Privacy Policy

---

PRIVACY POLICY

Last Updated: 23 October 2024

INTRODUCTION

This Privacy Policy describes how we collect, use and process your personal data, and how, in doing so, we comply with our legal obligations to you. Your privacy is important to us, and we are committed to protecting and safeguarding your data privacy rights.

This Privacy Policy applies in respect of the personal data of the following categories of people: Candidates, Temporary Workers, Clients, Suppliers and Third Parties, People Whose Data We Receive, Website Users, Staff Alumni, and Visitors.

If you are:

a member of Greenway Collins Search LTD Staff, you should refer to the Greenway Collins Search LTD Staff Privacy Policy which is available on the Greenway Collins Search LTD Intranet; or

seeking employment with Greenway Collins Search LTD internally, you should refer to the Recruits Privacy Policy.

We are subject to applicable data protection legislation including but not limited to the General Data Protection Regulation (Regulation (EU) 2016/679) (the “GDPR”), and the UK GDPR. Please note that when we refer to the GDPR throughout this Privacy Policy, we are referring to both the GDPR and UK GDPR.

The company responsible for your personal data (“Greenway Collins Search LTD”, “we” or “us“) can be found here.

It is important to point out that we may amend this Privacy Policy from time to time. Please just visit this page if you want to stay up to date, as we will post any changes here.

If you are dissatisfied with any aspect of our Privacy Policy, you may have legal rights and, where relevant, we have described these in this document.

HOW TO USE THIS PRIVACY POLICY

This Privacy Policy tells you a few things about how we use your personal data, and perhaps more importantly, what your rights are in relation to this (you have, for example, the right to ask us to delete or confirm the nature of information that we hold about you at any time, withdraw any consents that you may previously have given and/or lodge a complaint with our Data Protection Officer or a supervisory authority if you are not happy about something we have done).

The Privacy Policy is broadly divided into two sections:

Context-specific privacy information that applies to the different categories of person covered by this Privacy Policy, as follows:

Candidates

Temporary Workers

Clients

Suppliers and Third Parties

People Whose Data We Receive

Website Users

Staff Alumni

Visitors

General privacy information that applies to all of the different categories of people covered by this Privacy Policy, including:

Who do we share your personal data with?

How do we safeguard your personal data?

How long do we keep your personal data for?

How can you access, amend or take back the personal data that you have given to us?

Who is responsible for processing your personal data when you access the Greenway Collins Search LTD website?

How do we store and transfer data internationally?

Cookies Policy

Use of third party services

This Privacy Policy applies in relevant countries throughout our international network. Different countries may approach data privacy in slightly different ways and so we also have country-specific parts to this Privacy Policy. You can find country-specific provisions for your jurisdiction here. This allows us to ensure that we're complying with all applicable data privacy protections, no matter where you are.

This Privacy Policy also contains a number of defined terms (which we distinguish by starting them with a capital letter), so we have included a Glossary at the end of this document.

CONTEXT-SPECIFIC PRIVACY INFORMATION

CANDIDATES

This section of the Privacy Policy applies to Candidates.

Candidates include individuals with whom Greenway Collins Search LTD has not had prior contact, but whom Greenway Collins Search LTD reasonably considers would be interested in, or might benefit from, Greenway Collins Search LTD’ services and being considered for any roles advertised or promoted by Greenway Collins Search LTD including permanent, part-time and temporary positions and freelance roles with Greenway Collins Search LTD' Clients (including those individuals who want to become Temporary Workers). Candidates also include applicants for such roles as well as people who have supplied a speculative CV to Greenway Collins Search LTD not in relation to a specific job and/or who have engaged with Greenway Collins Search LTD about Greenway Collins Search LTD’ services and/or any roles advertised or promoted by Greenway Collins Search LTD. Individual contractors, freelance workers and employees of suppliers or other third parties put forward for roles with Greenway Collins Search LTD' Clients as part of an MSP offering or otherwise will be treated as Candidates for the purposes of this Privacy Policy.

WHAT KIND OF PERSONAL INFORMATION DO WE COLLECT?

So you're looking for a bit more insight into what data we collect about you? Here's a more detailed look at the sorts of information that we will collect. The information described below is, of course, in addition to any personal data we are required by law to process in any given situation.

Depending on the relevant circumstances and applicable local laws and requirements, we will collect some or all of the information listed below to enable us to assess how we can assist you if we reasonably believe you might be interested in, or might benefit from our services, and to offer you employment opportunities which are tailored to your circumstances and your interests.

In some jurisdictions, we are restricted from processing some of the data outlined below. In such cases, we will only process the data in those jurisdictions to the extent and under the circumstances permitted by law: 

Key identification and contact information

Name;

Age/date of birth;

Birth number;

Sex/gender;

Photograph;

Marital status;

Nationality/citizenship/place of birth;

Contact details;

Emergency contacts/next of kin information and details of any dependants;

A copy of your driving licence and/or passport/identity card;

Education and employment information

Education details;

Employment history;

Current job title/specialism/industry sector;

Skills and languages spoken;

Referee details;

Immigration status (whether you need a work permit);

Start date or availability date;

Details about your previous and current remuneration, pensions and benefits arrangements;

Details of hours worked (once you have been placed in a role);

Information on your interests and needs regarding future employment, both collected directly and inferred, for example from jobs viewed or articles read on our website or from links clicked on in emails from us;

Financial information

Bank details;

Financial information (where we need to carry out financial background checks);

Social security number (or equivalent in your country) and any other tax-related information;

Special category information

Details of racial or ethnic origin, sexual orientation, religious or other similar beliefs, and physical or mental health, including disability-related information, in ease case for diversity monitoring purposes;

Sexual orientation (for example where you disclose this through providing next-of-kin details);

Physical or mental health, including disability-related information in order to enable us to make reasonable adjustments and health-related information when we need to use or offer occupational health to you in the context of certain types of roles;

Details of health-related information arising from or in connection with the COVID-19 or other pandemics, if this is required for a role that you are interested in applying for or where volunteered by you, e.g. a test result (whether positive or negative) or vaccination history (including medical conditions relating to or affecting vaccination) where appropriate;

In certain circumstances, video recordings of Candidates attending or participating in training or meetings where individuals have consented to the recording;

Religious Beliefs in order to calculate entitlement to annual leave;

Criminal conviction data

Details of any criminal convictions if this is required for a role that you are interested in applying for;

Automatically collected information

IP address;

Usage information including the dates, times and frequency with which you access our services;

User choices (e.g. marketing preferences);

User reports;

Log and troubleshooting information;

Device information when you install, access or use our services;

Website browsing data e.g. pages viewed e.g. Greenway Collins Search LTD or Clients’ websites;

Email engagement history with Greenway Collins Search LTD;

Location information (inferred from jobs, IP address, application history or system stored data);

Account access information (e.g. PIN numbers for account verification purposes);

Information that others provide about you

Extra information that your referees choose to tell us about you;

Extra information that our Clients may tell us about you, or that we find from other third party sources such as job sites (which you have uploaded information onto, or is otherwise made available to us);

Information about your interests and needs regarding future employment, both collected directly and inferred, for example from jobs viewed or articles read on our website or from links clicked on in emails from us; and

Additional information that you choose to tell us

Any other information that you may provide to us including, for instance, details of your childcare or carer arrangements (for example, when you authorise a deduction from pay for childcare vouchers or when you volunteer this information) and when corresponding with us via email or otherwise.

Please note that the above list of categories of personal data we collect is not exhaustive.

To the extent that you access our website or click through any links in an email from us, we will also collect certain data from you. If you would like more information about this, please refer to the context-specific section of this Privacy Policy that applies to Website Users.

HOW DO WE COLLECT YOUR PERSONAL DATA?

We collect Candidate personal data in the following ways:

Personal data that you, the Candidate, give to us;

Personal data that we receive from other sources; and

Personal data that we collect automatically.

Personal data you give to us

Greenway Collins Search LTD needs to know certain information about you in order to provide you with its services. This will enable us, amongst other things, to provide you with the best opportunities, and should save you time in not having to trawl through information about jobs and services that are not relevant to you.

There are numerous ways you can share your information with us. These may include:

Entering your details on the Greenway Collins Search LTD website or via an application form, as part of the registration process;

Leaving a hard copy CV at a Greenway Collins Search LTD recruitment event, job fair or office;

Emailing your CV or other information to a Greenway Collins Search LTD consultant or being interviewed by them;

Applying for jobs through a job aggregator, which then redirects you to the Greenway Collins Search LTD website;

Entering your personal details into a Greenway Collins Search LTD microsite; or

Entering a competition through a social media channel such as Facebook or Twitter (or similar).

The types of information that receive from you in this way include:

Key identification and contact information;

Education and employment information;

Financial information;

Special category information;

Criminal conviction data, and

Additional information that you choose to tell us,

as described in the section entitled “What Kind of Personal Information Do We Collect?” above.

Personal data we receive from other sources

We also receive personal data about Candidates from other sources. Depending on the relevant circumstances and applicable local laws and requirements, this will involve personal data received in the following situations:

When we search for Candidates via third party sources, such as LinkedIn and other job sites, from which we obtain your personal information and/or when we carry out other pre-recruitment activities (please refer to the section entitled “Pre-recruitment activities” below);

Your referees may disclose personal information about you;

Our Clients, Suppliers, other Candidates and our colleagues within Greenway Collins Search LTD (e.g. in the context of them making a referral) may share personal information about you with us;

If we receive your personal information from Facebook or Twitter, if you ‘like’ our Facebook page or ‘follow’ us on Twitter (or perform a similar interaction with us on any social media platform on which we have a presence); and

If you were referred to us through an RPO or an MSP supplier, they may share personal information about you with us.

The types of information that we receive about you in this way include the information that others provide about you described in the section entitled “What Kind of Personal Information Do We Collect?” above.

Personal data we collect automatically

To the extent that you access our website or read or click on an email from us, where appropriate and in accordance with any local laws and requirements, we will also collect your data automatically (e.g. via website tracking scripts such as cookies or pixels) or through you providing it to us. For more information, please refer to the context-specific section of this Privacy Policy that applies to Website Users.

The types of information that we collect about you in this way includes the “Automatically collected information” described in the section entitled “What Kind of Personal Information Do We Collect?” above.

HOW DO WE USE YOUR PERSONAL DATA?

We generally use Candidate data in five ways:

Pre-recruitment Activities;

Recruitment Activities;

Marketing Activities;

Equal Opportunities Monitoring; and

To help us to establish, exercise or defend legal claims.

In appropriate circumstances, we also use Candidate data for Profiling.

Pre-recruitment Activities

When conducting pre-recruitment activities, we use your data to work out whether you might be interested in, or might benefit from, our services, and to assess whether and how we might be able to assist you. If we think we can help, we will use your contact details to get in touch with you and find out if you are interested in our services (usually via email), subject to any applicable laws and requirements.

In order for us to do this, we may:

Collect your personal data;

Store your details (and update them when necessary) on our database so that we can contact you about our services;

Send you an email to inform you about our processing of your personal data and to direct you towards this Privacy Policy;

Review your information to work out whether and how our services might help you; and

Contact you about our services.

We've set out in more detail below various ways in which we will use and process your personal data for the purposes of determining whether our services would be beneficial to you, where appropriate and in accordance with any local laws and requirements. Please note that this list is not exhaustive.

In most cases, we will use your personal data for the purposes below if we deem it necessary to do so for our legitimate interests. Article 6(1)(f) of the GDPR says that we can process your data where it “is necessary for the purposes of the legitimate interests pursued by us or by a third party, except where such interests are overridden by the interests or fundamental rights or freedoms of you which require protection of personal data.”

We don't think that any of the activities in relation to which we rely on the legitimate interests condition prejudice Candidates in any way. However, you do have the right to object to us processing your personal data on this basis. If you would like to know more about how to do so, please refer to the section entitled “How can you access, amend or take back the personal data that you have given to us” in the General Privacy Information section of this Privacy Policy.

Please note that in certain of the jurisdictions in which we operate, we comply with additional local law requirements. For more information in relation to your jurisdiction, please click here.

Why and how we process your information

Types of personal data used

Legal basis relied upon

Collecting and processing data in the course of and to the extent necessary to work out whether you might be interested in or benefit from recruitment services, including by:

collecting data from Candidates and other sources, such as LinkedIn

storing Candidates’ details on databases

assessing data against vacancies

Key identification and contact information

Education and employment information

Additional information that you choose to tell us

Information that others provide about you

Automatically collected information

Legitimate interests, namely it is in our interests and your interests for us to assess whether you may be interested in or benefit from our recruitment services

Collecting and processing your data in the course of reviewing your information to ascertain how Greenway Collins Search LTD' recruitment services may assist

Key identification and contact information

Additional information that you choose to tell us

Legitimate interests, namely it is in our interests and your interests for us to identify how we can help you with your job search

Collecting and processing your data in the course of communicating with you in relation to Greenway Collins Search LTD' recruitment services

Key identification and contact information

Additional information that you choose to tell us

Legitimate interests, namely it is in our interests and your interests to contact and correspond with you as part of providing you with our recruitment services

Recruitment Activities

Obviously, our main area of work is recruitment – connecting the right Candidates with the right jobs. We've listed below various ways in which we will use and process your personal data for this purpose, where appropriate and in accordance with any local laws and requirements. Please note that this list is not exhaustive.

In most cases, we will use your personal data for the purposes below if we deem it necessary to do so for our legitimate interests. Article 6(1)(f) of the GDPR says that we can process your data where it “is necessary for the purposes of the legitimate interests pursued by us or by a third party, except where such interests are overridden by the interests or fundamental rights or freedoms of you which require protection of personal data.”

We don't think that any of the activities in relation to which we rely on the legitimate interests condition prejudice Candidates in any way – in fact, they help us to offer you a more tailored, efficient service. However, you do have the right to object to us processing your personal data on this basis. If you would like to know more about how to do so, please refer to the section entitled “How can you access, amend or take back the personal data that you have given to us” in the General Privacy Information section of this Privacy Policy.

We may in certain circumstances process your personal data for the purposes below if it is necessary for us to deliver a contractual service to you (or to fulfil a pre-contract request from you). Article 6(1)(b) of the GDPR says that we can process your data where it “is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract.”

When we process your information for recruitment activities based on your consent, you have the right to withdraw your consent at any time without affecting the lawfulness of processing based on such consent before the consent is withdrawn by referring to the section entitled “How can you access, amend or take back the personal data that you have given to us” in the General Privacy Information section of this Privacy Policy.

Please note that in certain of the jurisdictions in which we operate, we comply with additional local law requirements. For more information in relation to your jurisdiction, please click here.

Why and how we process your information

Types of personal data used

Legal basis relied upon

Collecting and processing data in the course of and to the extent necessary to provide recruitment services to Candidates and facilitating the recruitment process including by:

Collecting data from Candidates and other sources, such as LinkedIn

Storing Candidates' details on database

Assessing data against vacancies

Sending Candidates' information to Clients, in order to apply for jobs or to assess eligibility for jobs

Enabling Candidates to submit CVs, apply online for jobs or to subscribe to alerts about jobs

Recording Candidates' question and answer sessions and/or video interviews to support our recruitment services (with the recordings being analysed for training/monitoring purposes and/or shared with Clients and viewed via a secure third party platform)

Making video recordings of Candidates' participation in training sessions or meetings for internal training/monitoring purposes and/or monitoring internal compliance standards

Key identification and contact information

Education and employment information

Additional information that you choose to tell us (e.g. information that you tell us in a recording)

Information that others provide about you

Video recording footage

We will rely on legitimate interests, namely it is in our interests and your interests for us to provide you with our recruitment services and for you to receive them in order for us to function as a profit-making business, and to help you and other Candidates to find employment

If you have entered or are about to enter into a contract with us or if you are making a request in the course of doing so, we may rely on the performance of a contract legal basis to the extent that the processing activity that we are seeking to conduct is necessary for the purposes of the contract or your request

To the extent that we record a video of you, we will ask for your consent before we start recording but will rely on legitimate interests in relation to our use of the data for training/monitoring and for monitoring compliance standards

Processing Candidates' data to facilitate payroll and invoicing processes

Key identification and contact information

Education and employment information

Financial information

Legitimate interests, namely it is in our interests and your interests to:

ensure that our business runs smoothly, so that we can carry on providing services to Candidates like you

ensure that you are appropriately remunerated

If you have entered or are about to enter into a contract with us or if you are making a request in the course of doing so, we may rely on the performance of a contract legal basis

Collecting and processing Candidates' data in the course of carrying out:

customer satisfaction surveys

Greenway Collins Search LTD market research which we will use to inform our marketing materials and other informational materials such as whitepapers, reports and articles (e.g. our salary guides)

To the extent that any data is published, this will be in aggregated/anonymised form only

Key identification and contact information

Additional information that you choose to tell us

Legitimate interests, namely it is in our interests to:

improve and develop the recruitment services that we provide to you by considering your feedback and feeding this into our processes where we deem necessary

gain an insight into the careers, goals and aspirations of the Candidates to whom we provide services in order to market our service offering to help differentiate us in a competitive marketplace

Collecting and processing Candidates' data in the course of communicating with Candidates in relation to services-related issues and providing customer support by processing requests for support

Key identification and contact information

Additional information that you choose to tell us

We will rely on legitimate interests, namely it is in our interests and your interests to:

address any issues that you have been experiencing

improve and develop the recruitment services that we provide to you by considering your feedback and feeding this into our processes where we deem necessary

If you have entered or are about to enter into a contract with us or if you are making a request in the course of doing so, we may rely on the performance of a contract legal basis in relation to using your data in the course conducting communications relating to our services with you

Processing Candidates' data to enable them to receive services ancillary to recruitment services, such as participation in:

specialist online training

interactive features of services

recruitment-related services via the Greenway Collins Search LTD App

Key identification and contact information

Additional information that you choose to tell us

Information that others provide about you

Certain automatically collected information e.g. User choices and information about your use of these services

We will rely on legitimate interests, namely it is in our interests and your interests to:

recommend and grant you with access to our specialist online training or some of our more interactive services as this might help with your job search

provide you with the best possible end-to-end service and enhance our service offering to you and to help differentiate us in a competitive marketplace

If you have signed up to receive these ancillary services (either separately or because they form part of the recruitment services to which you have already signed up) or if you are making a request in the course of doing so, we may rely on the performance of a contract legal basis to the extent that the processing activity that we are seeking to conduct is necessary for the purposes of the contract or your request

Processing Candidates' data in the course of carrying out Greenway Collins Search LTD' obligations arising from any contracts entered into between Greenway Collins Search LTD and third parties in relation to Candidates' recruitment, such as potential employers to whom we are committed to identifying the most suitable Candidates for roles in their organisations

Key identification and contact information

Education and employment information

Financial information

Information that others provide about you

Additional information that you choose to tell us

We will rely on legitimate interests, namely it is in our interests and your interests to fulfil our obligations under agreements with third parties such as potential employers so that we can help you find employment

If you have entered or are about to enter into a contract with us or if you are making a request in the course of doing so, we may rely on the performance of a contract legal basis to the extent that the processing activity that we are seeking to conduct is also necessary for the purposes of our contract with you (as well of the third party)

Verifying details that a Candidate has provided or to request information (such as references, qualifications and potentially any criminal convictions, to the extent that this is appropriate and in accordance with local laws)

Key identification and contact information

Education and employment information

Criminal conviction data

Information that others provide about you

Additional information that you choose to tell us

For criminal conviction data, we will obtain your explicit consent.

For all other types of data:

we will rely on the legitimate interests legal basis, namely it is in our interests and your interests to verify that all of the information that you have provided to us is true and accurate and to obtain references about your prior conduct as part of the process of finding you employment

if you have entered or are about to enter into a contract with us or if you are making a request in the course of doing so, we may rely on the performance of a contract legal basis to the extent that verifying details that you have provided or the requests that we need to make are necessary for the purposes of our contract with you.

In certain jurisdictions, using a web-based video identity verification process to verify a Candidate's identity if we do not meet them in person and document this process

Key identification and contact information (including a copy of driving licence and/or passport/identity card)

Additional information that you choose to tell us

Video recording footage

To the extent that this is carried out in your jurisdiction, we will ask for your consent before we start recording but rely on the legitimate interests condition (it is in our legitimate interests to maintain internal compliance standards) in relation to our use of the data that we capture to verify your identity.

For more information in relation to your jurisdiction, please click here

Collecting and processing Candidate data in the course of carrying out assessment and development activities such as psychometric evaluations or skills tests - for more information in relation to your jurisdiction, please click here

Key identification and contact information

Additional information that you provide or choose to tell us during the evaluation/skills test (including in relation to your performance)

Legitimate interests, namely it is in our interests and your interests for us to provide you with the services of our Assessment and Development departments, namely in relation to psychological assessment and research, assessment centres, competency management, reorganisation issues, management development, career development, mobility, outplacement, career transition and coaching. 

Marketing Activities

We will periodically send you information that we think you may find interesting, or to ask for your help with connecting other Candidates with jobs. In particular, we will use your data for the purposes listed below, where appropriate and in accordance with any local laws and requirements. Please note that this list is not exhaustive.

We need your explicit opt-in consent for some aspects of these activities or soft-opt-in (which we explain further below). Please note that in certain of the jurisdictions in which we operate, we comply with additional local law requirements regarding consenting to receive marketing materials. For more information in relation to your jurisdiction, please click here.

Soft opt-in consent is a specific type of consent which applies where we have obtained your contact details from an occasion when you previously engaged with us (for example by informing one of our consultants that you are interested in our services, submitting a job application or CV, or registering a vacancy to be filled), and we are e-marketing or sending by text message other recruitment-related services of our own. Under ‘soft opt-in’ consent, we will take your consent as given unless or until you object or opt out (and we will remind you of your right to do this and provide you with the opportunity to opt-out, in each e-marketing message that we send to you). For most people, this is beneficial as it allows us to provide you with information that we think will be of interest to you and suggest other jobs to you alongside the specific one you applied for, significantly increasing the likelihood of us finding you a new position. We will use your personal data to send you e-marketing materials with your ‘soft opt-in’ consent if we deem that it is in our legitimate interests to do so.

For other types of e-marketing, we are required to obtain your explicit consent. If you are not happy about our approach to marketing, you have the right to opt out or withdraw your consent at any time and can find out more about how to do so by referring to the section entitled “How can you access, amend or take back the personal data that you have given to us” in the General Privacy Information section of this Privacy Policy. Nobody's perfect, even though we try to be. We want to let you know that even if you have opted out from our marketing communications through our preference centre, it is possible that your details may be recaptured through public sources in an unconnected marketing campaign. We will try to make sure this doesn't happen, but if it does, we're sorry. We'd just ask that in those circumstances you opt out again.

Please note that in certain of the jurisdictions in which we operate, we comply with additional local law requirements. For more information in relation to your jurisdiction, please click here.

Why and how we process your information

Types of personal data used

Legal basis relied upon

Using Candidates' data to carry out marketing activities to promote our services through digital channels including in relation to:

marketing our full range of recruitment services (permanent, temporary, contract, outplacement, MSP programmes and RPO services) to you

sending Candidates details of reports, promotions, offers, networking and client events, and general information about the industry sectors which we think might be of interest to them

providing Candidates with information about certain discounts and offers that they are eligible for by virtue of their relationship with Greenway Collins Search LTD

Key identification and contact information

Automatically collected information

If we have obtained your contact details from an occasion when you previously engaged with us and we are e-marketing other recruitment-related services of our own, we will rely on soft opt-in consent if we consider that the legitimate interests legal basis applies, namely if we wish to reach out to you to tell you about our services and we consider that it would be in your interests to hear about similar services to those that you have already expressed an interest in

In all other circumstances, we will obtain your opt-in consent

Collection of data via cookies or tracking pixels and use of data to show users Greenway Collins Search LTD adverts and other content on other websites, for example, Facebook

Key identification and contact information

Automatically collected information

We will obtain your consent via the Cookie Preferences link on our website

If you do not want us to use your data in this way, please turn off the “Advertising Cookies” option (please refer to our Cookies Policy)

Even where you have turned off advertising cookies, it is still possible that you may see a Greenway Collins Search LTD advert, but in this case it won’t have been targeted at you personally, but rather at an anonymous audience

Please note that if you access Greenway Collins Search LTD' services across multiple devices, you may need to adjust your settings (e.g. if you want to turn off advertising cookies) via the Cookie Preferences link on each of your devices

Lookalike targeting and other data driven marketing: providing lists of certain Candidates' data to Facebook and Google to enable them to find an audience of people with similar characteristics or demographics to these Candidates (which will not include these Candidates) for Greenway Collins Search LTD' marketing purposes.

Facebook's policy is to irreversibly hash such lists prior to use, match the hashed data against their own customers, generate the lookalike audience, then delete the original list and use it for no other purpose. We will not have access to the identity of anyone in the lookalike audience, unless they choose to click on the advertisements.

Key identification and contact information

Automatically collected information (advertising identifiers)

We will obtain your opt-in consent for the collection of advertising identifiers via the Cookie Preferences link on our website

We will share these advertising identifiers with Facebook and Google in reliance on the legitimate interests legal basis, namely it is in our interests to identify and target advertisements to potential customers who share characteristics or demographics with our existing customers, unless we are required by local law to obtain your consent in which case we will obtain such consent via our consent management tool

Displaying excerpts from Candidates' profiles for promotional purposes on Greenway Collins Search LTD' website(s) to provide examples of success stories

Key identification and contact information

Education and employment information

Additional information that choose to tell us (we may ask you for additional details for the purposes of the story that we tell about you)

We will always ask for your explicit consent before featuring you in this way on the website

Use of Candidates' data in the course of making service and marketing communications via WhatsApp

Key identification and contact information

Automatically collected information

We will ensure that you have opted-in (and therefore provided your consent) through one of a number of channels:

when you signing up to WhatsApp job alerts on the website

submitting an opt-in message direct to one of our WhatsApp channels

clicking through on a sign-up button on an invite email.

Special category data

We are committed to ensuring that our recruitment processes are aligned with our approach to equal opportunities and so we will process certain sensitive/special category data about you to facilitate this. Where appropriate and in accordance with local laws and requirements, we will use this information on an anonymised basis to monitor our compliance with our equal opportunities policy.

We will collect other sensitive/special category personal data about you such as health-related information or religious affiliation if this is appropriate in accordance with local laws: Article 9(2)(b) of the GDPR allows us to do this where the processing is “necessary for the purposes of carrying out the obligations and exercising our or your specific rights… in the field of employment and social security and social protection law”, as long as this is allowed by law.

We may also collect details of any criminal convictions if appropriate in accordance with local laws which may require your consent. If you are not happy about this, you have the right to withdraw your consent at any time and you can find out how to do so by referring to the section entitled “How you can access, amend or take back the personal data you have given us” in the General Privacy Information section of this Privacy Policy.

Please note that in certain of the jurisdictions in which we operate, different rules apply to this sensitive/special category data. For more information in relation to your jurisdiction, please click here.

Why and how we process your information

Types of personal data used

Legal basis relied upon

Collecting and analysing Candidates' data in order to assess and ensure our compliance with equal opportunities obligations

Details of racial or ethnic origin, sexual orientation, religious or other similar beliefs, and physical or mental health, including disability-related information

We will process your personal data in this way if our processing is necessary for the purposes of (and we have a legitimate interest in) keeping under review the existence or absence of equality of opportunity or treatment between groups of people and local laws allow us to process your data in this way without obtaining your consent

If local law requires us to obtain your consent, we will do so

Sharing Candidates' data (that has been collected to assess and ensure our compliance with equal opportunities obligations) with Clients (including to their internal or external auditors) where this is contractually required or the Client specifically requests such information to enable them to comply with their own employment processes

Details of racial or ethnic origin, sexual orientation, religious or other similar beliefs, and physical or mental health, including disability-related information

We will obtain your explicit consent before we share your data in this way

Processing medical history/health-related data to make reasonable adjustments during the recruitment process

Medical history/physical or mental health-related data

We will process your personal data in this way if we have a legitimate interest in and it is necessary for us to process your data for health and social care purposes (e.g. to assess the working capacity of an employee or potential employee for an employer) and local laws allow us to process your data in this way without obtaining your consent

If local law requires us to obtain your consent, we will do so

Processing health-related data to when we need to use or offer occupational health to Candidates in the context of certain types of roles (e.g. teaching, nursing or night work)

Medical history/physical or mental health-related data

We will process your personal data in this way if we have a legitimate interest in and it is necessary for us to process your data for health and social care purposes (e.g. the provision of health care or treatment) and local laws allow us to process your data in this way without obtaining your consent

If local law requires us to obtain your consent, we will do so

Processing health-related information arising from or in connection with the COVID-19 or other pandemics where this is required for a role that you are interested in applying for or where volunteered by you

Test results (whether positive or negative), or vaccination history (including medical conditions relating to or affecting vaccination) where appropriate

We rely on legitimate interests, namely it is in our and your interests for us to collect and share your health-related information if this is required for a role that you are interested in applying for

We may also rely on the vital interests and the public interest lawful bases, namely to protect against serious cross-border threats to health 

We may process your health and travel-related information pursuant to Article 9(2)(i) of the GDPR to enable us to process health-related information arising from or in connection with the COVID-19 pandemic to prevent the spread of and assess the risk of COVID-19 and other infectious viruses and diseases

If local law requires us to obtain your consent, we will do so

Processing criminal convictions data when carrying out background checks

Details of any criminal convictions disclosed by Candidate on the Candidate Application Form

Details of any criminal convictions obtained via background checks that we are required to carry out where this is necessary for us to comply with our legal obligations in connection with a Candidate's search for work (e.g. if we put a Candidate forward for certain roles which require a certain type of background check to be carried out)

We will obtain your explicit consent in the Candidate Application Form though where local laws allow us to do so, we may need to request a Disclosure and Barring Service Check (or equivalent applicable check in your jurisdiction) without your consent where this is necessary for us to comply with our legal obligations in connection with your search for work

Processing certain types of Candidate data in order to calculate entitlement to annual leave

Medical history/health-related data

Religious affiliation

We will process your personal data in this way if our processing is necessary for the purposes of (and we have a legitimate interest in) carrying out the obligations and exercising Greenway Collins Search LTD' specific rights in the field of employment and social security and social protection law and local laws allow us to process your data in this way without obtaining your consent

If local law requires us to obtain your consent, we will do so

Processing the sensitive/special category personal data of individuals connected with Candidates, for example:

where a Candidate discloses this to us in the course of providing next-of-kin details

to allow the relevant Candidate to access certain benefits

Details of sexual orientation, and physical or mental health, including disability-related information

We will process your personal data in this way if our processing is necessary for the purposes of (and we have a legitimate interest in) carrying out the obligations and exercising Greenway Collins Search LTD' specific rights in the field of employment and social security and social protection law and local laws allow us to process your data in this way without obtaining your consent

If local law requires us to obtain your consent, we will do so

To help us to establish, exercise or defend legal claims

Sometimes it will be necessary for us to process personal data in reliance on the legitimate interests legal basis and, where appropriate and in accordance with local laws and requirements, special category data in connection with exercising or defending legal claims. Article 9(2)(f) of the GDPR allows this where the processing “is necessary for the establishment, exercise or defence of legal claims or whenever courts are acting in their judicial capacity”.

This will arise for example where we need to take legal advice in relation to legal proceedings or ar