Our Privacy Notice

Our Group means our subsidiaries, our ultimate holding company and its subsidiaries, our associated companies as defined in section 1159 of the UK Companies Act 2006 (our Group)

This notice together with our website terms of use sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us.

The UK General Data Protection Regulation (UK GDPR) (Regulation (EU) 2016/679) is a regulation which replaces the Data Protection Regulation (Directive 95/46/EC). The Regulation aims to harmonise data protection legislation across EU member states, enhancing privacy rights for individuals and providing a strict framework within which commercial organisations can legally operate.

The Brexit transition period ended on 31 December 2020 and the UK has now officially left the EU. The UK GDPR has been directly incorporated into UK law sitting alongside the Data Protection Act 2018.

Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

For the purposes of data protection legislation in force from time to time the data controller is The Association of Professional Staffing Companies (Global) Ltd. 

Our Data Protection representative is Tania Bowers, General Counsel.

Our employees and consultants should refer to our Employee Privacy Notice for information about how we process their data.

Who we are and what we do

We are a trade association for the professional recruitment industry and professional development training provider (our business). We collect the personal data of the following types of people to allow us to undertake our business:

• Prospective and current member and Trusted Partner member contacts;
• Individuals booked on our training courses;
• Individual and corporate members of Women in Recruitment;
• Employees, consultants, temporary workers;
• Supplier contacts including our freelance trainers and auditors;
• Industry and Government stakeholder contacts;
• Referees for our members.

We collect information about you to carry out our core business and ancillary activities.

Information you give to us or we collect about you

This is information about you that you give us by filling in forms on our site www.apscooutsource.org (our site) or by corresponding with us by phone, e-mail or otherwise. It includes information you provide when you register to become a member and supply member contacts, to use our website, subscribe to our services, attend our events, participate in discussion boards or other social media functions on our site or on third party sites such as LinkedIn, submit a response to a survey and when you report a problem with our site.

The information you give us or we collect about you may include your name, corporate address, private and corporate e-mail address and phone number, photograph, links to your professional profiles available in the public domain e.g. LinkedIn, Twitter, business Facebook or corporate website.

We do not normally collect your personal address and telephone numbers, personal financial information, compliance documentation, references verifying your qualifications and experience, your right to work in the United Kingdom or curriculum vitae unless we had explained the specific purposes of the processing to you beforehand, such as membership of one of our Representative Committees or because we are on-boarding you as one of our employees.

We do not generally collect special “sensitive” categories of data unless you volunteer the information to us in order to facilitate the provision of our services or for a specific purpose, such as a survey.

Information we collect about you when you visit our website

With regard to each of your visits to our web server we will automatically collect the following information:

IP address, browser type and version, operating system, URL and referral URL. This information does not identify you personally. We also record when you last logged in.

Obtain from other sources

This is information we obtain about you from other sources such as corporate websites, your employer, LinkedIn, your business card and personal recommendations.

We will process your personal data in accordance with this privacy notice.

We are working closely with third parties including companies within our Group, business partners, sub-contractors in technical, professional, payment and other services, advertising networks, analytics providers, search information providers, credit reference agencies and professional advisors. We may receive information about you from them for the purposes of our business.

Purposes of the processing and the legal basis for the processing

We use information held about you in the following ways:

To carry out our obligations arising from the membership contracts we intend to enter into or have entered into with our members, Trusted Partner members and training registrants.

To provide you with the information, and services that you request from us or we think will be of interest to you because it is relevant to your career, your organisation and the professional recruitment industry. This includes our bulletins, legal and policy updates, events information, surveys and trend reports. You have the opportunity to manage your preferences via your website log in.

Our legal basis for the processing of personal data is generally the contract we have with our members or are negotiating to enter into with prospects. We retain your personal data to keep in touch and let you know about the services we offer, book you on to events and training, register your attendance at our virtual and physical events, collect your feedback and survey responses and send you relevant information about the professional recruitment industry and our activities. We will process personal data to complete compliance requirements of membership such as Compliance + and Umbrella Management Company audits and to take references.   

We will rely on legal obligation if we are legally required to process your personal data.

Our legitimate interests in collecting and retaining your personal data include:

As a membership, not for profit, trade association we run elections for our Representative Committees periodically in accordance with our Global and country specific Rules and Terms and Conditions for members. We process candidates’ and current and historic Representative Committee members’ personal data in the course of running our committees.

In order to support our membership we require a database of current, prospect and historical member contacts containing historical information as well as current membership details.

To maintain, expand and develop our business we need to record the personal data of prospective members and training registrants.

In order to promote excellence in the recruitment industry we run APSCo awards programmes, whereby members will submit applications to us which will include personal data.

To promote responsible networking we host social events such as annual balls, lunches and executive dinners.

To communicate with stakeholders including our members’ end clients, Government and other trade associations to promote the interests of our members.

Consent

Should we want or need to rely on consent to lawfully process your data we will request your consent orally, by email or by an online process for the specific activity we require consent for and record your response on our system. Where consent is the lawful basis for our processing you have the right to withdraw your consent to this particular processing at any time by contacting [email protected].

Other Uses we will make of your data

• Use of our website;
• to notify you about changes to our services;
• to ensure that content from our site is presented in the most effective manner for you and for your computer.

We will use this information:

• to administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
• to improve our site to ensure that content is presented in the most effective manner for you and for your computer;
• to allow you to participate in interactive features of our service, when you choose to do so;
• as part of our efforts to keep our site safe and secure;
• to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you;
• to make suggestions and recommendations to you and other users of our site about goods or services that may interest you or them.

Cookies  

The APSCo OutSource website makes use of a “session cookie” that only exists during the time you are logged in via a web browser, so the website knows who you are and allow access to content if your account permits it. It does not contain any sensitive information about the user.

The APSCo OutSource website does make use of Google Analytics to provide web statistics to measure how users interact with the website. As a user navigates between web pages, Google Analytics provides website owners JavaScript tags (libraries) to record information about the page a user has seen, for example the URL of the page.

Disclosure of your information inside and outside of the EEA

We will share your personal information with:

Any member of our group both in the UK, the EEA and outside of the EEA if we consider there to be a legitimate business purpose for the sharing which will benefit our members. We do not as standard practice share our database with APSCo companies in Singapore and Australia.

Selected third parties including:

• our Trusted Partner members who host our events when you register to attend an event for security and health and safety purposes and we may disclose “sensitive” special categories of data disclosed to us if relevant, for example, to facilitate access;  
• suppliers for the performance and compliance obligations of any contract we enter into with them or you;
• subcontractors including email marketing specialists, event organisers, payment and other financial service providers;
• analytics and search engine providers that assist us in the improvement and optimisation of our site.
• suppliers such as Mailchimp we send data to for the purpose of communicating with our members, prospects and wider stakeholders.

We will disclose your personal information to third parties:

• In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets.
• We or substantially all of its assets are acquired by a third party, in which case personal data held by us about our members will be one of the transferred assets.
• If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or to protect our rights, our property, our customers, or others.

We will disclose contact information of attendees collated from the registration form at our virtual and physical events to event hosts and speakers who are current APSCo Trusted Partners.

The lawful basis for the third party processing will include:

• satisfaction of their contractual obligations to us as our data processor;
• for the purpose of a contract in place or in contemplation;
• for their own legitimate business interests;
• to fulfil their legal obligations.

Where we store and process your personal data

The data that we collect from you is stored in the United Kingdom. It may be transferred to, and stored at, a destination outside the European Economic Area (”EEA”) for the purpose of our business. It may be processed by staff operating outside the EEA who work for us or for one of our suppliers. This includes staff engaged in, among other things, our business and the provision of support services. 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 secure servers. Any payment transactions will be encrypted using SSL technology. 

Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will 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 to prevent unauthorised access.

Retention of your data

We understand our legal duty to retain accurate data and only retain personal data for as long as we need it under our contract with a member or for our legitimate business interests. Accordingly, we have a data retention policy, available on request. Much of the information we retain on our system comprise business records and not personal data. With a few exceptions, we only hold names and professional contact details for our members and prospects. Accordingly, we do not consider the personal data we hold to generally be of a sensitive or confidential nature.

We do the following to try to ensure our data is accurate:

We run periodic database routines to identify records that may be out of date.

We keep in touch with you so you can let us know of changes to your personal data.

We renew our membership on an annual basis so there is at least an annual opportunity to verify and update records.

We keep different types of data for different time periods. The criteria we use to determine whether we should retain your personal data includes:

• the nature of the personal data; and
• our legal obligations.

We may archive some or all of your personal data or retain it on our financial systems only, deleting all or part of it from our main Customer Relationship Manager (CRM) system. We may minimise the data we keep on you particularly following a request for suppression or deletion of your data, to ensure that we do not re-enter your personal data on to our database, unless requested to do so.

Your rights  

Under current legislation we do not need express consent to market to corporate contacts but we do invite you to manage the information you receive from us by completing the preference form accessible via our website.

Alternatively, please contact [email protected].

We also have an unsubscribe option on our regular communications. We do not consider these to be marketing but want to provide you with the means of easily managing content received from us.

Our website preference page provides an option to consent to data being passed to our Trusted Partner members hosting or sponsoring events so they are able to contact you about their goods and services which may be of interest to you.

Our site may, from time to time, contain links to and from the websites of our partner networks, advertisers and Trusted Partners. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.

The UK GDPR provides you with the following rights to:

• Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
• Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
• Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.
• Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
• Request the transfer of your personal information to another party in certain formats, if practicable.
• Make a complaint to a supervisory body which in the United Kingdom is the Information Commissioner’s Office. The ICO can be contacted through this link: https://ico.org.uk/concerns/

Access to information  

The Data Protection Act 2018 and the UK GDPR give you the right to access information held about you. We also encourage you to contact us to ensure your data is accurate and complete.

A subject access request should be submitted to [email protected]. No fee will apply once the UK GDPR comes into force unless we decide to exercise our right under the UK GDPR to request a fee for excessive or repetitive requests.

Changes to our privacy notice  

Any changes we make to our privacy notice in the future will be posted on our website. Please check back frequently to see any updates or changes to our privacy notice.

Contact  

Questions, comments and requests regarding this privacy notice are welcomed and should be addressed to [email protected].