Privacy policy

Privacy Policy

Last Updated: May 20, 2018

1.1 Introduction

Any references to "we", "us", "our", or "the company", are references to The Retail Appointment, a trading division of Retail Human Resources Ltd (RHR), company registration number 03699291.

This privacy policy sets out how we gather, use and protect any information that you may provide to us when using this website (www.retailappointment.co.uk).

As a business we value the trust that our users give us when they submit personal data.  We are committed to ensuring that we comply with the General Data Protection Regulation (GDPR) (Regulation (EU) 2016/679) Act and are committed to protecting the privacy of our clients and users of our website. We will ensure that the information you submit to us by way of our website is only used for the purposes set out in this policy. Should we ever ask you to provide information by which you could be identified, rest assured this information will only be used in accordance with this privacy policy.

We may make changes to this policy occasionally, by updating this page. You should check this page regularly to ensure that you are happy with the policy and any changes that may have been made. Any changes that may be made to this policy will in no way contravene our guarantee of confidentiality.

Who we are?

The company publishes a magazine, website and event solely for the purpose of matching jobseekers to jobs and to provide industry and work related content to professionals within the industry. The company will process personal data for the period in which the candidate is seeking employment or where indicated that as part of their career development, they wish to remain registered.  The data is reviewed on a three-month basis and will be stored for a period of three years unless legislation dictates otherwise.

By consenting to this privacy policy you are giving us permission to process your personal data specifically for the purposes identified.  Consent is required for the company to process personal data, but it must be explicitly given. Where we are asking you for sensitive personal data we will always tell you why and how the information will be used.

You may withdraw consent at any time by emailing the Data Privacy Officer at dpo@rhr.co.uk and requesting a Data Subject Consent Withdrawal Form.  We aim to complete your request within two working days of receiving the form.

1.2 Personal data and non-personal data

Personal data (“personal data”) refers to any information that identifies you as a specific individual, and non-personal data (“non-personal data”) refers to any information that does not identify you as a specific individual. Please note that at all times the company will adhere to the applicable statutory definition in determining what is and is not personal data for the purposes of this privacy policy. Where this privacy policy refers to “information” or “your information” this may include both personal and non-Personal data.

2. Information collected

You provide different types of information in order for the company to provide our services, products and features to you.

2.1 Information you provide

– From your account

We collect data from you when you create a profile via our registration pages, request information, subscribe for a service, participate in a survey, apply for job by posting a curriculum vitae, upload content or otherwise actively send us data on our site. This may include, but is not limited to, your user name, password, first and last name, email address, telephone number (including mobile phone number), address, gender, occupation, interests, messages you send to employers or the company, and any other data included in a submitted profile or curriculum vitae, including but not limited to application materials and answers to screening questions submitted to employers through the site and answers you give to any questionnaires sent to you, which you answer.

– Through your activity

In addition, as part of the standard operation of the site, the company may collect and analyse information from your computer or mobile device and actions taken on the site, including, but not limited to, your curriculum vitae, your searches, the titles of jobs you search, click on or apply to, where those jobs are located, salary interest or experience, the general salary range or experience level of the jobs you view (where indicated), your activity time on the site and each page, page views, clicks, taps, session activity, browser type, operating system, type of device, MAC address, IP address and the domain name from which you accessed the site.

– When providing employer information

If you are an employer, the company may request that you provide certain personal data to the company in order to verify your account. This information may include, but may not be limited to, your business registration information and the name and email address of an employer representative.

This information will be used for internal purposes only, subject to any request by law enforcement or a court order. In connection with chargeable services, we will also take payment information.  Where services are elected to be paid for by credit card, details are not stored by the company.

2.2 Personal data the company may receive from third parties

Any personal data that the company may obtain from third-party sources will be processed by the company in accordance with this privacy policy and all applicable laws.

2.3 Storage of your information

The company shall retain users’ personal data to the extent such retention is adequate, relevant and limited to what is necessary for the purposes for which they are processed. In particular, the company shall not retain personal data for any longer than necessary for the purposes of performing the processing outlined in this privacy policy.

If you create an account, your information may be collected and stored in a manner that connects to your account email address. The company may also create and assign to your device an identifier that is similar to an account number. We may collect the name you have associated with your device, device type, telephone number, country, and any other information you choose to provide, such as user name, email address, or post code. For example, while using a mobile device to access the site, the company may provide a job seeker with relevant job postings that are located within the same area as where this activity is taking place. The collection of this data is solely used in accordance with the purposes outlined in this privacy policy, to the extent applicable.

The company may also store the information detailed in this section 2 of the privacy policy on its equipment or the equipment of third parties that the company has a relationship with. Such storage services will be governed by appropriate protections, as required by applicable rules.

2.5 What personal data is required

The company will indicate to you at the point of provision as to whether or not particular personal data provided by you is required in order to provide particular services or features to you. Where personal data that is required is not provided by you then the particular feature or service may not be available to you.

2.6 The legal basis on which the company collects your personal data

The company collects and processes your personal data on the basis of different legal grounds, depending on the nature of the personal data being provided and the type of processing involved. More information is provided on this here.

– Performance of a contract

Most of the personal data processed by the company is performed on the basis that it is necessary for the performance of our agreement with you, or in order to take steps at the request of the user prior to entering such an agreement. An example of this would be where the company matches job seekers with employers.

– Legitimate interest

A second ground relied upon by the company for other types of processing of your personal data is that it is necessary for the purposes of legitimate interests pursued by the company. Such legitimate interests will include where the company sends you marketing about our products and services, where we believe you have a reasonable expectation that we will perform a particular type of processing on your behalf, or where such processing is strictly necessary for fraud detection and prevention. The company will only rely on such a ground where an assessment has been performed balancing the interests and rights involved and the necessity of the processing in order to provide our services, products and features to you.

– Compliance with a legal obligation

A third ground relied upon for certain types of processing is that it is necessary in order to allow the company to comply with a legal obligation. An example of this would be where the company is required to retain business records for fixed periods of time in order to comply with local legal requirements.

– Consent

Finally, in certain limited situations, the company relies on your consent in order to process your personal data. Where the company requires your consent in order to collect and process certain personal data, we seek your consent at the time of provision, and such processing will only be performed where consent is secured. For example, your consent will be sought where you initiate a job alert with the company (detailed in this privacy policy).

3. Purposes, uses and disclosures of information

We may use any information collected pursuant to this privacy policy, including personal data, for the purposes set forth in this privacy policy, to the extent applicable. The company uses such information to help job seekers find jobs and to help employers find candidates. In order to do this we use your personal data to:

1) provide our services, products and features to you, to help job seekers find jobs and employers find candidates;

2) to measure and improve those services, products and features; and

3) to protect our users and provide them with customer support.

More detail on these purposes, uses and disclosures of your information is set out below.

3.1 Creating an account, sending you job alerts and other promotional materials

If and to the extent permitted by applicable law, the company may use your contact information to (i) create an account; (ii) send you job alerts; and (iii) send you information about the company, including promotional materials. The company may use third-party partners to perform these activities on the company’s behalf.

A job alert is defined as an email sent to you that you sign up for containing job listings in response to a search query you have run (“job alert”). Job alerts may also include jobs that the company recommends for you, targeted ads, companies you may be interested in following, or other actions you may want to take on the site.

The company may also share your information with third parties (including operators of third-party websites and/or social networking sites) in order to show you targeted advertisements and other content that has been customised for you. Such advertisements will only relate to the company’s services, products, and features, all of which focus on helping job seekers find jobs and employers find candidates. If you wish to opt out of receiving any marketing messages from the company please contact us.

3.2 Giving you relevant search results and recommended jobs

In order to optimise our services, products and features for you, the company may use your previous search and browsing history (e.g. the jobs you click on), or application materials and answers to screening questions, to identify you and determine relevant search results and provide you with recommended jobs that you may be interested in. We may also use demographic and/or profile data to tailor your experience on the site, to show you content that the company thinks you may be interested in, and display content according to your preferences.

3.3 Your contact information

When you give the company contact information (such as your name and email address) and other forms of personal and non-personal data, you agree that the company may utilise this information for the purposes outlined in this privacy policy, to the extent applicable. In particular, you agree that the company may, as part of its services to you, communicate with you, or initiate communication with you on behalf of a third party, through your account or through other means such as email, telephone (including mobile phone), or postal mail, including through the use of contact information that you may provide to the company or that the company may otherwise obtain from third-party resources.

3.4 Your curriculum vitae information

Your information, including personal data, gets placed on the site when you upload or edit your curriculum vitae. The company reserves the right to charge third parties a fee for accessing your information, including personal data, as part of the company’s services. At your direction, the company may also send your curriculum vitae to third parties if you choose to apply for a job listing. The extent to which your information is made available to third parties depends on the privacy settings you choose on your my profile page. When a job seeker creates a curriculum vitae on site, they are given the option to hide it as detailed below.

– Hiding your curriculum vitae

You can set your curriculum vitae to be “hidden” or “private” via the “my profile” area on the site.  Where set to “hidden,” no employer will be able to access your curriculum vitae although your details will still be accessible to employees of the company.

If your curriculum vitae is not set to hidden, it will be accessible to anyone with access to the company’s curriculum vitae search application, in order to increase the visibility of that curriculum vitae and help the company find you a job. Where this occurs, you make your curriculum vitae, your name and other personal data that you place on your curriculum vitae available to third parties. Those third parties may be interested in you as an employee, and may forward your curriculum vitae to other third parties.

Your curriculum vitae will be displayed through our internal search engine when someone searches for your name. This means that third parties can view the personal data contained in your curriculum vitae.

– Changing your curriculum vitae privacy settings

You will be given the option to hide your curriculum vitae when you place your curriculum vitae on the site via the registration pages. You may adjust this at any point by editing your privacy settings.

3.5 Matching job seekers with employers

The company also runs a CV Watchdog service which automatically matches your curriculum vitae to saved searches that are made by employers who have contracted to use our “CV search” service.  When a match is made, your CV will be emailed directly to employers who will then contact you if your details are of interest for job opportunities that they may have at any given time.

3.6 Preventing fraud and spam

The company may also use information collected pursuant to this privacy policy to help diagnose problems with the site and the company’s service, to prevent potentially fraudulent or illegal activities, and to protect individuals from other activities that may be detrimental to you or others. The company may investigate and disclose information from or about you or your use of the company if we have a good faith belief that such investigation or disclosure (a) is reasonably necessary to comply with legal process (including subpoenas, search warrants, court orders) and law enforcement instructions and orders; (b) is helpful to prevent, investigate, or identify possible wrongdoing in connection with the use of the site; or (c) may protect our rights, reputation, property, safety, or that of the public; or (d) as necessary to meet national security requirements.

3.7 Automated processing of your personal data

In order to optimise the performance of the site and services for users, the company performs automated processing of personal data evaluating certain specific aspects relating to a user, in particular to analyse or predict aspects concerning a user’s personal preferences or interests in terms of the company’s site and services. Where it occurs, such processing is carried out if it is necessary for the performance of our agreement with our users, to allow the company to provide its services to job seekers and employers, or in other cases on the basis of a user’s consent.

For example, this allows the company to match job seekers with employers effectively, or provide job seekers with job listings they are more likely to be interested in. Such processing is subject to the safeguards detailed in this privacy policy and users may contact the data privacy officer (details at the bottom of this document) to get further information about this or to contest the decision generated by said automated processing.

3.8 Transfer of information to third parties

– Transfers to employers

Employers agree to comply with all their responsibilities under applicable data protection rules with respect to the collection, processing and storage of personal data, as well as providing adequate protection of all data subject rights provided for under all applicable data protection rules.

– Transfers to cloud service providers

Please also be aware that we may also use third-party cloud service providers that provide hosting, data storage and other services pursuant to standard terms and conditions that may be non-negotiable; these service providers have informed us or the general public that they apply security measures they consider adequate for the protection of information within their system, or they have a general reputation for applying such measures. However, we will not be liable (to the fullest extent permitted by law) for any damages that may result from the misuse of any information, including personal data, by these companies.

– Transfers of publicly available information

When users post content on the site in a manner that is intended to make that content publicly available and searchable by individuals, The company reserves the right to aggregate and share that information with third parties. For example, if an employer posts a job on the company, the company may share that job posting or information contained within that job posting with third parties, at the company’s discretion and subject to agreement between the company and any such third parties. The company also reserves the right to share information aggregated from public sources in this capacity.

– Third-party sites you link to

You may also use certain third-party sites or services that you link to from the company’s site. In such cases, all information you provide to a third party is provided to that third party and not to the company, and is subject to the third-party’s privacy policy and terms of service.

4. Additional uses and disclosures of non-personal data

In addition to the other uses and disclosures of information set forth in this privacy policy, and notwithstanding anything in this privacy policy to the contrary, we may use and disclose, for any purpose, any non-personal data, except where we are required to do otherwise under applicable law. If we combine any non-personal data with personal data, then we will only use and disclose such combined information for the purposes described in this privacy policy while it is so combined.

5. Security

The company seeks to use reasonable security measures to help protect against the loss, misuse and alteration of the personal data under the company’s control. No method of transmission over the internet, or method of electronic storage, is 100% secure, however. In addition, please note that emails, messages sent via your web browser, and other similar means of communication with other users, are not encrypted. Therefore, while we strive to protect your information, we cannot guarantee its security.

Please also be aware that we may use third-party cloud service providers that provide hosting, data storage and other services pursuant to standard terms and conditions that may be non-negotiable; these service providers have informed us or the general public that they apply security measures they consider adequate for the protection of information within their system, or they have a general reputation for applying such measures. However, we will not be liable (to the fullest extent permitted by law) for any damages that may result from the misuse of any information, including Personal data, by these companies. Please see section 11 of this Privacy policy for liabilities pertaining to the transfer of Personal data of individuals in the EU and Switzerland.

6. Cookies

A cookie is a data file that a website sends to your computer via your web browser. These files are safe as they are unable to spread any type of virus to your computer. Cookies are usually used to provide websites with user information for such activities as the tracking of web traffic (this would be done on an aggregate basis so as to keep users anonymous). Sites that have sent cookies to your computer will appear to 'remember' visitor information such as logins, preferences and other viewing habits.

Most web browsers will automatically accept cookies, however if you would prefer to decline them being sent to your computer, you should be able to modify your browser settings to do this. Please bear in mind though that doing so may prevent you from taking full advantage of this website.

7. Links to third-party sites

The site may make available links to other websites. When you click on such links, you may leave our site. The site may also make available company pages, which may contain information provided by third-party employers.

We are not responsible for the information collection, use, disclosure or other privacy practices of any third party, including our affiliates, third-party service providers, any employers (including any employer that provides a company page), any third-party social media platform, any third party making available the devices or operating systems for which the site is available, and any third party operating any website to which the site contains a link. You may have rights directly enforceable against these third parties so you should consider their privacy policies to learn more.

8. Exercising your rights with respect to your personal data

Users that provide their personal data in the EU, and those that provide their personal data in any other jurisdictions that adopt laws affording equivalent protections to those in the EU, may avail of the rights detailed below.

9.1 The right to rectify your personal data

The company users are able to edit and update most of their personal data held by the company on the site, and if you have any queries or complaints we encourage you to contact us.

9.2 The right to object to or restrict the processing of your personal data

If you have any queries or complaints about how we process your personal data we encourage you to contact us.

9.3 The rights of access to and portability of your personal data

Site users are able to access most of their personal data held by the company on the site, and if you have any queries or complaints we encourage you to contact us.

9.4 The right to delete your personal data

Site users are able to edit and update most of their personal data held by the company on the site, and if you have any queries or complaints we encourage you to contact us.

Alternatively, if you do not wish to do this, you may make a formal request to delete your personal data held by the company. In order to do so, please email the data controller (details below) from the email address associated with your account, and paste the following sentence in your email: “I am requesting to delete my personal data.” Your email should also attach a copy of your passport or national identity card (for identity verification purposes). Once your request has been confirmed, The company will initiate the necessary steps to execute this exercise, including the deletion of your account. Where the deletion request relates to personal data that you previously requested be made available (e.g. via your “my profile” page), we will make reasonable efforts to inform any other controllers of this request

9.5 Some limitations

Such rights of rectification, objection, restriction, access, portability and deletion are subject to certain limitations, as provided for by applicable laws. Individual requests will be completed within the time allotted by relevant regulations, which starts to run from the point of the company confirming your request.

10. Opting out

If you no longer want to receive marketing materials from us based upon your personal data, going forward, you may opt out of receiving such marketing related messages by sending an email to us. Please note that we may still send other messages to you, such as administrative messages. We will comply with your request as soon as reasonably practicable, and in accordance with applicable laws.

11. Contacting us

Contact details of the Data Privacy Officer:

Contact Name:	Ed Maala
Address line 1:	14 Bristol Gardens, London W9 2JG
Email:	ed.maala@retailappointment.co.uk
Telephone:	020 7432 8855