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Privacy Policy Simply Active Online LTD

Simply Active Online LTD T/A Direct Placements (company number 10987353) ("Direct Placements", "we", "us" or "our") is committed to protecting the privacy of our candidates, clients and users of our website. We want to provide a safe and secure user experience. We will ensure that the information you submit to us, or which we collect, via various channels (including our website, through written correspondence (including e-mail), conversations or meetings with our consultants, or through any of our offices or websites globally), is only used for the purposes set out in this policy.



Through this Privacy Policy we aim to inform you about the types of personal data we collect from candidates, the purposes for which we use the data and the ways in which the data is handled. We also aim to satisfy the obligation of transparency under the EU General Data Protection Regulation 2016/679 ("GDPR") and national laws implementing GDPR.

For this Privacy Policy the controller of personal data is Direct-placements and our contact details are set out in the Contact section at the end of this Privacy Policy.



The information we collect

We will collect your personal details, including but not limited to your name and contact details (together with your e-mail address) and other relevant information from your Curriculum Vitae ("CV"). On occasion this will also include sensitive personal information such as details of criminal convictions and ethnic origin. When we receive your details and CV electronically, this may be through a direct application on one of our websites or an application that you have made through a third-party job board.

We will likely obtain further personal information about you during our relationship with you. This information may be obtained from you directly or from third parties, such as organisations to whom we have provided your CV and who have engaged with you as part of a job application.



How we use your Personal Information

We will hold, use and disclose your personal information, for our legitimate business purposes including:

The Legal Basis for Processing your Personal Information

Under GDPR, the main grounds that we rely upon to process personal information of clients and candidates are the following:
(a) Necessary for entering into, or performing, a contract - to perform obligations that we undertake in providing a service to you, or in order to take steps at your request to enter into a contract with us, it will be necessary for us to process your personal data;

(b) Necessary for compliance with a legal obligation - we are subject to certain legal requirements which may require us to process your personal data. We may also be obliged by law to disclose your personal data to a regulatory body or law enforcement agency;

How we share your Personal Information

In certain circumstances we will share your personal information with other parties. Details of those parties are set out below along with the reasons for sharing it.
Where you are registered as a candidate on our database, we will share your personal information with other companies for employment purposes.

We will share your personal information as above for any or all the following purposes:





Clients

We disclose your personal information to clients who have vacancies for jobs in which you are interested.



Trusted Third Parties

We will share your personal information and, where necessary, your sensitive personal information with trusted third parties where we have retained them to provide services that you or our clients have requested, such as:


We will also share your personal information with third parties who perform functions on our behalf and provide services to us such as:


We require minimum standards of confidentiality and data protection from such third parties. To the extent that any personal information is provided to third parties outside the EEA, or who will access the information from outside the EEA, we will ensure that approved safeguards are in place, such as the approved Model Clauses or the EU/US Privacy Shield.



Regulatory and Law Enforcement Agencies

As noted above, if we receive a request from a regulatory body or law enforcement agency, and if permitted under GDPR and other laws, we may disclose certain personal information to such bodies or agencies.



New business owners

If we or our business merges with or is acquired by another business or company, we will share your personal information with the new owners of the business or company and their advisors. If this happens, you will be sent notice of such event.



How long we will hold your information

The length of time we will hold or store your personal information for will depend on the services we perform for you and for how long you require these. As we often support candidates with placements over many years, and potentially throughout their careers, the purpose for which we retain candidate data is often an ongoing purpose.

We conduct regular data-cleansing and updating exercises with our candidates to ensure that (a) the data that we hold is accurate and (b) we are not holding data for too long.

Our standard terms of business state that our clients should retain candidate data such as CVs for the purposes of the specific role you apply for and that, as controllers of your data, they should inform you if they plan to retain your CV on file in order to notify you about potential future roles, or to otherwise hold or use your data for other purposes.



Your rights on Information we hold about you

You have certain rights in relation to personal information we hold about you. Details of these rights and how to exercise them are set out below. We will require evidence of your identity before we are able to act on your request.



Right of Access

You have the right at any time to ask us for a copy of the personal information about you that we hold. Where we have good reason, and if the GDPR permits, we can refuse your request for a copy of your personal information, or certain elements of the request. If we refuse your request or any element of it, we will provide you with our reasons for doing so.



Right of Correction or Completion

If personal information we hold about you is not accurate, out of date or incomplete, you have a right to have the data rectified, updated or completed. You can let us know by contacting us using any of the methods in the Contact section below.



Consent

To the extent that we are processing your personal information based on your consent, you have the right to withdraw your consent at any time. You can do this by contacting us using the details in the Contact section below.



Curriculum Vitae

We give you the option to submit your CV via our website or by providing your CV to one of our consultants. You can do this either to apply for our Employment Placement Program (EPP) or for consideration by our recruitment consultants for positions as they come up.



Your CV will be stored in our database and will be accessible by our recruitment consultants.

Your CV may also be emailed directly to other companies within our Group of companies for review and entry onto their database to enable them to provide their services to you.

You can update your CV at any time, simply by following the same procedure to submit a new CV. Your old CV will automatically be archived providing the submission details remain the same (for example you submit both CVs using the same email address or you advise the relevant contact of your new submission).



Trustpilot

We may pass your name and email address on to our customer reviews partner Trustpilot. Trustpilot is an independent company specialising in collecting impartial customer feedback. Any feedback you provide will be publicly visible on trust pilot website, but your name and email address is not made publicly available.

You have no obligation to leave feedback for us, and Trustpilot will not share your information in any way. If you wish to opt out of being asked by Trustpilot to provide your feedback, please contact us using any of the methods in the Contact section below.



Changes to our Privacy Policy

This privacy policy can be changed by Direct Placements at any time. If we change our privacy policy in the future, we will advise you of material changes or updates to our privacy policy by email, where you have provided us with your email address.



When you contact us, we will ask you to verify your identity.

Our registered office is at:
Direct Placements
105 Victoria St,
Westminster, London
SW1E 6QT
0203 151 3748