Energy People Privacy Policy

The Company is a job board and recruitment marketing business which provides work-finding services to its clients and job-seekers. The Company must process personal data (including sensitive personal data) so that it can provide these services – in doing so, the Company acts as a data controller.

You may give your personal details to the Company directly, such as on an application or registration form or via our website, or we may collect them from another source such as a jobs board. The Company must have a legal basis for processing your personal data. For the purposes of providing you with work-finding services and/or information relating to roles relevant to you we will only use your personal data in accordance with this privacy statement. At all times we will comply with current data protection laws.

Contents

1. Collection and use of personal data
   1. Purpose of processing and legal basis
   2. Legitimate interest
   3. Statutory/contractual requirement
   4. Recipients of data
2. Information to be provided when data is not collected directly from the data subject
   1. Categories of data
   2. Sources of data
3. Overseas transfers
4. Data retention
5. Your rights
6. Automated decision making
7. Cookies
8. Login files
9. Links to external sites
10. Sale of the business
11. Data security
12. Changes to the privacy statement
13. Complaints or queries

1. Collection and use of personal data

a. Purpose of processing and legal basis

The Company 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 clients.

If you have opted-in we may also send you marketing information and news via email/ text. You can opt-out from receiving these at any time by clicking “unsubscribe” when you receive these communications from us.

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.

We must have a legal basis to process your personal data. The legal bases we rely upon to offer our work-finding services to you are:

• Your consent
• Where we have a legitimate interest
• To comply with a legal obligation that we have
• To fulfill a contractual obligation that we have with you

b. Legitimate interest

This is where the Company has a legitimate reason to process your data provided it is reasonable and does not go against what you would reasonably expect from us. Where the Company has relied on a legitimate interest to process your personal data our legitimate interests is/are as follows:

• Managing our database and keeping work-seeker records up to date;
• Providing work-finding services to you and our clients;
• 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;
• To provide and undertake recruitment services;
• To assess data against vacancies the Company may judge be suitable for you;
• To send your information to clients so they may receive your application or asses your eligibility for jobs;
• To improve the Company’s services and to make the Company’s services more relevant to you (including updating he Company’s website to enhance your digital experience);
• Where you have consented to being contacted, send you promotions, offers, networking events and marketing information;
• To answer your queries;
• To carry out our obligations arising from any contracts entered between you and the Company, or any contracts the Company enters with third parties in relation to providing you recruitment services;
• To facilitate the Company’s payroll and invoicing processes;
• To third parties, regulatory or law enforcement bodies if the Company believes that they are required to disclose it in connection with a crime, the collection of taxes/duties, or in order to observe an applicable law or legal proceedings.

c. Statutory/contractual requirement

The Company has 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.) 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 personal data we need to collect we may not be able to continue to provide work-finding services to you.

d. Recipient/s of data

The company will process your personal data and/or sensitive personal data with the following recipients:

• Clients (whom we may introduce or supply you to)
• Former employers whom we may seek references from
• 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
• Third party service provider who supply processing services or perform functions on The Company’s behalf;
• Outsourced IT and document storage providers that The Company has entered into contractual agreements with;
• Marketing technology suppliers and platforms;

2. Information to be provided when data collected not from the data subject

Categories of data:

The Company has collected the following personal data on you:

Personal data:

• Name, address, mobile number, email
• National insurance no.
• Nationality (through right to work check)
• Date of birth
• Educational background

Sensitive private data:

• Health information including whether you have a disability
• Criminal conviction

Source of the personal data:

The company sourced your personal data/sensitive personal data:

• From job boards, LinkedIn, Communications Opt-In, Google, Facebook and Personal input.
• A former employer
• A referee whose details you previously provided to us
• Software provides who we use to support our services
• Cookies listed in section 7

This information came from a publicly accessible source.

3. Overseas Transfers

The Company may transfer the information you provide to us to countries outside the European Economic Area (‘EEA’) for the purposes of providing you with work-finding services. 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.

4. Data retention

The Company will retain your personal data only for as long as is necessary for the purpose we collect it. Different laws may also 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.

Where the Company has obtained your consent to process your personal and sensitive personal data, we will do so in line with our retention policy. Upon expiry of that period the Company will seek further consent from you. Where consent is not granted the Company will cease to process your personal data and sensitive personal data.

In addition to our obligations under the Conduct of Employment Agencies and Employment Business Regulations 2003, the Company will delete your personal data after three years if we have not had any meaningful contact with you or if we do not hold any records on you that are in legitimate interests to keep.

“Meaningful contact” means, for example, any form of contact between us in relation to the Company assisting/providing recruitment services to you.

5. Your rights

Please be aware that you have the following data protection rights:

• The right to be informed about the personal data the Company processes on you;
• The right of access to the personal data the Company processes on you;
• The right to rectification of your personal data;
• The right to erasure of your personal data in certain circumstances;
• The right to restrict processing of your personal data;
• The right to data portability in certain circumstances;
• The right to object to the processing of your personal data that was based on a public or legitimate interest;
• The right not to be subjected to automated decision making and profiling; and
• The right to withdraw consent at any time.

Where you have consented to the Company processing your personal data and sensitive personal data you have the right to withdraw that consent at any time by contacting Networker Global by contacting info@energypeople.com. Please note that if you withdraw your consent to further processing that does not affect any processing done prior to the withdrawal of that consent, or which is done according to another legal basis.

There may be circumstances where the Company will still need to process your data for legal or official reasons. Where this is the case, we will tell you and we will restrict the data to only what is necessary for those specific reasons.

If you believe that any of your data that the Company processes is incorrect or incomplete, please contact us using the details above and we will take reasonable steps to check its accuracy and correct it where necessary.

You can also contact us using the above details if you want us to restrict the type or amount of data we process for you, access your personal data or exercise any of the other rights listed above.

6. Cookies Policy

We may obtain data about you from cookies. These are small text files that are placed on your computer by websites that you visit. They are widely used in order to make websites work, or work more efficiently, as well as to provide information to the owners of the site. Cookies also enable us to deliver more personalised content.

The cookie-related information is not used to identify you personally and the pattern data is fully under our control. These cookies are not used for any purpose other than those described here.

The table below explains the cookies we use and why.

Cookie Name	Purpose
Strictly necessary cookies	These cookies are needed for effective site usage and as such, cannot be turned off. These cookies do not gather information about you that could be used for other purposes, such as marketing or tracking your internet usage.
Performance cookies	These cookies help us monitor and improve the performance of our website, counting visits, identifying traffic sources and judging site popularity. All information gathered is anonymous.
Functionality cookies	These cookies remember choices you make upon first visiting our website, including user name, language or where you are based. This allows the website to remember changes you have made to text size, font and other customisable elements. It also prevents repeat processes such as pop-ups. Functionality cookies may also be used to provide services you wish to use, such as watching videos and commenting, and are usually anonymous.

Most web browsers allow some control of most cookies through the browser settings. To find out more about cookies, please refer to our Cookie policy. Please note that in a few cases some of our website features may not function if you remove cookies from your browser.

Google Analytics

This website uses Google Analytics, a web analytics service provided by Google, Inc. (“Google”). This service uses cookies to help us analyse how users navigate and interact with the site. The information generated by the cookie includes your IP address and is transmitted to and stored by Google on servers in the United States. It uses this information to create reports on website activity for Networker Global and providing other services relating to website activity and internet usage. Google may send this information to third parties where required to do so by law, or if such third parties use the information on Google’s behalf. Google will not associate your IP address with any other data held by Google. Most web browsers allow some control of most cookies through the browser settings.

7. Log Files

We use IP addresses to analyse trends, administer the site, track users’ movements, and to gather broad demographic information for aggregate use. IP addresses are not linked to personally identifiable information.

8. Links to external websites

The Company’s website may contain links to other external websites. Please be aware that the Company is not responsible for the privacy practices of such other sites. When you leave our site we encourage you to read the privacy statements of each and every website that collects personally identifiable information. This privacy statement applies solely to information collected by the Company’s website.

9. Sale of business

If the Company’s business is sold or integrated with another business your details may be disclosed to our advisers and any prospective purchasers and their advisers and will be passed on to the new owners of the business.

10. Data Security

The Company takes every precaution to protect our users’ information. The Company uses the following security measures to safeguard your data;

• Firewalls including anti-spyware software
• Anti-virus software
• Patching
• Anti-spam filters
• All data is backed up daily
• All files/data are stored on password protected systems

Only employees who need the information to perform a specific job (for example, consultants, our accounts clerk or a marketing assistant) are granted access to your information.

The Company uses all reasonable efforts to safeguard your personal information. However, you should be aware that the use of email/ the Internet is not entirely secure and for this reason the Company cannot guarantee the security or integrity of any personal information which is transferred from you or to you via email/ the Internet.

If you share a device with others we recommend that you do not select the “remember my details” function when that option is offered.

If you have any questions about the security at our website, you can email, info@energypeople.com

11. Changes to this privacy statement

We will update this privacy statement from time to time. We will post any changes on the statement with revision dates. If we make any material changes, we will notify you.

12. Complaints or queries

If you wish to complain about this privacy notice or any of the procedures set out in it please contact: info@energypeople.com 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.