PROSPECTIVE CANDIDATE / CANDIDATE, CLIENT AND SUPPLIER PRIVACY NOTICE (UPDATED 20/08/24)
1. Scope
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 2018 (or its successor) and the UK 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 is part of the RTC Group of companies.
The website containing this Privacy Notice may contain links to third parties’ websites. Ganymede assumes no responsibility for the privacy practices or the content of those websites. Therefore, please carefully read 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 or ATA Recruitment website, or any other means.
Ganymede 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.
2. Responsibilities
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. Ganymede’s Head of Compliance and Assurance, 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 specialise in supplying large, trained workforces to undertake safety critical work across the rail, energy, construction, highways and transportation sectors across the UK. Whether it’s recruiting permanent and temporary technical, engineering and safety-critical roles or providing fully managed workforce solutions of recruitment, training, account management, contingent labour and fleet provision, we work closely with our clients to understand their requirements, keeping their goals in mind every step of the way. Our ATA Recruitment brand is a leading UK provider of recruitment services for engineering and manufacturing industries. Working as a trusted partner to several of the largest businesses in the UK, ATA has a proven track record of placements across engineering and manufacturing.
Our in-depth knowledge of the sectors we work in and the specific disciplines within them ensures we deliver tailored solutions to meet the individual needs of every client requirement. We work in line with our core values and strive to add value in all we do.
Ganymede Solutions Limited (Ganymede and/or ATA Recruitment) are part of the RTC Group Ltd. RTC Group Plc is an AIM listed recruitment business, providing temporary and permanent labour to a broad range of industries and customers in both domestic and international markets through its geographically defined operating divisions.
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. 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 |
Documents proving evidence of your 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 UK GDPR defines special category data as:
personal data revealing racial or ethnic origin;
personal data revealing political opinions;
personal data revealing religious or philosophical beliefs;
personal data revealing trade union membership;
genetic data;
biometric data (where used for identification purposes);
data concerning health;
data concerning a person’s sex life; and
data concerning a person’s sexual orientation.
It is anticipated that the most common Special categories of personal data required from a job seeker will be for the purposes of Health Screening as well as information relating to Criminal Convictions, including criminal record checks, which we may be required to obtain in order to meet industry or job role requirements.
We may also at times process data in relation to other special categories such as (but not limited to) ethic origin or sexual orientation in line with our Equality, Diversity and Inclusion processes, however, this will be anonymised, and processing of this data will not be mandatory.
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 your contact information and/or CV details and/or job specification details as you proceed through the stages of the application either via our website, directly with one of our staff members via email/telephone or face-to-face.
c) Automatic collection
Like most websites, our website uses cookies and web beacons to enhance your visitor experience. Please refer to our Cookie Policy for further information.
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 or CITB. Ganymede will use this information to update our database records.
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.
b) Automatic collection
Like most websites, our website uses cookies and web beacons to enhance your visitor experience. Please visit our Cookie Policy for further details.
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.
Independent of how we collect your data, we will always ensure that you have access to this Privacy Notice. If we have gathered your information from a third-party, we will notify you that we are storing and processing your data.
Additional details in relation to using our website, including our use of cookies, can be found in our Cookie Policy which can be accessed at www.ganymedesolutions.co.uk.
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;
We will process and store your information for any or all of the following purposes:
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 possible job opportunities and generally maintain the information you hold with us. If we are in discussion with you about a particular role or assignment, we may be required to share your information with our client in order to assist us in providing you with job-seeking services. 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 as well as obtain information in relation to your previous experience and suitability for a role by taking up references with previous employers.
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 with us. We may also be required to share this data with our clients for whom you are working for.
To assist with marketing of Ganymede services
In order to ensure that we provide you with the best possible 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;
1. To meet contractual obligations
2. To carry out new business development activities by offering you Ganymede services or products
3. 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. |
Clients/Potential Employers | Ganymede may be required to share your data with our clients as is necessary to provide you with job-seeking services and process your application for a particular role. |
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 European Economic Area EAA.
3.8 Transferring outside of the European Economic Area (EAA)
Ganymede will only transfer data outside of the EAA if necessary. This section explains how we use and protect personal data when sharing it outside of the EEA.
To provide our recruitment services, it may be necessary for us to transfer personal data to recipients located outside the EEA. These recipients may be our clients, partners, or service providers situated in countries that do not have the same level of data protection laws as the EEA. We are committed to ensuring the security and confidentiality of personal data transferred outside the EEA and will take all reasonable steps to protect it in accordance with applicable laws and regulations.
To ensure the protection of personal data transferred outside the EEA, we implement appropriate safeguards in accordance with the GDPR. These safeguards may include:
• Consent: We will obtain explicit consent from individuals before transferring their personal data outside the EEA.
• Adequacy Decisions: If the European Commission has determined that a particular country ensures an adequate level of protection, we may transfer personal data to recipients in that country.
• Risk Assessment: We may carry out a transfer risk assessment to enable us to consider whether, in the circumstances of the transfer, the relevant protections under the UK data protection regime will be undermined.
• Standard Contractual Clauses: We may use standard contractual clauses that provide adequate safeguards for the protection of personal data.
Individuals whose personal data is transferred outside the EEA still retain their data subject rights under the GDPR. Individuals can also exercise their right to lodge a complaint with the relevant supervisory authority.
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 (either directly or via a third-party), or by providing your details, you are giving us permission to retain your details in accordance with this Privacy Notice and our Data Retention Policy.
If we have been obtained 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 engaging with Ganymede, 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:
1. Processing of UK GDPR defined Special Categories of Personal Data, (i.e., Any data associated with Health, or our Equality & Diversity Commitment).
2. 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 your 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 optout@ganymedesolutions.co.uk.
3.10 Profiling and Automated processing
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 Retention Policy.
3.12 How will we contact you?
We will contact you in the following circumstances;
Circumstance | How | Why |
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 contacted, 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 contacted, 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. |
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 not 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 by emailing us at DPR@ganymedesolutions.co.uk.
In order to avoid personal data about one individual being sent to another, either accidentally or as a result of deception, we are required to be satisfied that we can verify the identity of the person requesting the information. We may therefore ask for further information from you to judge whether you are the person that the data is about, however, we will ensure that any request will be reasonable and proportionate.
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: | | |
Email: | | DPR@ganymedesolutions.co.uk |
Telephone: | 0303 123 1113 | 0333 011 2048 |
Online | https://ico.org.uk/concerns/handling/ | ` |