Who we are?
The Data Controller is Victoria Lindfield Associates Ltd, based at 12 Hay Hill, London, W1J 8NR. We provide permanent, temporary and contractual recruitment services to clients looking to recruit personnel for their business.
As we are a recruitment company, this means that in order to help individuals such as clients or candidates, we will need to obtain certain types of information to aid in your job search.
What information do we collect?
Candidates: We collect and use only the information necessary to be able to find the best available opportunities and any further information needed to assess your eligibility through the different stages of recruitment. This information includes CVs, identification documents, educational records, work history, employment and references, and financial information.
We may also collect sensitive personal data about you, related to your health, diversity information or details of any criminal conviction offences. We only collect sensitive personal data from you, and further process this data, where you have given your explicit consent.
Clients: We collect and use only the information necessary to provide you, or people in your organisation with services such as finding the best available candidates for your opportunities.
Other data subjects: We collect and use only the information necessary to be able to contact you and pay you for the services you provide.
Website Users: We collect and use only the information necessary to improve your experience when using our website. This may include how, when and how often you visit us.
Where do we collect personal data about you from?
The following are the different sources we may collect personal data about you from:
- Directly from you. This is information you provide while searching for a new opportunity and/or during the different recruitment stages, or during the course of our work with you to ensure that our relationship runs efficiently.
- From an agent/third party acting on your behalf. e.g. A Contractor’s Limited Company.
- Through publicly available sources. For example: LinkedIn, Job Boards, By Reference or word of mouth.
Where we collect your information through publicly available sources as set out above, we may do this with the aid of software programs’. These programs are given parameters on the requirements of a role and search through publicly available sources to find such candidates. These programs are designed to only output information on candidates that meet the search criteria. The parameters of this program are restricted to only searching for candidate information from public sites where there is a reasonable expectation that such information may be collected and further processed by job recruiters for the purpose of sourcing candidates for different job roles.
Why we process personal data?
We use information held about you in the following ways:
To provide you with information, products and services that you may request from us, or we think will be of interest to you because it is relevant to your career or to your organisation.
The core service we offer to our candidates and clients is the introduction of candidates to our clients for the purposes 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 data is our Legitimate Business Interests, described in more detail below. We will in some instances rely on consent for particular use 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 a candidate to a client.
We process health information if we need to make reasonable adjustments to the recruitment process for you. This is to carry out our obligations and exercise specific rights in relation to employment.
Where we process other special categories of data, such as information about ethnic origin, sexual orientation, health or religion or belief, this is for equal opportunities monitoring purposes.
We are entitled to carry out criminal records check in order to satisfy ourselves that there is nothing in your criminal convictions history which makes you unsuitable for the role. We use a third party to do this on our behalf and may receive a copy of their report if you have consented for us to do so.
We will not use your data for any purpose other than the recruitment exercise for which you have applied.
Our legitimate business interests.
Our legitimate interests in collecting and retaining your personal data is described below:
As a recruitment business, we introduce candidates to clients for employment. 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.
Who has access to your data?
Your information will be shared internally for the purpose of the recruitment exercise. This includes members of the HR and recruitment team, interviewers involved in the recruitment process, managers in the business area with a vacancy and IT staff if access to the data is necessary for the performance of their roles.
Candidates: We share your personal data with the client who has a position to fill, in order to determine with the client whether you are a good fit for the available position. We may also conduct checks on you to verify the information you have provided and where we do this, we share your information with our appointed background checking company. Unless you specify otherwise, we may share your data with any of our associated parties – for example, our payroll and pension providers – to provide you with the best possible service.
Clients: We share your data with candidates during the course of providing recruitment services to you, and with third parties as part of our contractual relationship.
Suppliers: We share your data with third parties as part of our contractual relationship.
We will not share your data with third parties, unless your application for employment is successful and we make you an offer of employment. We will then share your data with former employers to obtain references for you, our employment background check provider to obtain necessary background checks, including a criminal record check and our credit reference agency. All our third-party service providers are required to take appropriate security measures to protect your personal information in line with our policies.
We do not envisage transferring the personal information we collect about you outside the EU.
How do we protect your data?
We take the security of your data seriously. We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions, and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.
Where do we store and process your personal data?
We keep your information on our electronic database. We access this database daily for our day-to-day business activities from a secure platform which is password protected and has strict user restrictions.
The data that we collect from you may/will be transferred to, and stored at, a destination outside of 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 of the EEA who work for us or 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 on our electronic database. Unfortunately, the transmission of information via the internet is not completely secure. Although we 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 and prevent unauthorised access.
As an environmentally conscious business, we try to limit any printed materials; especially any that contains personal information. In the event that we do have any printed personal information, it is company policy that documents are not left on desks and are locked away each evening. We shred all confidential paperwork on a daily and weekly basis.
Controlling your personal information
We value our customers and their privacy, and we will not sell, distribute or lease your personal information to third parties unless we have your permission or are required by law to do so.
We aim to keep your data for as long as required. We do regular checks with our candidates to find out if the data we hold on to them is correct and if they still would like to be kept on our system or if they still wish to be contacted regarding any job opportunities we have.
If you believe that any information we are holding on you is incorrect or incomplete, or you would like it deleted, then please contact us either verbally, or in writing at the below contact details.
Do we make automated decisions concerning you?
We may make automated decisions about you during the assessment stage of the recruitment process. We put assessment candidates through a structured screening process to assess whether each candidate meets the specific criteria for a particular position. These assessments may be fully automated, e.g. online pre-screening tests. As these assessments may result in a candidate being deemed not suitable for a position by means of a solely automated assessment, we only undertake this activity with the candidate’s explicit consent.
For how long do we keep data?
If your application for employment is unsuccessful, we will hold your data on file for 12 months after the end of the relevant recruitment process. After this period, we will securely destroy your personal information in accordance with our data retention policy.
If we wish to retain your personal information on file, on the basis that a further opportunity may arise in future and we may wish to consider you for that, we will write to you separately, seeking your explicit consent to retain your personal information for a fixed period on that basis.
If your application for employment is successful, personal data gathered during the recruitment process will be transferred to your personnel file. The period for which your data will be held will be provided to you in a new privacy notice.
As a data subject, you have a number of rights. You can:
- Access and obtain a copy of your data on request.
- Require us to change incorrect or incomplete data.
- Require us to delete or stop processing your data, for example where the data is no longer necessary for the purposes of processing.
- Object to the processing of your data where we are relying on our legitimate interests as the legal ground for processing.
- Ask us to stop processing data for a period if data is inaccurate or there is a dispute about whether or not your interests override our legitimate grounds for processing data.
If you would like to exercise any of these rights, please contact either a member of the team at email@example.com or our Data Protection Officer.
If you believe that we have not complied with your data protection rights, you can complain to the Information Commissioner.
What if you do not provide personal data?
You are under no statutory or contractual obligation to provide data to us during the recruitment process. However, if you do not provide the information, we may not be able to process your application properly or at all.
How to complain?
The complaints procedure for VLA is designed to ensure transparency, accountability, and timely resolution of any concerns raised by our clients or candidates. To initiate the process, individuals are encouraged to submit their complaints in writing via email or formal letter, detailing the nature of the issue, relevant dates and any supporting documentation. Upon receipt of the complaint, our team will conduct a thorough investigation to understand the circumstances surrounding the issue. We are committed to acknowledging receipt of the complaint within 2 weeks, and a designated complaints officer will be assigned to oversee the resolution process. The complainant will receive regular updated on the progress of the investigation, and a final resolution, along with any necessary corrective actions, will be communicated in writing within 8 weeks. Additionally, we welcome feedback on the complaints handling process to continuously improve our services and address any areas of concern. Our goal is to foster a transparent and fair environment that ensures the satisfaction of our clients and candidates.
Address: 12 Hay Hill, London, W1J 8NR