Privacy Policy

Welcome to the Winners Recruitment Ltd.’s privacy notice.

This Privacy Notice sets out the basis on which Winners will process personal information provided to us, this information is also referred to as ‘personal data’.

We take our obligations in respect of the privacy of personal data very seriously and we will only process personal information as detailed in this notice, unless we inform you otherwise. To ensure that the personal data we hold is accurate and up to date, we request that you inform us of any relevant changes to the personal information that we hold about you.

We help individuals to find work (either permanent or temporary) and we are also an employer. Our business activity is recruitment, whether this is directly or through supply by us and we assist hirers in introducing or supplying the staff that they require. We also recruit staff to work for us to provide our recruitment services. For this Privacy Notice, our commercial activities and services for individuals and businesses are referred to as ‘Recruitment Services’, and our actual or potential hiring customers are referred to as ‘Clients’.

Our Data Protection Officer is James Prentice, and can be contacted on 01872 264744.

If you do not wish us to process personal data per this policy, then please do not provide it to us. Please refer to Section 4 ‘Your rights’, in respect of the data that we already hold or which we receive from third parties.

Section 1

This section applies to individuals wishing to use or using our Recruitment Services or looking for a role to work with us (‘a Candidate’)

The personal data we collect or receive includes the following as applicable:

  • Name
  • Address
  • Email or other contact details
  • Date of Birth
  • Job History
  • Educational history, qualifications and skills
  • Visa and other rights to work documents or identity information
  • Passport
  • Bank Details
  • National Insurance and tax (payroll) information
  • Next of kin and emergency contact details
  • Contact details of referees
  • Information contained in references and pre-employment checks from third parties.
  • Other sensitive personal information such as health records (see ‘Sensitive Personal Data’ section below.

We may obtain your date from the following sources (please note this list is not exhaustive):

  • You (e.g. a curriculum vitae, application or registration form)
  • A client
  • Other candidates
  • Online job sites
  • The public domain
  • Social Media
  • At the interview
  • Conversations on the telephone or video conferencing
  • Notes following a conversation or meeting
  • Our website software applications

Where you are a Candidate and we have obtained your data from a third party such as an online job board, it is our policy to advise you of the source when we first communicate with you.

How we will use your data

The processing of your personal information may include:

  • Collecting and storing your data, whether hard copy or electronic files
  • Notifying you of potential roles or opportunities
  • Assessing and reviewing your suitability for job roles
  • Introducing and or supplying you to actual or potential clients
  • Engaging you for a role with us or with our Clients including any related administration e.g. timesheets and payroll
  • Collating market or sector-specific information and providing the same to our clients
  • Sending information to third parties with who we have or intend to enter into an arrangement which is related to our Recruitment Services.
  • Providing information to regulatory authorities or statutory bodies, and our legal or other professional advisers including insurers
  • To market our Recruitment Services
  • Retaining a record of our dealings
  • Establishing quality, training and compliance to fulfil our obligations and best practice
  • To back up information on our computer systems.

Why we process your data:

1. Entering into and performing a contract with you:

To provide our Recruitment Services, we may enter into a contract with you and/or a third party. To enter into a contract, we will need certain information, for example, you name and address. A contract will also contain obligations on both your part and our part and we shall process your data as is necessary for those obligations. For example, to process payroll, a national insurance number and bank details will be required.

2. Compliance with legal obligations (regulatory and statutory obligations)

We must comply with several statutory provisions when providing our Recruitment Services, which necessitates the processing of personal data. These include the Conduct of Employment Agencies and Employment Businesses Regulations 2003, which amongst other things requires us to

  • Verify your identity
  • Assess your suitability of external job role
  • Maintain records for specific periods

Where we engage a person to work for us (whether directly or as supplied to a client) other statutory obligations must be complied with including payroll, tax, social security, HMRC reporting requirements and any other law or regulation.

We are also required to comply with statutory and regulatory obligations relating to business generally, for example complying with tax, bribery, fraud, crime prevention and data protection legislation, and co-operating with regulatory authorities such as HMRC or Information Commissioners Office.

3. Our Legitimate Interest (carrying on the commercial activity of Recruitment Services):

In providing our Recruitment Services, we will carry out some processing of personal data which is necessary for our legitimate interest, which include: Retaining records of our dealings and transactions and where applicable, use such records for:

  • Establishing compliance with contractual obligations with Clients or suppliers
  • Addressing any query or dispute that may arise including establishing, exercising or defending any legal claims
  • Protecting our reputation
  • Maintaining a back up of the system, solely to be able to restore the system to a point in the event of a system failure or security breach
  • Evaluating quality and compliance including compliance with this Privacy Notice
  • Determining staff training and system requirements

Using your data to:

  • Assess suitability and contact you regarding potential opportunities and /or services
  • collate market information or trends including providing analysis to potential or actual clients
  • Source potential opportunities or roles as part of our Recruitment Services
  • Personalise your experience and our offering, whether via our website or otherwise.
  • This means that our commercial viability and to pursue the legitimate interests, we may continue to process your data for as long as we consider necessary to these purposes.
Purpose/ActivityType of DataLawful basis for processing including the basis of legitimate interest
To register you as a new candidate for work-finding services or when you make an employment application to usIdentityContact detailsEvidence of your right to work in the UKCVReferencesUnspent criminal/motoring convictionsFulfil a contract with you or with the potential employer
To provide you with work-finding services including sending your details of available job opportunities and job alert emails following your job search preferences and criteria, providing career advice, providing your CV to clients concerning their job vacancies, paying your wages (if you are a temporary worker) and charging clients for placements we makeIdentityContact DetailsFinancial DataFulfil a contract (Candidate Agreements and client contracts)Legitimate InterestsLegal or regulatory duty
Disclosing your personal information to governments and law enforcement agencies and our appointed 3rd party vendorsIdentityContact detailsEvidence of your right to work in the UKCVReferencesUnspent criminal/monitoring convictionsLegitimate InterestYour consent
To manage our relationship with you includingNotifying you about changes to our Candidate Agreement or Privacy NoticesAsking you to leave a review or feedback or complete a surveyAdministration and IT services connected with representing you for roles, placing you in temporary assignments to work for our clients, processing timesheets, payroll and other payments, tax deductions, issuing payslips etcIdentityContactProfile/SurveyFulfil a contractLegal or regulatory dutyLegitimate interests (keeping our records up to date and to study how candidates and potential candidates and visitors to our website use our services and website, to develop and improve them and to grow our business
Keeping your Personal Information secure to prevent it from being lost, used, accessed disclosed or altered in any wayIdentityContactEvidence of your right to work in the UKCVRefereesUnspent criminal/motoring convictionsLegal or regulatory dutyLegitimate InterestsFulfil a contract
To investigate issues, disputes and complaints between us and between us, you and our clients to seek to resolve themIdentityContactProfileLegitimate InterestFulfil a contract
To administer and protect our business and our website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)IdentityContactTechnical DataLegitimate interestsLegal or regulatory duty
Retaining your Personal Information for as long as necessary for providing you with work-finding servicesIdentityContact DetailsEvidence of your right to work in the UKCVRefereesUnspent criminal/motoring convictionsLegitimate interestsLegal or regulatory duty
To help us respond to queries, complaints or for other reasons such as responding to requests from regulators, government and law enforcement agencies such as the PoliceContactLegitimate InterestLegal or regulatory duty

4. Consent to our processing of your data

We may process your data on the basis that you have consented to us doing so for a specific purpose, for example, if you apply to a specific role you may have consented to our processing of the data that has been provided for progressing your application and considering your suitability for the role. In other cases, you may have provided your written or verbal consent to the use of your data for a specific reason.

You may withdraw your consent to our processing of your personal information for a particular purpose at any stage. However, please note that we may continue to retain or otherwise use your personal information thereafter where we have a legitimate interest or a legal or contractual obligation to do so. Our processing in that respect will be limited to what is necessary for the furtherance of those interest or obligations. Withdrawal of consent will not have any effect on the lawfulness of any processing based on consent before its withdrawal.

What if we obtain your data from a third party

Part of our business activity involves researching information relating to individuals to find and fill job roles. This may include obtaining personal data from online sources, for example, we may obtain information from social media sites such as LinkedIn and job boards, some information being publicly available but others being from sites or providers to which we subscribe. From time to time we may also receive personal information about you from hiring organisations, colleagues and former employers, or from the person for whom you have provided services or been otherwise engaged.

Where information for this party is of no use to us. Or where you have notified us that you do not want us to provide you with services, we shall discard it, however, we may maintain a limited record to avoid the duplication of process. Where we consider that information may be of use to us in pursuance to the provision of our Recruitment Services, any processing will be under this Privacy Notice. You do have the right to object to processing, please see Section 4 your rights.

Sensitive Personal Data (SPD)

Sensitive Personal Data is information which is intensely personal to you and is usually irrelevant to our consideration of your suitability for a job role. Examples of SPD include information which reveals your political, religious or philosophical beliefs, sexual orientation, race or ethnic origin or information relating to your health.

Regardless of the basis for your dealings with us, we request that you do not provide us with any sensitive personal data unless necessary. However, to the extent that you do provide with any sensitive personal data, such as data which you choose to share with us in conversation, we shall only use that data for our relationship with you or the provision of our Recruitment Services. This will be for more one or more of the following reasons:

  • You have explicitly consented to the processing
  • For our assessment of your suitability for job roles or working capacity
  • Where the processing is necessary for obligations or rights under employment or social security or social protection law
  • To maintain records of our dealings to address any later dispute, including but not limited to the establishment, exercise or defence of any legal claims.

Who we share your data with:

We will not share your personal information unless we are entitled to do so. The categories with whom we may share your personal information include:

  • Individuals, hirers and other third parties for the provision of our recruitment services
  • Any regulatory authority or statutory body under a request to information or any other legal obligation which applies to you
  • Parties who process data on our behalf which may include
  • Outsources payroll providers
  • IT Support
  • Storage service providers including cloud
  • Legal and professional advisers
  • Insurers

Automated decisions

We do not use any automated decision-making software

Section 2:

This section applies where you are an individual working for a third party with whom we have dealings. For example, a client or a payroll company.

We may collect your data during our dealings and this may include the following:

  • Your contact information, which may include your full name, job role, contact telephone number and email.
  • Your statements and opinions about candidates and or personnel e.g. a reference
  • Information relating to our relationship with you or the party for whom you work including records of any meetings or discussions

We may collect your data from the following sources (please note this list is not exhaustive):

  • You, where you have provided us with your contact details or other information to use our Recruitment Services
  • Staff or other representatives of the organisation you represent
  • Candidates
  • Marketing databases
  • Social Media
  • The public domain
  • Conversations with you or others on the telephone or in meetings
  • Notes following a conversation, with you or others, or meetings that you attend.

How we will use your data:

We will process your data in the context of our dealings with the third party for whom you work and as part of our Recruitment Services. Processing may include:

  • Collecting and storing your data, whether in hard copy or electronic files
  • Using the data to communicate with you
  • Sending information to third parties with who we have or intend to enter into an arrangement which is related to our Recruitment Services.
  • Actions necessary to further any obligation on us according to a contract between ourselves and the third party that you work for.
  • Providing information to regulatory authorities or statutory bodies, and our legal or other professional advisers including insurers
  • Retaining a record of our dealings with you and the organisation whom you represent
  • Establishing quality, training and compliance with our obligations and best practice

Section 3 This Section applies to all personal data

Data Security

We have put in appropriate security measures to prevent your data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. Also, we limit access to your data to those employees, agent’s contractors and other third parties who have a business need to know. They will only process our data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedure to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

Data retention

We will only retain your data for as long as necessary to fulfil the purposes we collected it for, including to satisfy any legal, accounting, or reporting requirements.

To determine the appropriate retention period of personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your data, the purposes for which we process your data and whether we can achieve those purposes through other means and applicable legal requirements.

By law, we have to keep basic information about clients and candidates for 6 years after they cease being a customer or candidate for tax and contractual purposes.

Section 4 Your Legal Rights

We take the protection of your data very seriously and it important that you know your rights within that context which include:

  • The right to be informed about the personal data the Company processes on you;
  • The right of access to the personal data the Company processes on you;
  • The right to rectification of your data;
  • The right to the erasure of your data in certain circumstances;
  • The right to restrict the processing of your data;
  • The right to data portability in certain circumstances;
  • The right to object to the processing of your data that was based on public or legitimate interest;
  • The right not to be subjected to automated decision making and profiling; and
  • The right to withdraw consent at any time.

Where you have consented to the Company processing your personal data and sensitive personal data you have the right to withdraw that consent at any time by contacting the Data Protection Officer or any other representative of the Data Controller (in this case Winners Recruitment).

Section 5: Complaints or queries

If you wish to complain about this privacy notice or any of the procedures set out in it, please contact Winners Recruitment on 01872 264744. You can speak to any member of the team as they are all representatives of the Data Controller or the Data Protection Officer, James Prentice.

You also have the right to raise concerns with Information Commissioner’s Office on 0303 123 1113 or at, or any other relevant supervisory authority should your data be processed outside of the UK, if you believe that your data protection rights have not been adhered to.