INTRODUCTION

  • This policy explains what we do with personal data, whether we are in the process of helping candidates find a job, continuing our relationship with them once we have found them a role, providing clients with a service, receiving a service from suppliers, using their data to ask for assistance in relation to one of our candidates, or you are visiting our website.
  • It describes how we collect, use and process personal data, and how we comply with our legal obligations. Privacy is important to Abalon, and we are committed to protecting and safeguarding all data privacy rights.
  • This privacy policy applies to the personal data of our website visitors, candidates, clients, suppliers, and other people whom we may contact to find out more about our candidates, or whom they indicate is an emergency contact. It also applies to the emergency contacts of our Staff. If you are a member of the Abalon team, please refer to the Abalon Internal Privacy Policy which is available from your line manager upon request.
  • For the purpose of applicable data protection legislation the company responsible for your personal data is Abalon Limited (Company Number: 08555647).
  • Abalon may amend this privacy policy from time to time in line with legislative updates and changes. Please visit this page if you want to view the latest version, as we will always post the most recent version here.

 

OVERVIEW

What kind of personal data do we collect?

CANDIDATES:

In order to provide the best employment opportunities that are tailored to you, we need to process certain information about you. We only ask for details that will genuinely help us to help you, such as your name, age, contact details, education details, employment history, emergency contacts, immigration status, financial information (where we need to carry out financial background checks) and National Insurance number you may also choose to share additional relevant information with us). Where appropriate and in accordance with local laws, we may also collect information related to your health, diversity information or details of any criminal convictions.

By submitting your CV either in response to a specific position, including via 3rd party recruitment websites (such as Reed, Indeed, Jobsite etc) or as a general upload to our website you are providing us with consent to use data contained within the document as detailed by this privacy policy. We shall also subject your data to the highest level of protection to prevent unauthorised access, use or disclosure of the data.

CLIENTS:

If you are an Abalon customer, we need to collect and use information about you, or individuals at your organisation, in the course of providing you services such as:

  1. finding candidates who are the right fit for you or your organisation
  2. providing you with outsourced resource services
  3. providing you with recruitment services
  4. notifying you of content published by Abalon which is likely to be relevant and useful to you

We hold your personal data in respect of your work contact details including: name, job title, telephone and email

The processing of this data is part of the performance if necessary and therefore supported by the consent provided by our contractual dealings with clients.

SUPPLIERS:

We need a small amount of information from our suppliers to ensure that everything runs correctly. We require the contact details of relevant individuals at your organisation so that we can communicate with you. We also need other information such as your bank details so that we can pay for the services you provide, where required.

We hold your personal data in respect of your work contact details including: name, job title, telephone and email

The processing of this data is part of the performance of a contract is necessary and therefore supported by the consent provided by our contractual dealings with clients.

REFEREES AND EMERGENCY CONTACTS:

In order to provide candidates with suitable employment opportunities safely and securely and to provide for every eventuality for them and our staff, we need some basic background information. We only ask for very basic contact details, so that we can get in touch with you either for a reference or because you’ve been listed as an emergency contact for one of our candidates or staff members.

By referring a friend or colleague to Abalon you are confirming that you have gained the consent of that individual for the submission of their personal details. Should you not have valid consent for the submission of the details Abalon will not be able to process them and they will be deleted from our records.

WEBSITE VISITORS:

We collect a limited amount of data from our website visitors which we use to help us to improve your experience when using our website and to help us manage the services we provide. This includes information such as how you use our website, the frequency with which you access our website, and the times that our website is most popular.

How do we collect your personal data?

CANDIDATES:

There are two main ways in which we collect your personal data:

1.       Directly from you

2.       From 3rd parties

CLIENTS:

There are two main ways in which we collect your personal data:

1.       Directly from you

2.       From 3rd parties and other limited sources with whom we hold formal contractual agreements for the access to candidate details and do so under legitimate interest consent

REFEREES AND EMERGENCY CONTACTS:

We use referees’ personal data to support candidates to find employment which is suited to them. If we are able to verify their details and qualifications, we can make sure that they are matched with suitable employers. We may also use referees' personal data to contact them in relation to recruitment activities that may be of interest to them. We use the personal details of a candidates emergency contacts in the case of an accident or emergency affecting that candidates. We approach referees under legitimate interest as a basis for processing.

WEBSITE VISITORS:

We use website visitor data to help us to improve the experience of using our website, for example by analysing recent job search criteria to help us to present jobs to you that we think visitors be interested in. If visitors are also candidates or clients of Abalon, we may use data from their use of our website to enhance other aspects of our communications.

Who do we share your personal data with?

CANDIDATES:

We may share your personal data with various parties, in various ways and for various reasons. Primarily we will share your information with prospective employers to increase your chances of securing you a job.

CLIENTS:

We will share your data:

  1. to ensure that we provide you with a suitable list of candidates
  2. to provide you with relevant, skilled outsourced resource
  3. to provide you with recruitment services

Our supply chain is risk assessed and we hold suitable due diligence information on file for each member of our supply chain to provide an assurance of their ability to effectively process personal data and ensure it remains secure and not disclosed to unauthorised resource or unnecessarily processed.

SUPPLIERS:

Unless you specify otherwise, we may share your information with any of our group companies and associated 3rd parties such as our service providers and organisations to whom we provide services.

WEBSITE VISITORS:

Unless you specify otherwise, we may share your information with providers of web analytics services, marketing automation platforms and social media services to make sure any advertising you receive is targeted to you.

How do we safeguard your personal data?

We care about protecting your information. All information is stored securely with significant security measures in place prevent unauthorised access to, and misuse of, your personal data.

How long do we keep your personal data for?

We consider the retention of candidate to be relevant and of legitimate interest to both parties and therefore such data will be retained on file until such time consent is withdrawn. Abalon will undertake necessary steps to ensure that the data remains accurate and will contact you to verify the validity of the data we hold.

How can you access, amend or take back the personal data that you have given to us?

  • Queries: If we already hold your personal data, you still have various rights in relation to it. To find out more, please contact us. We will seek to deal with your request without delay, and in in accordance with the stipulations of all applicable laws. Please note that we may keep a record of your communications to help us resolve any issues which you raise.
  • Right to object: If we are using your data because we deem it necessary for our legitimate interests to do so, and you do not agree, you have the right to object. We will respond to your request within 30 days (although we may be allowed to extend this period in certain cases). We’ll only disagree with you if certain limited conditions apply.
  • Right to withdraw consent: Where we have obtained your consent to process your personal data for certain activities (e.g. profiling your suitability for a roles), or consent to market to you, you may withdraw your consent at any time.
  • Data Subject Access Requests: You have the right to ask us to confirm what information we hold about you at any time, and you may ask us to change or remove such information. At this point we may comply with your request or do one of the following:
    • ask you to verify your identity, or ask for further clarification about your request
    • where we are legally permitted to do so we may decline your request, but we will explain why if we do
  • Right to erasure: In certain situations (for example, where we have processed your data unlawfully), you have the right to request us to "erase" your personal data. We will respond to your request within 30 days (although we may be allowed to extend this period in certain cases) and will only disagree with you if certain limited conditions apply. If we do agree to your request, we will Delete your data but will generally assume that you would prefer us to keep a note of your name on our register of individuals who would prefer not to be contacted. That way, we will minimise the chances of you being contacted in the future where your data are collected in unconnected circumstances. If you would prefer us not to do this, please say so.
  • Right of data portability: If you wish, you have the right to transfer your data from us to another data controller. We will help with this – either by directly transferring your data for you, or by providing you with a copy in a common format.
  • Right to lodge a complaint with a supervisory authority: You also have the right to lodge a complaint with your local supervisory authority – in the UK this is the Information Commissioner’s Office (contact details can be found at the end of this document)

If your interests or requirements change, you can unsubscribe from part or all of our marketing content (e.g. Abalon newsletters) by clicking the unsubscribe link in the email.

What are cookies and how do we use them?

  • A cookie is a small piece of data that is stored on your computer's hard drive. Cookies are used by nearly all websites and do not harm your system. Abalon use cookies to track your activity to help ensure you get the smoothest possible experience when visiting our website. We can use the information from cookies to ensure we present you with options tailored to your preferences on your next visit. We can also use cookies to analyse traffic.

  • If you want to check or change what types of cookies you accept, this can usually be changed within your browser’s settings.

How to reject cookies

  • If you don’t want to receive cookies that are not strictly necessary to perform basic features of our site, you may choose to opt-out by changing your browser settings
  • Most web browsers will accept cookies but if you would rather we didn’t collect data in this way you can choose to accept all or some or reject cookies in your browser's privacy settings. However, rejecting all cookies means that you may not be able to take full advantage of all our website's features.
  • For more information generally on cookies, including how to disable them, please refer to aboutcookies.org. You will also find details on how to delete cookies from your computer.

THE FULL DETAILS

What kind of personal information do we collect?

The information described below is in addition to any personal data we are required by law to process in any given situation.

CANDIDATES:

Depending on the relevant circumstances and applicable local laws and requirements, we may collect some or all of the information listed below to enable us to offer employment opportunities which are tailored to circumstances, skillset and interests:

  • Name
  • Address details
  • Date of birth
  • Sex/gender
  • Education
  • Employment history
  • Emergency contacts
  • Referee details
  • Nationality/citizenship/place of birth
  • Right to Work status
  • Driving licence
  • Passport
  • National Insurance number and any other tax-related information
  • Diversity information such as racial or ethnic origin, religious or other beliefs, and physical or mental health, including disability-related information
  • Details of any criminal convictions (if this is relevant for the role applied for)
  • Additional information that you choose to tell us
  • Information that your referees choose to tell us about you
  • Information supplied by our clients about you
  • IP address, dates, times and frequency with which you access our website

Please note that the above list of categories is not meant to be exhaustive.

By submitting your CV either in response to a specific position or via an unsolicited email, you are providing us with consent to use data contained within the document as detailed by this privacy policy. We shall also subject your data to the strict security protocols to prevent unauthorised access, use or disclosure of the aforementioned data.

CLIENTS:

The data we collect about clients is actually very limited. We generally only need to have your contact details or the details of individual contacts at your organisation (such as their names, telephone numbers and email addresses) to enable us to ensure that our relationship runs smoothly.

We also hold information relating to your online engagement with candidate profiles and other material published by Abalon, which we use to ensure that our marketing communications to you are relevant and timely.

We may also hold extra information that someone in your organisation has chosen to tell us. If we need any additional personal data for any reason, we will let you know.

We hold your personal data in respect of your work contact details including: name, job title, telephone and email

The processing applied to this data if part of the performance of a contract or as you are party to the performance of contract is necessary and therefore supported by the consent provided by our contractual dealings with clients.

SUPPLIERS:

We don't collect much data about Suppliers – we simply need to make sure that our relationship runs smoothly. We'll collect the details for our contacts within your organisation, such as names, telephone numbers and email addresses. We'll also collect bank details, so that we can pay you.

We may also hold extra information that someone in your organisation has chosen to tell us. In certain circumstances, such as when you engage with our Finance and Debt Recovery teams, our calls with you may be recorded, depending on the applicable local laws and requirements.

We hold your personal data in respect of your work contact details including: name, job title, telephone and email

The processing applied to this data if part of the performance of a contract or as you are party to the performance of contract is necessary and therefore supported by the consent provided by our contractual dealings with clients.

REFEREES AND EMERGENCY CONTACTS:

All we need from referees is confirmation of what you already know about our Candidate or prospective member of Staff, so that they can secure that job they really want. Emergency contact details give us somebody to call on in an emergency. To ask for a reference, we'll obviously need the referee's contact details (such as name, email address and telephone number). We'll also need these details if our Candidate or a member of our Staff has put you down as their emergency contact so that we can contact you in the event of an accident or an emergency.

WEBSITE VISITORS:

We collect a limited amount of data from our Website Users which we use to help us to improve your experience when using our website and to help us manage the services we provide.

This includes information such as how you use our website, the frequency with which you access our website, your browser type, the location you view our website from, the language you choose to view it in and the times that our website is most popular. If you contact us via the website, for example by using the chat function, we will collect any information that you provide to us, for example your name and contact details.

How do we collect your personal data?

CANDIDATES:

We collect candidate personal data in three primary ways:

  • Personal data that you give to us
  • Personal data that we collect automatically
  • Personal data that we receive from other sources

Personal data you give to us

  • Abalon needs to know certain information about you in order to provide a tailored service. This will enable us to provide you with the best opportunities and should save you time in not having to trawl through information about jobs and services that are not relevant to you.
  • There are numerous ways you can share your information with us. It all depends on what suits you.

These may include:

  • Entering your details on the Abalon website or via an application form
  • Emailing your CV to an Abalon consultant or being interviewed by them
  • Posting a hard copy CV at Abalon’s office
  • Entering a competition through a social media channel such as Facebook or Twitter

Personal data we receive from other sources

We also receive personal data about Candidate from other sources. Depending on the relevant circumstances and applicable local laws and requirements, these may include personal data received as follows:

  1. Via referees
  2. Via clients
  3. Searching sources, such as LinkedIn and other job sites

Personal data we collect automatically

CLIENTS:

We collect client personal data in a number of ways:

  1. Personal data that we receive directly from you
  2. Personal data that we receive from other sources
  3. Personal data that we collect automatically

We will receive data directly from you in three ways:

  1. You contact us proactively, usually by phone, email or LiveChat
  2. We contact you, either by phone or email
  3. Via our account managers’ business development process

Personal data we receive from other sources

Where appropriate and in accordance with any local laws and requirements, we may seek more information about you or your colleagues from other sources generally by way of due diligence or other market intelligence including:

  • From 3rd party market research and by analysing online and offline media which we may do internally, or employ other organisations to do for us
  • From delegate lists at relevant events
  • From other limited sources and 3rd parties

Personal data we collect via our website

To the extent that you access our website or read or click on an email from us, where appropriate and in accordance with any local laws and requirements, we may also collect your data automatically or through you providing it to us.

WEBSITE VISITORS:

When you visit our website, there is certain information that we may automatically collect, whether or not you decide to use our services. This includes your IP address, the date and the times and frequency with which you access the website and the way you browse its content. We will also collect data from you when you contact us via the website, for example by using the chat function.

We collect your data automatically via cookies, in line with cookie settings in your browser. If you are also a candidate or client of Abalon, we may use data from your use of our websites to enhance other aspects of our communications with or service to you.

How do we use your personal data?

Having obtained data about you, we then use it in a number of ways.

CANDIDATES:

We generally use candidate data in multiple ways:

  • Recruitment
  • Marketing
  • Equal Opportunities monitoring
  • To help us to establish, exercise or defend legal claims

We may also use Candidate data for Profiling, such as:

Recruitment Activities: Obviously, our main area of work is recruitment – connecting the right Candidates with the right jobs. We've listed below various ways in which we may use and process your personal data for this purpose, where appropriate and in accordance with any local laws and requirements. Please note that this list, while comprehensive, is not meant to be exhaustive.

  • Collecting your data from you and other sources, such as LinkedIn
  • Storing your details (and updating them when necessary) on our database, so that we can contact you in relation to recruitment
  • Providing you with our recruitment services and to facilitate the recruitment process
  • Assessing data about you against vacancies which we think may be suitable for you
  • Sending your information to clients, in order to apply for jobs or to assess your eligibility for jobs
  • Enabling you to submit your CV, apply online for jobs or to subscribe to alerts about jobs we think may be of interest to you
  • Allowing you to participate in specialist online training
  • Allowing you to participate in the interactive features of our services, when you choose to do so
  • Carrying out our obligations arising from any contracts entered into between us
  • Carrying out our obligations arising from any contracts entered into between Abalon and 3rd parties in relation to your recruitment
  • Facilitating our payroll and invoicing processes
  • Carrying out customer satisfaction surveys
  •  Verifying details, you have provided, using 3rd party resources (such as psychometric evaluations or skills tests), or to request information (such as references, qualifications and potentially any criminal convictions, to the extent that this is appropriate and in accordance with local laws)
  • Complying with our legal obligations in connection with the detection of crime or the collection of taxes or duties
  • Processing your data to enable us to send you targeted, relevant marketing materials or other communications which we think are likely to be of interest to you

Marketing Activities: We may periodically send you information that we think you may find interesting, or to ask for your help with connecting other Candidates with jobs. In particular, we may wish to use your data for the purposes listed below, where appropriate and in accordance with any local laws and requirements. Please note that this list is not exhaustive.

  • enable us to develop and market other products and services
  • market our full range of recruitment services (permanent, temporary, contract, outplacement services) to you
  • send you details of reports, promotions, offers, networking and client events, and general information about the industry sectors which we think might be of interest to you
     

We need your consent for some aspects of these activities which are not covered by our legitimate interests (in particular, the collection of data via cookies, and the delivery of direct marketing to you through digital channels) and, depending on the situation, we'll ask for this via an opt-in or soft-opt-in (which we explain further below).

If you are not happy about our approach to marketing, you have the right to withdraw your consent at any time and can find out more about how to do so here. Nobody's perfect, even though we try to be. We want to let you know that even if you have opted out from our marketing communications through our preference centre, it is possible that your details may be recaptured through public sources in an unconnected marketing campaign. We will try to make sure this doesn't happen, but if it does, we're sorry. We'd just ask that in those circumstances you opt out again.

All our marketing is based on what we think will serve our clients and candidates best, but we know we won’t always get it right for everyone. We may use your data to show you Abalon adverts and other content on other websites, for example Facebook. If you do not want us to use your data in this way, please turn off the “Advertising Cookies” option (please refer to our Cookies Policy). Even where you have turned off advertising cookies, it is still possible that you may see a Abalon advert, but in this case, it won’t have been targeted at you personally, but rather at an anonymous audience.

Equal opportunities monitoring and other sensitive personal data: We are committed to ensuring that our recruitment processes are aligned with our approach to equal opportunities. Some of the data we may (in appropriate circumstances and in accordance with local law and requirements) collect about you comes under the umbrella of "diversity information". This could be information about your ethnic background, gender, disability, age, sexual orientation, religion or other similar beliefs, and/or social-economic background. Where appropriate and in accordance with local laws and requirements, we'll use this information on an anonymised basis to monitor our compliance with our equal opportunities policy. We may also disclose this (suitably anonymised where relevant) data to Clients where this is contractually required, or the Client specifically requests such information to enable them to comply with their own employment processes.

  • This information is what is called ‘sensitive’ personal information and slightly stricter data protection rules apply to it. We therefore need to obtain your explicit consent before we can use it. We'll ask for your consent by offering you an opt-in. This means that you have to explicitly and clearly tell us that you agree to us collecting and using this information.
  • We may collect other sensitive personal data about you, such as health-related information, religious affiliation, or details of any criminal convictions if this is appropriate in accordance with local laws and is required for a role that you are interested in applying for. We will never do this without your explicit consent.
  • If you would like to find out more about consent, please click here. Please note that in certain areas of the jurisdictions in which we operate, different rules apply to this sensitive data. For more information in relation to your jurisdiction, please click here.
  • If you are not happy about this, you have the right to withdraw your consent at any time and you can find out how to do so here.
  • To help us to establish, exercise or defend legal claims
  • In more unusual circumstances, we may use your personal data to help us to establish, exercise or defend legal claims

Profiling: Although at present all our recruitment activities involve human-decision making during the process, we may in the future use fully automated technologies such as expert systems or machine learning to complete a Candidate selection process from end-to-end, where appropriate and in accordance with any local laws and requirements.

Where appropriate, we will seek your consent to carry out some or all of these activities. If you do not provide consent to profiling, your application will continue to be reviewed manually for opportunities you apply for, but your profile will not be automatically considered for alternative roles. This is likely to decrease the likelihood of us successfully finding you a new job.

CLIENTS:

We use Client information for:

  • Recruitment Activities;
  • Marketing Activities; and
  • To help us to establish, exercise or defend legal claims

Here are some more details about each:

Recruitment Activities: Our main area of work is recruitment, through:

  1. Provision of candidates
  2. Outsourced resources
  • Storing your details (and updating them when necessary) on our database, so that we can contact you in relation to recruitment activities
  • Keeping records of our conversations and meetings, so that we can provide targeted services to you
  • Undertaking customer satisfaction surveys
  • Processing your data for the purpose of targeting appropriate marketing campaigns

Marketing Activities: Subject to any applicable local laws and requirements, we will not, as a matter of course, seek your consent when sending marketing materials to a corporate postal or email address.

SUPPLIERS:

We will only use supplier information:

  • To store (and update when necessary) your details on our database, so that we can contact you in relation to our agreements
  • To offer services to you or to obtain support and services from you
  • To perform certain legal obligations
  • To help us to target appropriate marketing campaigns
  • In more unusual circumstances, to help us to establish, exercise or defend legal claims
  • We will not, as a matter of course, seek your consent when sending marketing messages to a corporate postal or email address

REFEREES AND EMERGENCY CONTACTS:

We will only use the information that our Candidate gives us about you for the following purposes:

  • If our Candidates or Staff members put you down on our form as an emergency contact, we'll contact you in the case of an accident or emergency affecting them; or
  • If you were put down by our Candidate or a prospective member of Staff as a referee, we will contact you in order to take up a reference. This is an important part of our Candidate quality assurance process and could be the difference between the individual getting a job or not.
  • If you were put down by our Candidate or a prospective member of Staff as a referee, we may sometimes use your details to contact you in relation to recruitment activities that we think may be of interest to you, in which case we will use your data for the same purposes for which we use the data of Clients.
  • We may use your personal data for these purposes if we deem this to be necessary for our legitimate interests. If you are not happy about this, you have the right to object

WEBSITE VISITORS:

We use your data to help us to improve your experience of using our website, for example by analysing your recent job search criteria to help us to present jobs or Candidates to you that we think you'll be interested in.

Who do we share your personal data with?

Where appropriate and in accordance with local laws and requirements, we may share your personal data, in various ways and for various reasons, with the following categories of people:

  • Individuals and organisations who hold information related to your reference or application to work with us, such as current, past or prospective employers, educators and examining bodies and employment and recruitment agencies
  • Tax, audit, or other authorities, when we believe in good faith that the law or other regulation requires us to share this data (for example, because of a request by HMRC or in connection with any anticipated litigation)
  • 3rd party service providers who perform functions on our behalf (including external payroll,  consultants, business associates and professional advisers such as lawyers, auditors and accountants, technical support functions and IT consultants carrying out testing and development work on our business technology systems)
  • 3rd party outsourced IT and document storage providers where we have an appropriate processing agreement (or similar protections) in place
  • If Abalon merges with or is acquired by another business or company in the future, (or is in meaningful discussions about such a possibility) we may share your personal data with the (prospective) new owners of the business or company

How do we safeguard your personal data?

Abalon are committed to taking all reasonable and appropriate steps to protect the personal information that we hold from misuse, loss, or unauthorised access. We do this by having in place a range of appropriate technical and organisational measures. These include measures to deal with any suspected data breach. If you suspect any misuse or loss of or unauthorised access to your personal information, please let us know immediately.

How long do we keep your personal data?

  • We will delete your personal data from our systems if we have not had any meaningful contact with you (or, where appropriate, the company you are working for or with) for two years (or for such longer period as we believe in good faith that the law or relevant regulators require us to preserve your data). After this period, it is likely your data will no longer be relevant for the purposes for which it was collected.
  • For those candidates whose services are provided via a 3rd-party company or other entity, "meaningful contact" with you means meaningful contact with the company or entity which supplies your services. Where we are notified by such company or entity that it no longer has that relationship with you, we will retain your data for no longer than two years from that point or, if later, for the period of two years from the point we subsequently have meaningful contact directly with you.
  • When we refer to "meaningful contact", we mean, for example, communication between us (either verbal or written), or where you are actively engaging with our online services. If you are a Candidate, we will consider there to be meaningful contact with you if you submit your updated CV onto our website or take part in any of our online training. We will also consider it meaningful contact if you communicate with us about potential roles, either by verbal or written communication or click through from any of our marketing communications. Your receipt, opening or reading of an email or other digital message from us will not count as meaningful contact – this will only occur in cases where you click-through or reply directly.

How can you access, amend or take back the personal data that you have given to us?

  • One of the GDPR's objectives is to protect and clarify the rights of EU citizens and individuals in the EU with regards to data privacy. This means that you retain various rights in respect of your data, even once you have given it to us. These are described in more detail below.
  • To get in touch about these rights, please contact us. We will seek to deal with your request without undue delay, and in any event within one month (subject to any extensions to which we are lawfully entitled). Please note that we may keep a record of your communications to help us resolve any issues which you raise.

Right to object: this right enables you to object to us processing your personal data where we do so for one of the following 4 reasons:

  1. legitimate interests
  2. to send you direct marketing materials
  3. for scientific, historical, research, or statistical purposes
  4. to enable us to perform a task in the public interest or exercise official authority

The legitimate interests and direct marketing categories above are the ones most likely to apply to our website visitors, candidates, clients and suppliers. If your objection relates to us processing your personal data because we deem it necessary for your legitimate interests, we must act on your objection by ceasing the activity in question unless:

  • we can show that we have compelling legitimate grounds for processing which overrides your interests
  • we are processing your data for the establishment, exercise or defence of a legal claim
  • if your objection relates to direct marketing, we must act on your objection by ceasing this activity.

Right to withdraw consent: Where we have obtained your consent to process your personal data for certain activities (for example, for our marketing arrangements or automatic profiling), you may withdraw this consent at any time and we will cease to carry out the particular activity that you previously consented to unless we consider that there is an alternative reason to justify our continued processing of your data for this purpose in which case we will inform you of this condition.

Data Subject Access Requests: You may ask us to confirm what information we hold about you at any time, and request us to modify, update or Delete such information. We may ask you to verify your identity and for more information about your request. If we provide you with access to the information we hold about you, we will not charge you for this unless your request is "manifestly unfounded or excessive". If you request further copies of this information from us, we may charge you a reasonable administrative cost where legally permissible. Where we are legally permitted to do so, we may refuse your request. If we refuse your request, we will always tell you the reasons for doing so.

Please note that in certain areas of the jurisdictions in which we operate, we comply with additional local law requirements regarding data subject access requests and may refuse your request in accordance with such laws.

Right to erasure: You have the right to request that we erase your personal data in certain circumstances. Normally, the information must meet one of the following criteria:

  • the data are no longer necessary for the purpose for which we originally collected and/or processed them;
  • where previously given, you have withdrawn your consent to us processing your data, and there is no other valid reason for us to continue processing;
  • the data has been processed unlawfully (i.e. in a manner which does not comply with the GDPR);
  • it is necessary for the data to be erased in order for us to comply with our legal obligations as a data controller; or
  • if we process the data because we believe it necessary to do so for our legitimate interests, you object to the processing and we are unable to demonstrate overriding legitimate grounds for our continued processing.
  • We would only be entitled to refuse to comply with your request for one of the following reasons:
  • to exercise the right of freedom of expression and information
  • to comply with legal obligations or for the performance of a public interest task or exercise of official authority
  • for public health reasons in the public interest
  • for archival, research or statistical purposes
  • to exercise or defend a legal claim
  • When complying with a valid request for the erasure of data we will take all reasonably practicable steps to delete the relevant data.

Right to restrict processing: You have the right to request that we restrict our processing of your personal data in certain circumstances. This means that we can only continue to store your data and will not be able to carry out any further processing activities with it until either:

  1. one of the circumstances listed below is resolved;
  2.  you consent
  3. further processing is necessary for either the establishment, exercise or defence of legal claims, the protection of the rights of another individual, or reasons of important EU or Member State public interest.

The circumstances in which you are entitled to request that we restrict the processing of your personal data are:

  • where you dispute the accuracy of the personal data that we are processing about you. In this case, our processing of your personal data will be restricted for the period during which the accuracy of the data is verified;
  • where you object to our processing of your personal data for our legitimate interests. Here, you can request that the data be restricted while we verify our grounds for processing your personal data;
  • where our processing of your data is unlawful, but you would prefer us to restrict our processing of it rather than erasing it; and
  • where we have no further need to process your personal data, but you require the data to establish, exercise, or defend legal claims.

If we have shared your personal data with 3rd parties, we will notify them about the restricted processing unless this is impossible or involves disproportionate effort. We will, of course, notify you before lifting any restriction on processing your personal data.

Right to rectification: You also have the right to request that we rectify any inaccurate or incomplete personal data that we hold about you. If we have shared this personal data with 3rd parties, we will notify them about the rectification unless this is impossible or involves disproportionate effort. Where appropriate, we will also tell you which 3rd parties we have disclosed the inaccurate or incomplete personal data to. Where we think that it is reasonable for us not to comply with your request, we will explain our reasons for this decision.

Right of data portability: If you wish, you have the right to transfer your personal data between data controllers. In effect, this means that you are able to transfer your Abalon’s account details to another online platform. To allow you to do so, we will provide you with your data in a commonly used machine readable format that is password-protected so that you can transfer the data to another online platform.

Alternatively, we may directly transfer the data for you. Right of data portability applies to:

  1. personal data that we process automatically (i.e. without any human intervention)
  2. personal data provided by you
  3. personal data that we process based on your consent or in order to fulfil a contract

Right to lodge a complaint with a supervisory authority: You also have the right to lodge a complaint with your local supervisory authority. Details of how to contact them can be found here.

  • If you would like to exercise any of these rights or withdraw your consent to the processing of your personal data (where consent is our legal basis for processing your personal data), details of how to contact us can be found here. Please note that we may keep a record of your communications to help us resolve any issues which you raise.
  • It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during the period for which we hold your data.

Who is responsible for processing your personal data on the Abalon website?

You can find out which Abalon entity is responsible for processing your personal data and where it is located by following this link. If you have any comments or suggestions concerning this privacy policy, please follow this link. We take privacy seriously, so we'll get back to you as soon as possible.

How do we store and transfer your data internationally?

In order to provide you with the best service and to carry out the purposes described in this privacy policy, your data may be transferred:

  • between and within Abalon’s entities
  • to 3rd parties (such as advisers or other Suppliers to the Abalon business)
  • to clients within your country who may, in turn, transfer your data internationally
  • to a cloud-based storage provider
  • to other 3rd parties

We want to make sure that your data are stored and transferred in a way which is secure. We will therefore only transfer data outside of the European Economic Area or EEA where it is compliant with data protection legislation and the means of transfer provides adequate safeguards in relation to your data, for example:

  • by way of data transfer agreement, incorporating the current standard contractual clauses adopted by the European Commission for the transfer of personal data by data controllers in the EEA to data controllers and processors in jurisdictions without adequate data protection laws
  • by signing up to the EU-U.S. Privacy Shield Framework for the transfer of personal data from entities in the EU to entities in the United States of America or any equivalent agreement in respect of other jurisdictions
  • transferring your data to a country where there has been a finding of adequacy by the European Commission in respect of that country's levels of data protection via its legislation
  • where it is necessary for the conclusion or performance of a contract between ourselves and a 3rd party and the transfer is in your interests for the purposes of that contract (for example, if we need to transfer data outside the EEA in order to meet our obligations under that contract if you are a Client of ours)
  • where you have consented to the data transfer

To ensure that your personal information receives an adequate level of protection, we have put in place appropriate procedures with the 3rd parties we share your personal data with to ensure that your personal information is treated by those 3rd parties in a way that is consistent with and which respects the law on data protection.

COOKIES POLICY

What are cookies?

A "cookie" is a piece of information that is stored on your computer's hard drive and which records your navigation of a website so that, when you revisit that website, it can present tailored options based on the information stored about your last visit. Cookies can also be used to analyse traffic and for advertising and marketing purposes.

Cookies are used by nearly all websites and do not harm your system. If you want to check or change what types of cookies you accept, this can usually be altered within your browser settings. We also provide information about this in our Marketing preferences page on the Abalon website.

How do we use cookies?

We use cookies as follows:

  • to track your use of our website. This enables us to understand how you use the site and track any patterns that emerge individually or from larger groups. This helps us to develop and improve our website and services in response to what our visitors want and need; and
  • to help us advertise jobs to you that we think you'll be interested in. Hopefully this means less time for you trawling through endless pages and will get you into the employment you want more quickly.

Cookies are either:

  • Session cookies: these are only stored on your computer during your web session and are automatically deleted when you close your browser – they usually store an anonymous session ID allowing you to browse a website without having to log in to each page, but they do not collect any information from your computer; or
  • Persistent cookies: a persistent cookie is stored as a file on your computer and it remains there when you close your web browser. The cookie can be read by the website that created it when you visit that website again. We use persistent cookies for Google Analytics and for personalisation (see below).

Cookies can also be categorised as follows:

  • Strictly necessary cookies: These cookies are essential to enable you to use the website effectively, such as when applying for a job, and therefore cannot be turned off. Without these cookies, the services available to you on our website cannot be provided. These cookies do not gather information about you that could be used for marketing or remembering where you have been on the internet
  • Performance cookies: These cookies enable us to monitor and improve the performance of our website. For example, they allow us to count visits, identify traffic sources and see which parts of the site are most popular
  • Functionality cookies: These cookies allow our website to remember choices you make (such as your user name, language or the region you are in) and provide enhanced features. For instance, we may be able to provide you with news or updates relevant to the services you use. These cookies can also be used to remember changes you have made to text size, font and other parts of web pages that you can customise. They may also be used to provide services you have requested such as viewing a video or commenting on a blog. The information these cookies collect is usually anonymised
  • Personalisation cookies: These cookies help us to advertise details of potential job opportunities that we think may be of interest. These cookies are persistent (for as long as you are registered with us) and mean that when you log in or return to the website, you may see advertising for jobs that are similar to jobs that you have previously browsed

OUR LEGAL BASIS FOR PROCESSING YOUR DATA

LEGITIMATE INTERESTS

  • As per GDPR legislation, we can process your data where it "is necessary for the purposes of the legitimate interests pursued by [us] or by a 3rd party, except where such interests are overridden by the interests or fundamental rights or freedoms of [you] which require protection of personal data."

  • We don't believe that any of the following activities prejudice individuals in any way However, you do have the right to object to us processing your personal data on this basis. If you would like to know more about how to do so, please contact us.

CANDIDATES:

  • It is a reasonable expectation that if you are looking for employment or have posted your professional CV information on a job board or professional networking site, you are happy for us to collect and use your personal data to provide recruitment services to you, share that information with prospective employers and assess your skills against our vacancies.
  • We have to make sure our business runs smoothly. We therefore also need to use your data for our internal administrative activities such as payroll and invoicing, where required.
  • We have our own obligations under the law. If deemed necessary, we may be required to share your data in connection with crime detection, tax collection or litigation.

CLIENTS:

To ensure that we provide you with the best service possible, we store your personal data and the personal data of individual contacts at your organisation as well as keeping records of our conversations, meetings, requirements and placements. On occasion, we may also ask you to undertake a customer satisfaction survey. We think this is reasonable – we deem these uses of your data to be necessary for our legitimate interests as an organisation providing various recruitment services to you.

SUPPLIERS:

We use and store the personal data of individuals within your organisation in order to facilitate the receipt of services from you as one of our Suppliers. We also hold your financial details, so that we can pay you for your services. We deem all such activities to be necessary within the range of our legitimate interests as a recipient of your services.

REFEREES AND EMERGENCY CONTACTS:

If you have been put down by a candidate or a prospective member of staff as one of their referees, we use your personal data in order to contact you for a reference. This is a part of our quality assurance procedure and so we deem this to be necessary for our legitimate interests as an organisation offering recruitment services and employing people ourselves.

If a candidate or staff member has given us your details as an emergency contact, we will use these details to contact you in the case of an accident or emergency. We are sure you will agree that this is a vital element of our people-orientated organisation, and so is necessary for our legitimate interests.

CONSENT

In certain circumstances, we are required to obtain your consent to the processing of your personal data in relation to certain activities. Depending on exactly what we are doing with your information, this consent will be by:

  • Positive opt-in via the submission of your CV via the Abalon website
  • Legitimate interests in pursuing employment opportunities for candidates
  • Due to the performance of a contract or being party to the performance of a contract due to your association with an Abalon customer or supply chain member
  • As we have mentioned, you have the right to withdraw your consent to these activities

ESTABLISHING, EXERCISING OR DEFENDING LEGAL CLAIMS

Sometimes it may be necessary for us to process personal data and, where appropriate and in accordance with local laws and requirements, sensitive personal data in connection with exercising or defending legal claims. GDPR legislation allows this where the processing "is necessary for the establishment, exercise or defence of legal claims or whenever courts are acting in their judicial capacity". This may arise for example where we need to take legal advice in relation to legal proceedings or are required by law to preserve or disclose certain information as part of the legal process.

HOW TO CONTACT US

How you can get in touch with us:

  • to access, amend or take back the personal data that you have given to us
  • if you suspect any misuse or loss of or unauthorised access to your personal information
  • to withdraw your consent to the processing of your personal data (where consent is the legal basis on which we process your personal data)
  • with any comments or suggestions concerning this policy

Abalon Limited, New Broad Street House, 35 New Broad Street, London, EC2M 1NH

info@abalon.co.uk

HOW TO CONTACT THE ICO

The Information Commissioner's Office.

  • 0303 123 1113
  • casework@ico.org.uk
  • Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF