Westworld Consulting Limited Privacy Statement
This Privacy Statement was first published 24th May, 2018
and last Updated on 1st September 2019
Westworld Consulting Limited (“Westworld”, “we“, “us” or “our“) respects your privacy and is committed to protecting your personal data. This privacy notice will explain how we look after your personal data and tell you about your privacy rights and how the law protects you.
1. Important Information And Who We Are
2. Our Contact Details
3. Why Do We Collect Your Data?
4. The Data We Collect About You
5. How We Use Your Personal Data
6. Ground For Processing
7. Who We Share Your Personal Data With
8. Your Rights
9. Data Retention
10. Data Security
12. International Data Transfers
1. Important Information & Who We Are
Westworld provides work finding services and acts as an outsourced business development agency for aerospace and defence businesses (“business client” or “business clients” in this policy). This privacy notice aims to give you information on how we clect and process your personal data in the context of the services that we provide.
As a business, we provide two primary services, the data we collect depends on the service we are providing and your relationship to us:
- For Business Development; Business Clients engage us to develop new business opportunities for them. To do so, we must collect data about and contact businesses that might be interested in our business clients’ products or services.
- For Work Finding Services (Recruitment); We provide work finding services for job seekers, and for companies that want to hire them (“recruitment client” or “recruitment clients” in this policy). To do so, we must process personal and occassionally sensitive personal data. This data is normally supplied via your C.V., Application form and/or any other documentation provided by you to verify your I.D., Right to Work in the UK, N.I. Number etc.
This policy explains the basis on which personal information we collect from you will be processed by us. Where we decide the purpose or means for which personal data supplied by you is processed, we are the “data controller.” We will comply with all applicable data protection laws, including the General Data Protection Regulation 2016/679.
This policy explains the following:
- Why we collect your data;
- What personal information we may collect about you;
- How we will use that information;
- Grounds for processing;
- Who we share your information with; and
- Your rights regarding the information.
We have appointed a data protection officer who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below.
2. Our Contact Details
Our full details are:
Full name of legal entity: Westworld Consulting Limited, a Private Limited Company registered In England And Wales with Company Number 8672769.
Our registered office: Bath House, 6-8 Bath Street, Bristol, BS1 6HL, United Kingdom
ICO Registration number: ZA551878
Name of Data Protection Officer: Robert Hooper
Email: dataprotection AT westworldconsulting DOT com
Postal address: 130 Aztec West, Almondsbury, Bristol, BS32 4UB
Telephone: +44 (0) 1454 629 628
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
3. Why Do We Collect Your Data?
We collect, or you may provide your information to us, for the following reasons:
- For Business Development; When we are acting on behalf of our business clients or ourselves, we collect, store and process the data of individuals within businesses that may benefit from either our or our business clients’ products or services.
- As Westworld For outreach and marketing purposes, we may contact you about a product or service that Westworld offers that we believe your company may be interested in. We will only contact you if we think that product or service is of interest to your business. This is generally based on your job title and type of organisation that you work for.
- Acting on behalf of a business client of Westworld For outreach and marketing purposes, we may contact you about a product or service that one of our business clients offer that we believe your company may be interested in. We will only contact you if we think that product or service is of interest to your business. This is generally based on your job title and type of organisation that you work for.
- For Work Finding Services As an individual, we will collect your personal data (which may include sensitive personal data) and will process your personal data for the purposes of providing you with work-finding services. This includes for example, contacting you about job opportunities, assessing your suitability for those opportunities, updating our databases, putting you forward for job opportunities, arranging payments to you and developing and managing our services and relationship with you and our recruitment clients.
4. The Data We Collect About You
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you, which we have group together as follows:
- Data for Business Development When we are trying to develop business opportunities for ourselves or our business clients we collect, store and process the data of individuals within businesses that may benefit from our clients’ products and services. We collect and process the following personal information: name, job title, business address, business telephone number (direct and mobile), business e-mail address and LinkedIn URL. The majority of the personal information we collect about you will you come from you publicly available online information or from you directly. We may also collect information on the phone or face-to-face. We do not hold special category data for business development purposes.
When deciding whether to contact you about a product or a service, we look at your job title and the sector you operate within. We primarily source our data from LinkedIn, Xing or Companies House (and other company registers in Europe) – which are publicly accessible. If we need to source further information, we may use Google. We may also collect data over the phone from representatives within businesses.
- Data for Work Finding Services Where we are providing work finding services, personal data may be collected or received in different ways such as:
- Applying for a Job Online
- Other sources including job boards that you have registered with and are a publicly accessible source of personal data for recruitment purposes.
Initially, examples of personal data that may be shared with us or collected include your;
- Contact details – such as name, addresses, telephone numbers and email addresses;
- CV/work history; and
- Job or work preferences;
Once we make contact with you to discuss opportunities that may lead to an engagement, further personal data may be shared such as:
- Date of Birth;
- ID/RTW documentation;
- National Insurance number;
- The outcome of third-party screening; (such as security clearance, criminal record checks);
- Financial information (including bank details, tax details, pension scheme); and
- Data of other parties relevant to you such as referees, emergency contact details and Next of Kin.
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with our services or submit your application for role we have advertised). In this case, we may have to cancel our services but we will notify you if this is the case at the time.
We may also collect technical information about your computer and/or device that may identify you, including your IP address and behaviour when you receive emails (e.g. whether you read the email, open it and forward it on to third recipients). We generally collect this from cookies.
5. How We Use Your Personal Data
- For Business Development; where we are undertaking business development services, we may from time to time decide to send you information by email, phone, Linkedin or post that we believe will be of interest to your role, if your company is likely to be interested in services of our clients’ or ourselves.
This information may include extracts of work done, or the opportunity to speak with our team to discuss services. If you are not interested in receiving these communications, please let us know.
- For Work Finding Services; The data we receive directly from you or via another source, such as a job board, is only used for the purposes for which it was provided or received. This is essentially for the purposes of either providing recruitment services to you based on Westworld acting as an agency/employment business or to engage you to work for Westworld directly. The data may be used to;
- match your skills and experience with current available opportunities either with our Clients or directly with Westworld;
- to provide you with information about other opportunities that are similar to those that you have already enquired about;
- to submit your details to our clients or internal departments;
- to ascertain that you have the right to work;
- to carry relevant security and/or criminal record checks as may be required;
- to engage you on a suitable contractual arrangement; and
- to pay you for work carried out.
6. Grounds of Processing
We must have a legal basis to process your personal data. The legal basis we rely upon to undertake our business development and work-finding services are:
- Your consent
- Where we have a legitimate interest
- To comply with a legal obligation that we have
- To fulfil a contractual obligation that we have with you
Should we at any time be required to collect and hold any special category personal data, we will request your consent prior to any processing of that data.
On some occasions, Westworld processes your data with your consent. You have the right to withdraw consent at any time. Where consent is the only legal basis for processing, we will cease to process data after consent is withdrawn.
Generally, Westworld processes your personal information based on legitimate interest and when these interests are not overridden by your data protection rights. This is where we have a legitimate reason to process your data provided it is reasonable and does not go against what you would reasonably expect from us. Where we have relied on a legitimate interest to process your personal data our legitimate interests is/are as follows:
- For Business Development
- Westworld acts as an outsourced business development function for our business clients. Our offering involves connecting our business clients with businesses that may benefit from their products or services. Therefore, we have a legitimate interest in contacting relevant businesses (and individuals within those businesses) on behalf of our business clients as they may benefit from the products or services of our business clients’.
- If you are a prospective business client of Westworld, we may process your data where we believe that your business may benefit from the services of Westworld (based on your job title and the sector that your business operates in). As we are a business that provides business development services we have a legitimate interest in approaching potential clients who may benefit from our services.
- Work Finding Services
- Providing work-finding services to you and our clients;
- Managing our database and keeping work-seeker records up to date;
- Contacting you to seek your consent where we need it;
- Giving you information about similar products or services that you have used from us recently;
- Managing your application, screening, and selection process for suitable assignments;
- Providing your details to nominated third party agencies or bodies for the purposes of pre-assignment screening;
- Managing any subsequent contract of engagement;
- Contacting you by phone or email about potential future assignments.
To comply with a legal obligation that we have
In some cases, we may be required to use your data for the purpose of investigating, reporting and detecting crime and also to comply with laws that apply to us. We may also use your information during the course of internal audits to demonstrate our compliance with certain industry standards.
Necessary to fulfil a contract
Westworld may process your data when we need to do this to fulfil a contract with you and when we have certain legal and contractual requirements to collect personal data (e.g. to comply with the Conduct of Employment Agencies and Employment Businesses Regulations 2003, immigration and tax legislation, and in some circumstances safeguarding requirements.) Where we are providing work finding services, our clients may also require this personal data, and/or we may need your data to enter into a contract with you. If you do not give us the personal data we need to collect we may not be able to continue to provide work-finding services to you.
7. Who we share your personal data with
Access to personal information within Westworld and our group of companies is restricted to those individuals who have a need to access the information as part of their job function.
- For Work Finding Services; For the purposes of progressing your job application we may share your personal data with;
- Clients (whom we may introduce or supply you to);
- Former employers whom we may seek references from;
- Approved Intermediary/Umbrella companies (who you may be engaged through);
- Payroll service providers who manage payroll on our behalf or other payment intermediaries whom we may introduce you to;
- Other recruitment agencies in the supply chain
- Government agencies (such as HMRC, UK Border Agency, DBS);
- External screening providers (where personal checks are required to be carried out);
In addition, we may share your data with:
- Service providers acting as processors based inside and outside the EU who provide IT and system administration services.
- Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the EU who provide consultancy, banking, legal, insurance and accounting services.
- HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom.
- Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
7. Your Rights
Please be aware that you have the following data protection rights:
Request access to your personal data (commonly known as a “data subject access request”).This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
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 successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
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 ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain services to you. We will advise you if this is the case at the time you withdraw your consent.
If you wish to exercise any of the rights set out above, please contact us.
No fee usually required
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 is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
8. Data Retention
Westworld will retain your personal data only for as long as is necessary for the purpose we collect it and will endeavour to erase your personal data at the end of the relevant retention period. All businesses must keep personnel and financial records in order to run their business efficiently and to comply with statutory and or client requirements. Different laws may require us to keep different data for different periods of time. For example, the Conduct of Employment Agencies and Employment Businesses Regulations 2003, require us to keep work-seeker records for at least one year from (a) the date of their creation or (b) after the date on which we last provide you with work-finding services.
We must also keep your payroll records, holiday pay, sick pay and pensions auto-enrolment records for as long as is legally required by HMRC and associated national minimum wage, social security and tax legislation. This is currently 3 to 6 years.
- Data Retention for Business Development Services; up to 5 years since the last contact was made with you. Contact means where we have had verbal or written communication with you in relation to business-to-business sales on behalf of Westworld or one of our business clients.
- Data Retention for Work Finding Services
- For prospective candidates – up to 5 years since the last contact made with you. Contact means where we have had a verbal or written communication with you or where you have applied for a job directly, via our website or through a third party job board and you have been added to our database.
- For engaged workers – up to 7 years following the last payment made to you. Engaged workers means candidates who we have successfully placed into a role either for a client or directly with Westworld.
10. Data Security
Westworld is committed to keeping your personal data safe and secure from unauthorised access to or unauthorised alterations, disclosure or destruction of information that we hold.
Only employees who need the information to perform a specific job (for example, business development managers may have access to personal data related to business-to-business sales and recruitment mangers may have access to personal data related to work finding services) are granted access to your information.
We will take all reasonable technical and organisational precautions to prevent the loss misuse or alteration of your personal information and to safeguard it. However, you should be aware that the use of email/ the Internet is not entirely secure and for this reason we cannot guarantee the security or integrity of any personal information which is transferred from you or to you via email/ the Internet.
Our security measures include:
- Hashing and encryption of our services and data;
- Regular review of information collection;
- Encryption of our services and data;
- Restricted access of data to employees, contractors and agents; and internal policies setting out our data security. Please be aware that, although we endeavour to provide reasonable security for information we process and maintain, no security system can prevent all potential security breaches.
11. International Data Transfers
Your Personal Information which you supply to us is generally stored and kept inside the European Economic Area, however due to the nature of our business and the technologies required, your Personal Information may be transferred to third party service providers outside the EEA, in countries where there may be a lower legal level of data protection. Where this is the case we will take steps to ensure adequate protections are in place to ensure the security of your information. The EEA comprises the EU member states plus Norway, Iceland and Liechtenstein.
We will notify you of any changes to this policy by email or notice on our website.
This version was last updated on 1 September 2019.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
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If you would like further information, please contact us at:
Email: info AT westworldconsulting DOT com
Phone: +44 (0)1454 629 628