PURPOSE OF THIS NOTICE

Last updated: 31^st January 2023

This notice describes how we collect and use personal data about you, in accordance with the General Data Protection Regulation (GDPR), the Data Protection Act [1998 OR 2018] and any other national implementing laws, regulations and secondary legislation, as amended or updated from time to time, in the UK (‘Data Protection Legislation’).

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

ABOUT US

Focus Management Consultants Limited (“Focus Management”, “FMCL”, “Focus”, “we”, “us”, “our” and “ours”) is a recruitment company.  We are registered in England and Wales as a limited liability partnership company under number: 2511268 and our registered office is at 10 Westminster Road, Macclesfield, Cheshire, SK10 1BX.

For the purpose of the Data Protection Legislation and this notice, we are the ‘data controller’. This means that we are responsible for deciding how we hold and use personal data about you. We are required under the Data Protection Legislation to notify you of the information contained in this privacy notice.

Details of how to contact us in relation to any data protection queries are noted at Contact Us, below.

HOW WE MAY COLLECT YOUR PERSONAL DATA

We obtain personal data in several ways, for example, when:

• you apply and upload your CV for a specific role advertised;
• at the point of registering as a user on Our website;
• you request a proposal from Us in respect of the services We provide;
• you contact Us by email, telephone or post (for example when you have a query about our services); or
• Or by completing online requests for information etc. We also utilise data collection devices, such as cookies.

Please be aware that We may also infer certain information about you from your expressed search preferences. We also collect from:

• our websites;
• the software applications made available by us for use on or through computers and mobile devices;
• cookies;
• publicly available information; and,
• other tools and applications.

HOW WE USE YOUR PERSONAL DATA

• to determine your suitability for Our jobs
• to contact you with vacancies we believe you may be interested in
• to provide confidential, anonymous statistics about Our users, customers and related site information to reputable third party companies. These statistics will include no identifying personal information.
• to provide you with job related email or text, which We believe, will be of interest to you
• Notify you of changes to the website
• Similar services which we may introduce in future

THE KIND OF INFORMATION WE HOLD ABOUT YOU

The information we hold about you may include the following:

• your personal details (such as your name and/or address, email address, telephone number(s), your nationality, your education and working career details, your IP address);
• information about the types of vacancies you may be interested in
• details of contact we have had with you in relation to the provision, or the proposed provision, of Our services;
• details of any services you have received from Us;
• our correspondence and communications with you;
• information about any complaints and enquiries you make to Us;
• information from research, surveys, and marketing activities;
• information We receive from other sources, such as publicly available information or information provided by your employer.

HOW WE USE PERSONAL DATA WE HOLD ABOUT YOU

We may process your personal data for purposes necessary and agreed in line with our commercial focus – namely finding appropriate people for Jobs.

The processes we follow will be in accordance with UK Law and be complaint with GDPR legislation.

We may process your personal data for the purposes of Our own legitimate interests provided that those interests do not override any of your own interests, rights and freedoms which require the protection of personal data.

We may use your personal data in order to:

• search and find you for vacancies We are working on.
• to support your application for a vacancy which you have given Us consent to represent you for.
• send you push notifications, text messages, alerts, emails or other types of messages directly sent to you.
• provide you with information related to Our services and Our events and activities that you request from Us or which we feel may interest you, provided you have consented to be contacted for such purposes;
• seek your thoughts and opinions on the services We provide; and
• notify you about any changes to Our services.

In some circumstances We may anonymise or pseudonymise the personal data so that it can no longer be associated with you, in which case We may use it without further notice to you.

If you refuse to provide Us with certain information when requested, We may not be able to perform the contract We have entered into with you. Alternatively, We may be unable to comply with our legal or regulatory obligations.

We may also process your personal data without your knowledge or consent, in accordance with this notice, where We are legally required or permitted to do so.

Data retention

We will only retain your personal data for as long as is necessary to fulfil the purposes for which it is collected.

When assessing what retention period is appropriate for your personal data, we take into consideration:

• the requirements of our business and the services provided;
• any statutory or legal obligations;
• the purposes for which We originally collected the personal data;
• the lawful grounds on which We based our processing;
• the types of personal data We have collected;
• the amount and categories of your personal data; and
• whether the purpose of the processing could reasonably be fulfilled by other means.

Change of purpose

Where We need to use your personal data for another reason, other than for the purpose for which We collected it, We will only use your personal data where that reason is compatible with the original purpose.

Should it be necessary to use your personal data for a new purpose, We will notify you and communicate the legal basis which allows us to do so before starting any new processing.

DATA SHARING

Why might We share your personal data with third parties?

We will share your personal data with third parties where We are required by law, where it is necessary to administer the relationship between Us or where We have another legitimate interest in doing so.

Which third-party parties may have access to your personal data?

“Third parties” includes third-party service providers. The following activities are carried out by third-party service providers: Our clients, IT and cloud services, Database providers, Job Boards and Websites, Linkedin.

All of Our third-party service providers are required to take commercially reasonable and appropriate security measures to protect your personal data. We only permit our third-party service providers to process your personal data for specified purposes and in accordance with our instructions.

What about other third parties?

We will not present your details to any third party without your consent.

TRANSFERRING PERSONAL DATA OUTSIDE THE EUROPEAN ECONOMIC AREA (EEA)

We may transfer the personal data We collect about you to certain countries outside of the EEA in order to perform Our contract with you.

There is an adequacy decision by the European Commission in relation to any country to which the personal data is transferred, therefore they will be deemed to provide an adequate level of protection for your personal information for the purpose of the Data Protection Legislation.

Should you require further information about please contact Us using the contact details outlined below.

DATA SECURITY

We have put in place commercially reasonable and appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.

Our security measures include:

• encryption of our services and data;
• We limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on Our instructions and they are subject to a duty of confidentiality.
• We review our information collection, storage and processing practices, including physical security measures.
• internal policies setting out our data security approach and training for employees.

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.

RIGHTS OF ACCESS, CORRECTION, ERASURE, AND RESTRICTION

Your duty to inform Us of changes

It is important that the personal data We hold about you is accurate and current. Should your personal information change, please notify Us of any changes of which we need to be made aware by contacting Us, using the contact details below.

Your rights in connection with personal data

Under certain circumstances, by law you have the right to:

• Request access to your personal data. This enables you to receive details of the personal data We hold about you and to check that We are processing it lawfully.
• Request correction of the personal data that We hold about you.
• Request erasure of your personal data. This enables you to ask Us to delete or remove personal data 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 data where you have exercised your right to object to processing (see below).
• Object to processing of your personal data 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 basis. 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 data. This enables you to ask Us to suspend the processing of personal data about you, for example if you want Us to establish its accuracy or the reason for processing it.
• Request the transfer of your personal data to you or another data controller if the processing is based on consent, carried out by automated means and this is technically feasible.

If you want to exercise any of the above rights, please email gdpr@fmcl.co.uk

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, We may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, We may refuse to comply with the request in such circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.

RIGHT TO WITHDRAW CONSENT

In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal data for a specific purpose (for example, in relation to your applications for job advertisements), you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please email gdpr@fmcl.co.uk

Once we have received notification that you have withdrawn your consent, We will no longer process your personal information (personal data) for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.

UPDATES TO THIS PRIVACY NOTICE

We may update this Privacy Notice from time to time in response to changing legal, technical or business developments. When We update our Privacy Notice, We will take appropriate measures to inform you, consistent with the significance of the changes we make. We will obtain your consent to any material Privacy Notice changes if and where this is required by applicable data protection laws.

You can see when this Privacy Notice was last updated by checking the date displayed at the top of this Privacy Notice.

CONTACT US

If you have any questions regarding this notice or if you would like to speak to Us about the manner in which we process your personal data, please email our Data Protection Point of Contact Maneeza Williams, Managing Director, gdpr@fmcl.co.uk or 01625 560778.

You also have the right to make a complaint to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues, at any time. The ICO’s contact details are: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, Telephone – 0303 123 1113 (local rate) or 01625 545 745, Website – https://ico.org.uk/concerns

COOKIE POLICY

This Cookie Policy explains how Focus Management Consultants Ltd (“we”, “us”, “our” “Focus”, “FMCL”) use cookies and similar technologies when you visit our website (“Site”).  It explains what these technologies are and why we use them, as well as your rights to control our use of them.

What are cookies?

Cookies are a small data file that are placed on your computer or mobile device when you visit a website. The data file can take a number of different forms, such as pixels, plugins, tags scripts and combinations of these technologies to allow ‘device fingerprinting’. Cookies use information that is transferred to or read from your device’s hard drive. Some cookies may collect personal data about you. You can find out more information about cookies and pixels on the Information Commissioner’s Officer (ICO) website (www.ico.org.uk).

Why are cookies used?

Cookies are widely used by website owners in order to make their websites work, or to work more efficiently, as well as to provide reporting information.  Some cookies are required for technical reasons in order for a website to operate, and are referred to as “essential” or “strictly necessary” cookies.  Other cookies enable website owners to track and target the interests of users to enhance the experience on the website.

Cookies used for advertising

Third-party vendors, including Google, use cookies to serve ads based on your prior visits to a website.  Google’s use of the DART* cookie enables it and its partners to serve ads to you, our visitors, based on your visit to our sites and/or other sites on the Internet.  You may opt out of the use of the DART cookie by visiting the advertising opt-out page.

*The DoubleClick DART cookie is used by Google in the ads served on the websites of its partners, such as websites displaying AdSense ads or participating in Google certified ad networks. When users visit a partner’s website and either view or click an ad, a cookie may be dropped on that end user’s browser. The data gathered from these cookies will be used to help better serve and manage ads on the publisher’s site(s) and across the web.

Cookies used for analysis

Cookies may be used to track your path across our Site, allowing us to see which pages you have viewed. This provides us with information that can help to make our website more efficient and better suit your needs.

How can I control cookies?

You have the right to decide whether to accept or reject cookies. The first time that you visit our Site, we notify you about our use of Cookies through a notification banner. By continuing to use our Site, you consent to our use of Cookies as described in this Cookie Statement. However, you can choose whether or not to continue accepting Cookies at any later time. Alternatively, you can set or amend your web browser controls to accept or refuse cookies. If you choose to reject cookies, you may still use our Site though your access to some functionality and areas of our Site may be restricted. As the means by which you can refuse cookies through your web browser controls vary from browser-to-browser, you should visit your browser’s help menu for more information. In addition, most advertising networks offer you a way to opt out of targeted advertising.

How often will you update this Cookie Statement?

We may update this Cookie Statement from time to time in order to reflect, for example, changes to the cookies we use or for other operational, legal or regulatory reasons. Please therefore re-visit this Cookie Statement regularly to stay informed about our use of cookies and related technologies.

Last updated: 31^st January 2023

Where can I get further information?

If you have any questions about our use of cookies or other technologies please e-mail contactus@fmcl.co.uk

GOOGLE STATEMENT

This Site uses Google Analytics, a web analytics service provided by Google, Inc. (“Google”). Google Analytics uses “cookies”, which are text files placed on your computer, to help the website analyse how users use the Site. The information generated by the cookie about your use of the Site (including your IP address) will be transmitted to and stored by Google on servers in the United States. Google will use this information for the purpose of evaluating your use of the website, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf. Google will not associate your IP address with any other data held by Google. You may refuse the use of cookies by selecting the appropriate settings on your browser, however please note that if you do this you may not be able to use the full functionality of this website. By using this Site, you consent to the processing of data about you by Google in the manner and for the purposes set out above.  To opt out of being tracked by Google Analytics across all websites visit http://tools.google.com/dlpage/gaoptout