Cotleigh Associates (“the Company”) and its offices, branches and related companies ("we", “our”, or “us”) is a recruitment business operating as an employment business for the purposes of the Conduct of Employment Agencies and Employment Businesses Regulations 2003. We are committed to ensuring that we when collect and use information about visitors to our websites, we do so in accordance with the EU General Data Protection Regulations (“GDPR”) as well as other global legislation where our offices are located.
We are committed to protecting and respecting your privacy.
For the purposes of the GDPR, the data controller is Cotleigh Associates of 23-24 The Green, Southgate, London N14 6EN
1. Information we may collect from you
We may collect and process the following data about you:
1.1. Information you give us. You may give us information about you by filling in forms on our site https://www.cotleigh.com/associates-home or any one of the websites that relates to our associated companies https://www.cotleigh.com or by corresponding with us by phone, e-mail or otherwise. This includes information you provide when:
• you register to use our site;
• subscribe to our services or request further services on our site;
• when you report a problem with our site or make any enquiry or query or comment on our site;
• You apply for a vacancy we have advertised on our website or via a careers website we advertise through, or you have registered your personal details on the career websites to which we have authorised access.
The information you give us may include (without limitation) your name, address, e-mail address and phone number, financial and credit card information, personal description, photograph, skills, qualifications, education history, employment history, accreditations.
Your job application via us will constitute your express consent to our use of the above information, to access your application and to allow us to carry out any reference checking and other related activities as may be required of us under the applicable law, of the jurisdiction in which our offices or related companies may be based, as an employer.
We may also collect other types of your personal information such as references and employment objectives during the course of dealing with you, for example if you are considered for a particular employment position. Where practical, the purpose for which we collect personal information and the consequences of not providing it will be made clear at the time of collection.
In circumstances where we are required to collect sensitive information about you, such as information or an opinion about you, including:
• racial or ethnic origin;
• political opinions, membership of a political association;
• religious beliefs or affiliations, philosophical beliefs;
• membership of a professional or trade association, membership of a trade union;
• sexual preferences or practices;
• criminal records; and
• health information,
We will first seek your consent prior to collecting it.
1.2. Information we collect about you. With regard to each of your visits to our site we may automatically collect the following information:
• technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;
• information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our site (including date and time); products or services you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call our customer service number.
• Information we receive from other sources. We may collect or receive information about you if you use our site or any of the other websites we operate or the other services we provide. We may also collect or receive information about you from public records or third parties (including, for example, business partners, advertising networks, search information providers, credit reference agencies).
In either of the above circumstances, we may collect Personal Data about you. Personal Data is defined as any and all data that relates to an identifiable person who can be directly or indirectly identified from that data. In this case, it means personal data that you give to us via our site. This definition shall, where applicable, incorporate the definitions provided in the GDPR.
A cookie is a small data file that is stored on your computer, for use when you return to a page/website that you visited before.
In this case it contains information required for downloading documents. Cookies are not required to view our site but are in the document downloads area. If you wish to download a document, a cookie will be used to remember your name and email address to keep you from having to re-enter it every time you download a document. If cookies are disabled, you will need to re-enter this information every time you download a file.
3. Uses made of the information
We use information held about you in the following ways:
3.1. Information you give to us. We will use this information:
• to carry out our obligations arising from any contracts entered into between you and us and to provide you with the information and services that you request from us;
• to provide you with information about other services we offer that are similar to those that you have already purchased or enquired about;
• to maintain our business relationship with you, where you are a user of our site, a client or candidate;
• to enable you to submit your curriculum vitae (“CV”) generally, to apply for specific jobs or to subscribe to our services (such as job alerts, event alerts, etc);
• to match your coded details with job vacancies, to assist us in finding a position that is most suitable for you and, where you provide your prior consent as a candidate, to send your personal information to clients in order to apply for jobs;
• to answer your inquiry;
• to direct-market products and services, advise you of news and industry updates, events, promotions and competitions, reports and other information. Where we do so, you will be able to unsubscribe from such communications;
• to different offices of ours to enable the development and marketing of other products and services and to improve our customer service and to make our services more valuable to you, including tailoring our site when you log on to make it relevant to you personally;
• to trusted third parties where we have retained them to provide services that you have requested, such as psychometric evaluations or skills tests, and who also provide services to us, such as professional advisers, IT consultants, mailing houses and function co-ordinators. These third parties must comply with similar undertakings of privacy and confidentiality as we do;
• to provide you, or permit the above mentioned trusted third parties to provide you, with information about goods or services we feel may interest you. If you are an existing customer, we will only contact you by electronic means (e-mail or SMS) with information about goods and services similar to those which were the subject of a previous sale of services or discussions / negotiations of a sale of services to you. If you are a new customer, and where we permit trusted third parties to use your data, we (or they) will contact you by electronic means only if you have consented to this. If you do not want us to use your data in this way, or to pass your details on to third parties for marketing purposes, you will be able to unsubscribe from such use of your data;
• if we merge with or is acquired by another business, we may share personal information with the new owners of the business and their advisers and if this happens, you will be sent notice of such an event;
• we may also release personal information to regulatory or law enforcement authorities, if they require us to do so;
• to notify you about changes to our service; and
• to ensure that content from our site is presented in the most effective manner for you and for your computer.
3.2. Information we collect about you. We will use this information:
• to administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
• to improve our site to ensure that content is presented in the most effective manner for you and for your computer;
• to allow you to participate in interactive features of our service, when you choose to do so;
• as part of our efforts to keep our site safe and secure;
• to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you;
• to make suggestions and recommendations to you and other users of our site about goods or services that may interest you or them.
3.3. Information we receive from other sources. We may combine this information with information you give to us and information we collect about you. We may us this information and the combined information for the purposes set out above (depending on the types of information we receive).
4. Disclosure of your information
We may share your personal information with any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006.
We may also share your information with selected third parties including:
• Business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you
• Advertisers and advertising networks that require the data to select and serve relevant adverts to you and others;
• Analytics and search engine providers that assist us in the improvement and optimisation of our site;
• Credit reference agencies for the purpose of assessing your credit score where this is a condition of us entering into a contract with you.
• We may disclose your personal information to third parties:
• In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets.
• If we or substantially all our assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
• If we are under a duty to disclose or share your personal data to comply with any legal obligation, or to enforce any contract between us and other agreements; or to protect the rights, property, or safety of ourselves, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
5. How we deal with your CV on our site
5.1. Submitting your CV, Applying for jobs and request for conferences and events
• You may submit your CV to us via our site, either for general consideration by our recruitment consultants for positions as they arise or to apply for a specific advertised job.
• Once submitted, your CV will be sent directly to the relevant recruitment consultant who will review your details and advise you whether you are to be accepted by us for registration on our central database.
• This database, including your personal information, can be accessed by any of our recruitment consultants working in other branch or associate offices of the Company.
• If you are accepted onto our database, our recruitment consultants will contact you to set up an interview in person.
• You can update your CV at any time, simply by following the same procedure to submit a new CV via our site.
5.2. Job alerts; event alerts, etc
• You may sign up to receive emails that alert you to new jobs on our site or upcoming conferences and events.
• To subscribe to these, you need to provide your email address, which will be used for the purpose of keeping you informed by email of the latest jobs and / or news / events. If you no longer wish to receive any of these, unsubscribe links are provided in every email that you receive.
6. Where we store your personal data
The data that we collect from you may be transferred to, and stored (whether in hard copy or electronically) at, a destination outside the European Economic Area ("EEA"). It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers. Such staff maybe engaged in, among other things, the fulfilment of your order, the processing of your payment details and the provision of support services. By submitting your personal data, you agree to this transfer, storing or processing.
Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. We cannot accept responsibility for the information you send or receive from us over the internet or for any authorised access or use of that information. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
7. Your rights
You have the right to ask us not to process your personal data for marketing purposes. We will usually inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes. You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your data. You can also exercise the right (along with any of your other rights under the GDPR, as set out below) at any time by contacting us at firstname.lastname@example.org
As a data subject, you have the following rights under the GDPR, which this Policy and our use of Personal Data have been designed to uphold:
1. The right to be informed about our collection and use of personal data;
2. The right of access to the personal data we hold about you;
3. The right to rectification if any personal data we hold about you is inaccurate or incomplete;
4. The right to be forgotten – i.e. the right to ask us to delete any personal data we hold about you (we only hold your personal data for a limited time, but if you would like us to delete it sooner, please contact us using the details set out above);
5. The right to restrict (i.e. prevent) the processing of your personal data;
6. The right to data portability (obtaining a copy of your personal data to re-use with another service or organisation);
7. The right to object to us using your personal data for particular purposes; and
8. Rights with respect to automated decision making and profiling.
If you have any cause for complaint about our use of your personal data, please contact us using the details provided above and we will do our best to solve the problem for you. If we are unable to help, you also have the right to lodge a complaint with the UK’s supervisory authority, the Information Commissioner’s Office.
For further information about your rights, please contact the Information Commissioner’s Office or your local Citizens Advice Bureau.
Please contact us if you have a request relating to any of the following:
• if you would like to access, or correct, your personal information held by us;
• if you would like your personal information removed from our database;
• if you would like to opt-out from receiving direct marketing e-mails; or
You also have the right to raise concerns with Information Commissioner’s Office on 0303 123 1113 or at https://ico.org.uk/concerns/, or any other relevant supervisory authority should your personal data be processed outside of the UK, if you believe that your data protection rights have not been adhered to.