.e. the natural person whose personal data is being collected, held or processed), in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

Personal Data includes data relating to a living individual who can be identified from that data alone or from that data and other information in our possession. Personal Data can be factual (for example, a name, address, date of birth, race, religion, or mobile device IDs) or it can be an opinion about that person, their actions, and/or behaviour.

WHAT DOES THIS PRIVACY POLICY COVER?

The purpose of this Privacy Policy (the “Policy”) is to describe how First Call complies with the Law with regards to any personal information provided to us. This Policy applies to the collection and use of Personal Data relating to living individuals and explains how we collect, hold, and process your Personal Data. It also explains your rights under the law relating to your Personal Data. Under the law, First Call is known as a “Controller”. Controllers are the people/ organisations that determine the purpose and the way in which, (i.e. how and why), any Personal Data is processed.

WHAT PERSONAL DATA IS COLLECTED?

We may collect some or all of the following Personal Data

(this may vary according to your relationship with us):

 Name
 Date of birth
 Gender
 Address to be verified
 Nationality
 Photographic identification document (Passport or other)
 E-Mail address
 Telephone number
 Business name

 Job title
 Profession
 Employment history
 Education history
 Qualifications and skills
 Payment information
 Residence Certificate or Employment Permit
 Information about your preferences and interests

We may gain additional Personal Data from your CV or from companies with whom you have sought employment or have been employed with in the past, e.g. through references and the collection of due diligence documentation. Personal Data which is recognised by the Law as being more sensitive is categorised as “Special Category Data”. This may also be requested and could consist of information relating to:

• Your health, sickness record with a former or current employer, or any medical condition
• The commission (or alleged commission) of any criminal offence.

HOW YOUR PERSONAL DATA IS COLLECTED

We collect Personal Data from our candidates in a number of different ways, such as:
• Your interaction with us, including telephone, email and the use of our website
• Contact forms on our website
• CVs
• Application forms or other material you provide to us during the course of your business relationship with us
• Sources that are accessible to the public such as social networks, the internet and/ or any commercial registers
• Data analytics providers
• Credit reference agencies

HOW WE USE YOUR PERSONAL DATA

Under the Law, we must always have a lawful basis for using your Personal Data. This may be because the data is necessary for our performance of a contract with you, where we need to comply with a legal obligation, because you have consented to our use of your Personal Data, or because it is in our legitimate business interests to use it. Data may also be used where we need to protect your interests or if it is in the public interest to do so. Your Personal Data will be used for and/or may be used for one of the following purposes:

 Providing and managing your relationship with us
 Supplying our services to you. Your personal details are required in order for us to enter into a contract with you
 Forwarding your relevant Personal Data onto prospective employers in our role as an employment agency, which may include other jurisdictions where you have indicated your willingness to relocate
 Personalising and tailoring our services for you
 Communicating with you. This may include responding to e-mails or calls from you
 Supplying you with information by e-mail and/or post that you have opted-in to (you may unsubscribe or opt-out at any time by contacting us by your preferred method)
 Conducting data analytics

With your permission and/or where permitted by law, we may also use your Personal Data for marketing purposes, which may include contacting you by e-mail, post, text message, or telephone with information, news, and offers on our products and/or services. You will not be sent any unlawful marketing or spam. We will always work to fully protect your rights and comply with our obligations under the Law and you will always have the opportunity to opt-out / withdraw consent. To do so, please email [email protected].

HOW WE USE SENSITIVE PERSONAL DATA

As mentioned above, Special Category Data requires higher levels of control. We will only process Special Category Data under the following conditions:

 With explicit consent from you;
 To comply with legal obligations;
 Where it is in the public interest;
 In response to a legal claim to protect your interests when you may not be able to give consent; or
 The information is already in the public domain.

Any concerns a candidate may have about how First Call will use any Special Category Data may be raised on an individual basis.

HOW LONG WE RETAIN YOUR PERSONAL DATA

We will not keep your Personal Data for any longer than is necessary in light of the reason(s) for which it was first collected, including satisfying any legal, accounting or reporting obligation. Details of the various retention periods are listed in the Retention section of our Data Protection Policy and are available from our Data Protection Responsible Person on request.

HOW AND WHERE WE STORE OR TRANSFER YOUR PERSONAL DATA

We store or transfer your Personal Data within the European Economic Area (“EEA”) and the Channel Islands. This means that it will be fully protected under the Law. Where we transfer any Personal Data outside of the EEA or Channel Islands in order to seek opportunities for you, we will obtain consent from you to do so and take suitable steps in order to ensure that your Personal Data is protected and transferred in a manner consistent with the requirements under the applicable Data Protection Law.

HOW WE SHARE YOUR PERSONAL DATA

We will not share any of your Personal Data with any third-parties for any purposes other than to facilitate our recruitment services and the provision of employment opportunities to you by sharing your data with prospective employers, subject to one important exception. In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority. If any of your Personal Data is required by 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.

WHAT ARE YOUR RIGHTS?

Under the Law, you have the following rights, which we will always work to uphold:

 Right to Access and port your Personal Data
 Right to object to the processing of your Personal Data
 Right to rectification of your Personal Data
 Right to request for your Personal Data to be erased
 Right to restrict the use of your Personal Data
 Right to lodge a complaint about our use of your Personal Data with The Office of the Data Protection Authority (www.odpa.gg)
 Right to withdraw consent (if we have relied on specific consent to process your Personal Data)

Further details of your rights can be requested from the Data Protection Responsible Person or viewed on https://odpa.gg/exercising-your-rights/.
Should you wish to exercise any of the rights listed above, please contact us using the details below.

HOW YOU CAN ACCESS YOUR PERSONAL DATA

If you want to know what Personal Data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”. All subject access requests should be made in writing and sent to the e-mail or postal addresses shown below. To make this as easy as possible for you, a Subject Access Request Form is available for you to use. You do not have to use this form, but it is the easiest way to tell us everything we need to know to respond to your request as quickly as possible. Please contact us to request a Subject Access Request Form if required.

There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded’, we may refuse to provide the requested information. Should any part of the request be frivolous, vexatious, unnecessarily repetitive or otherwise excessive, we may refuse to give the information or take any action requested in that part of the request, or in exceptional circumstances, a fee may be charged to cover our administrative costs in providing such information. We will respond to your subject access request within two weeks and, in any case, not more than one month of 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.