PROSPECTIVE CANDIDATE / CANDIDATE, CLIENT AND SUPPLIER PRIVACY NOTICE (UPDATED 22/05/18)
Our Privacy Notice describes the ways we collect your personal information and governs how we will deal with it. We aim to ensure that any personal information we obtain and use will always be held, used and transmitted in compliance with the Data Protection Act 1998 (or its successor) and the EU General Data Protection Regulations (together referred to as the ‘Data Protection Laws’)
Where this Privacy Notice contains hyperlinks to our website, we recommend you click on those links as they may contain additional important details about our Data Protection Policy. Ganymede Solutions Ltd (Ganymede) is part of the RTC Group of companies.
The website containing this Privacy Notice may contain links to third parties’ websites. Ganymede Solutions Ltd assumes no responsibility for the privacy practices or the content of those websites. Therefore, please read carefully any privacy policies on those websites before either agreeing to their terms or using those websites.
This Privacy Notice applies with immediate effect to all Personally Identifiable Information collected either in person, through the Ganymede Solutions Ltd website, or any other means.
Ganymede Solutions Ltd may occasionally amend this Privacy Notice to reflect regulatory requirements and changes in our information collection and disclosure practices. Any new Privacy Notice will automatically be effective when it is published on the website or issued to you directly. We also advise you to print a copy for your records.
The RTC Group Data Protection Representative has overall responsibility for ensuring that this notice is applicable, compliant and in accordance with the RTC Group Data Protection Policy. The Ganymede Compliance Manager acting as the Ganymede Data Projection Representative (DPR) is responsible for ensuring that the contents of the Notice are implemented on behalf of the company.
All staff of Ganymede who interact with data subjects are responsible for ensuring that this notice is drawn to the data subject’s attention and where applicable, their consent to the processing of their data is secured.
3. Privacy Notice
3.1 Who are we?
Ganymede Solutions Limited is part of the RTC Group.
Ganymede specialise in supplying large, trained workforces to undertake safety critical work across the infrastructure sector.
With 20 years of experience, we are experts in delivering complex labour logistics and managing change. We attract, source and deploy candidates on both short and long-term assignments while supporting the infrastructure sector replenish indigenous skills through retraining programmes and apprenticeship schemes.
We believe in creating open and honest relationships with our clients and we keep safety at the heart of everything we do. This enables us to deliver safe, reliable and efficient solutions exactly when it’s needed.
As part of the RTC Group, Ganymede combines over 20 years’ experience of approved supply with 38 years of specialist technical selection. We work in line with our core values and strive to add value in all we do.
As part of our commitment to protecting our candidates, employees, clients, suppliers and third-parties’ data, we have implemented a stringent Information Security Management system to protect both the security and integrity of the data we process.
As part of our commitment to managing individual’s rights, we have appointed a Data Protection Representative, responsible for all Data Protection activities, to work alongside the RTC Group Data Protection Representative.
Our Ganymede Data Protection Representative (DPR) can be contacted directly here: DPR@ganymedesolutions.co.uk
3.2 What information do we collect?
The personal data we would like to collect on you is detailed below:
|Personal data type:||Source||Legal Basis|
|Contact Name, Social Media profile (In the public domain), Job title, previous experience)||Social Media Profiles / third-party Job Boards||Legitimate Interest / Contract|
|Contact Information, such as name, address and telephone number||Your submitted CV or details via direct communication with our staff members, our website / third-party Job Boards/ telephone, business development sources, referrals, supplier details||Legitimate Interest / Contract|
|Online contact information, such as your email address,||Social Media Profiles / Your submitted CV or details via our website / third-party Job Boards, business development sources, referrals, supplier details||Legitimate Interest / Contract|
|A copy of your CV||Social Media Profiles / Your submitted CV or details via our website / third-party Job Boards||Legitimate Interest / Contract|
|Other personal information such as your preferred employment requirements||Your submitted CV or details via our website or personal interaction||Legitimate Interest / Contract|
|Personal health data that may be required from an occupational health screening perspective to confirm suitability for a role.||Personal interaction, website form, CV||Legitimate Interest / Contract / Consent|
|Right to work in the UK or required region||Personal interaction/ submitted document(s)||Legitimate Interest / Contract|
|Details pertaining to our Equality and Diversity policies||Personal interaction / Our Website||Consent|
|Navigation and click-stream data, the time of accessing the website, duration of your visit, pages and job vacancies you viewed or searched for||Our Website||Legitimate Interest / Contract|
|Information from cookies or web beacons.||Our Website||Legitimate Interest / Contract|
|Your requested restrictions on our data processing such as preferred employers||Personal interaction / Your submitted CV or details via our website||Legitimate Interest / Contract|
|Your Subject Access Requests||Personal Interaction / email / telephone conversation / in writing.||Legitimate Interest / Contract|
It may be necessary for us to collect data, which under Data Protection Law is classified as Special Categories of Personal Data.
The special categories of personal data referred to within the EU GDPR are;
- Ethnic origin
- Political opinions
- Religious beliefs
- Philosophical beliefs
- Trade union membership
- Genetic data
- Biometric data
- Health data
- Data concerning a natural person’s sex life
- Sexual orientation
It is anticipated that the only Special categories of personal data required from a job seeker will be for the purposes of Health Screening in very specific circumstances, in accordance with our Equality and Diversity policy where it will be anonymised and where authorised by Law, Criminal Record checks.
Consent will always be sought prior to this data being stored and processed.
3.3. How we collect your information if you are a job seeker or prospective job seeker
Ganymede obtains information from you in the following four ways:
a) Personal Interaction – If you wish to apply for a vacancy by visiting our office or having a conversation with one of our staff members, we may ask you for your contact information and/or CV details and/or job specification details.
b) Submitting your details – If you wish to apply for a vacancy online or submit your details to one of our staff members, we may ask you for you your contact information and/or CV details and/or job specification details as you proceed through the stages of the contact form or the conversation.
d) Information from third parties – Ganymede may also obtain information about you directly from third parties, such as third-party job boards, social media sites and CV websites and online qualification and competency systems such as Sentinel. Ganymede will use this information to update our database records. If we have found your details on a social media website or if you have been referred to us, your data will only be retained during the process of establishing your consent for us to contact you. If you do not grant permission, your details will be removed from our systems.
3.4 How we collect your information if you are a client, prospective client, supplier or prospective supplier
Ganymede obtains information from you in three ways:
a) Submitting your details – If you submit your details to us as a contact to enable us to manage a contractual obligation or provide information on our services or your products / services.
c) Information from third parties – Ganymede may also obtain information about you directly from third parties, such as social media sites, referrals, your own company website. If we have found your details via a third party, and we do not require them for contractual purposes they will only be retained during the process of establishing your permission for us to contact you.
Independent of how we collect your data, we will always ensure that you have access to the relevant Privacy Notice.
If we have gathered your information from a third-party we will always seek authorisation from you to store and process your data.
If you want to disable cookies you need to change your website browser settings to reject cookies.
3.5 What will we do with your information if you are a job seeker or potential job seeker?
We will process and store your information for any or all of the following purposes;
Whilst on assignment
The principal purposes for which we collect and store your personal information is to meet our contractual obligations, whilst you are engaged by us, and / or whilst we are your Primary or Secondary Sponsor.
During the provision of job seeking activities.
Ganymede may collect and store your personal information in order to process your job applications, respond to your enquiries, get in touch with you about other possible job opportunities and generally maintain the information you hold with us, together with improving our website. You will be given the opportunity to restrict this use at any time.
To validate competency and suitability
Ganymede may collect and store your personal information and validate it against external third party competency / experience management systems.
To assist with marketing of Ganymede services
In order to ensure that we provide you with the best possible employment and employment opportunities and our client with the best possible service, we may also use your data for marketing purposes.
Occasionally, Ganymede may contact you by telephone for the purposes of market research, marketing our services (and for telemarketing) where you have consented to us doing so. You are under no obligation to participate in the call.
In addition, we may use an IP address to identify you and to gather broad demographic information about you, which may be used to assist Ganymede in market segmentation activities, to help identify problems with our server and to administer our website.
3.6 What will we do with your information if you are a client / supplier or potential client / supplier.
We will process and store your information for any or all of the following purposes;
- To meet contractual obligations
- To carry out new business development activities by offering you Ganymede services or products
- To procure / assess possible services or products that could lead to a contractual engagement.
Contractual Obligations – The principal purposes for which we collect and store your personal information are to meet contractual obligations. In order to provide our services in an effective and efficient manner we need to ensure that we have the correct communication channels. This is managed through keeping a record of contact positions, email addresses, telephone numbers and business addresses.
New Business Development – Occasionally, Ganymede may contact you by telephone or email to inform you of our services and capabilities with the intention of developing new business. In addition, we may use an IP address to identify you and to gather broad demographic information about you, which may be used to assist Ganymede in market segmentation activities. If you do not object to receiving marketing material at the time the information was collected from you, but subsequently change your mind and no longer wish to receive this information, you can opt out.
Service / Product Procurement – Ganymede may retain personal contact information in order to establish a supply chain of services or products required to ensure that Ganymede continues to provide an effective and efficient recruiting solution for our clients.
3.7 Sharing with Third-Parties
Ganymede will not sell your personal information to third parties. However, on occasions it is necessary for us to share personal information with third parties as described below for the purposes described above.
|Third-Party||Data and Purpose|
|RTC Group||Ganymede is part of the RTC Group Plc family of companies. We will share your information with the RTC Group in order to meet our contractual and legal obligations, including those required for insurance and payroll. We may also provide your details to another of the RTC Group companies if we feel it is in your best interest with respect to job seeking.|
|Website analytics providers||Ganymede collates statistics about site traffic, sales and other commercial information. This information is collected through third parties to assist us in improving the services we provide to you. We also use demographic information to tailor the website to the interests of our work seekers and clients, which we share with third parties, again on an aggregate basis only so that they can build up a better picture of our customer base and general consumer trends.|
|Recruitment and Communications Software||Ganymede may require to store or process your data with third parties as is necessary to process your application for a particular role.|
|Competency and Experience validation||Ganymede may share your information with industry specific safety systems to ensure your safety whilst on assignment.|
|Legal entities||Ganymede may disclose your personal information if necessary to comply with regulations or law or to assist with law enforcement, to enforce the terms under which you are contracted with Ganymede or to protect our or other third parties property and other rights.|
|Third-Party Recruiter/ Job board||You may have accessed our website via a hyperlink from another job board. Your personal details including behavioral patterns, may be shared between Ganymede and that third-party.|
|Successor||In the event that Ganymede is sold, or some of its assets transferred to a third party, your personal information, as a valuable asset of the company, may also be transferred. However, use of your personal information will remain subject to this Privacy Notice. Similarly, your personal information may be passed on to a successor in interest in the event of a liquidation or administration of Ganymede.|
Where possible all data processors will be within the EEA. If it is a requirement to transfer data outside of the EEA, this will be in accordance with 3.8 Transferring Data outside of the EAA.
3.8 Transferring outside of the European Economic Area (EAA)
Ganymede will only transfer data outside of the EAA if necessary.
Ganymede do not currently transfer your Data outside of the European Economic Area. However should there be a general business requirement to do so, we will record the details in the table below and re-issue this Privacy Notice.
|Third country (non-EU)/international organisation||Safeguards in place to protect your personal data||Retrieve a copy of the safeguards in place here:|
Should we be required to pass your information onto a country outside of the European Economic Area on an individual basis, we will seek your permission to do so.
3.9 Consent, Permissions and Contractual Obligations
For the purposes of this Privacy Notice, Ganymede refer to Consents, Permissions and Contractual Obligations.
The difference between consent and permission can be seen below;
Consent; requires a physical record from yourself.
Permission; can be granted by you and recorded by a Ganymede representative.
By submitting your CV, applying for a specific role, or by providing your details, you are giving us permission us to retain your details in accordance with this Privacy Notice.
If we have been provided with your details via a third-party, we will seek your permission prior to starting the recruitment process. Should this permission not be granted, upon your request, we shall remove your details from our system.
By allowing Ganymede to act as your sponsor, or by entering into a contract with us to place you on assignment you are agreeing to Contractual Obligations, which will be implemented in accordance with this Privacy Notice.
Should you request that we refrain from contacting you in the future, we will, with your permission, retain and restrict minimal information to which we can record a note of your restrictions.
Ganymede will seek formal consent if data is to be used for the following activities;
- Processing of EU GDPR defined Special Categories of Personal Data, ( I.e. Any data associated with Health, or our Equality & Diversity Commitment).
- Adding of your contact details to a marketing list that is different from the uses stated in section 3.4 and 3.5 of this Privacy Notice and you contract.
Where we are asking you for special categories of personal data we will always tell you why and how the information will be used. You may withdraw consent or permission at any time by contacting us at firstname.lastname@example.org
In the event that you are not already entered into a formal contractual agreement with us, the following permissions will be asked when you submit your CV/application to our website or during the initial engagement with a Ganymede staff member.
|Would you like us to continue to contact you about possible job opportunities?||☐||☐|
|Would you like to receive periodical emails about industry news and opportunities?||☐||☐|
3.10 Profiling and Automated processing
Automatic profiling is also employed whilst establishing suitability for assignments using information stored on third-party competency and training management systems.
Ganymede may utilise automatic profiling to establish whether a candidate meets the minimum requirements of job application or assignment. The exact details of these decisions can be made available upon request.
3.11 Retention period
Ganymede will keep your information for the longer of the period required in order to meet our business, legal or regulatory responsibilities. Ganymede will process, store and dispose of Personal Data in line with our Document Control and Record Retention Procedures.
3.12 How will we contact you?
We will contact you in the following circumstances;
|If you submit your details to our website in response to a particular job advertisement.||Telephone or email in the first instance.||To inform you of the status of your application and to further the conversation.|
|If you submit your details on a speculative basis to our website.||Telephone or email in the first instance.||To further the conversation and to find out more about how we can help you seek work.|
|If we receive a referral||Telephone, email or social media where appropriate.||To find out if you are content to be referred, communicate our Privacy Notice and to confirm permissions if appropriate.|
|If you visit one of our offices and apply for a post or request us to act as a sponsor.||Telephone or email in the first instance.||To confirm suitability and availability and provide information on relevant assignments.|
|If we find your details on Social Media and think that you may be suitable for a current opportunity.||Social Media, email and telephone.||To find out if you are content to be referred, communicate our Privacy Notice and to confirm permissions if appropriate.|
|If we receive your CV or contact details through a third-party job board / website||Telephone or email in the first instance.||To find out if you are content to be contacted, to communicate our Privacy Notice and to confirm permissions if appropriate.|
|If we believe that we can legitimately assist your recruitment requirements.||Telephone or email in the first instance.||To offer our services|
|If we believe that we have a need for your products or services.||Telephone or email in the first instance.||To request information about services or products or to engage in contract negotiations.|
|If we require to contact you for contractual reasons.||Telephone or email in the first instance.||To implement a contractual requirement.|
3.13 Your rights as a data subject
At any point while we are in possession of or processing your personal data, you, the data subject, have the following rights:
- Right of access – you have the right to request a copy of the information that we hold about you.
- Right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete.
- Right to be forgotten – in certain circumstances you can ask for the data we hold about you to be erased from our records.
- Right to restriction of processing – where certain conditions apply to have a right to restrict the processing.
- Right of portability – you have the right to have the data we hold about you transferred to another organisation.
- Right to object – you have the right to object to certain types of processing such as direct marketing.
- Right to object to automated processing, including profiling – you also have the right to be subject to the legal effects of automated processing or profiling.
- Right to judicial review: in the event that Ganymede refuses your request under rights of access, we will provide you with a reason as to why. You have the right to complain as outlined in clause 3.15 below.
3.14 Requesting information on the data we hold
Ganymede, at your request, can confirm what information we hold about you and how it is processed. This is called a Subject Access Request. If Ganymede does hold personal data about you, you can request copies of the information we hold from the DPR on the contact details below.
A Subject Access Request form can be can be requested from our DPR SAR@ganymedesolutions.co.uk. Whilst you do not need to complete the Subject Access Request form to log a request, it will make processing easier.
We will need two different forms of identification to show a facial photograph and address, which can be:
- Driving licence
- Birth certificate
- Utility bill (from last 3 months)
- Current vehicle registration document
- Bank statement (from last 3 months)
Your request should be emailed to the Ganymede DPR at SAR@ganymedesolutions.co.uk
3.15 Complaints and contacts
In the event that you wish to make a complaint about how your personal data is being processed by Ganymede or how your complaint has been handled, you have the right to lodge a complaint directly with the ICO and the Ganymede Data Protection Representative.
The details for each of these contacts are:
|Supervisory authority contact details||Data Protection Representative|
|Contact Name:||Information Commissioners Office (ICO)||Compliance Manager|
|Address line 1:||Wycliffe House,||The Derby Conference Centre,|
|Address line 2:||Water Ln,||London Road|
|Address line 3:||Wilmslow||Derby|
|Address line 4:||SK9 5AF||DE24 8UX|
|Address line 5:|
|Telephone:||0303 123 1113||0333 011 2048|