Buckleigh & Williams GDPR Policy
“Buckleigh & Williams Ltd welcomes the introduction of GDPR in May 2018 and is very conscious of information security. Buckleigh & Williams takes the security of personal data very seriously regardless as to whether our organisation is considered a data processor or data controller.” – Ian Buckley, Director
Buckleigh & Williams has been working towards being fully compliant with GDPR throughout 2017 & 2018 so that Buckleigh & Williams’ customers can be confident that they are dealing with a compliant organisation and that the security of their data is taken seriously.
In conjunction with GDPR compliance, Buckleigh & Williams have conducted comprehensive reviews of all activities across the business and how supporting data is processed. The company’s activities fall within three key areas:
- A data controller of its own employee data.
- A data controller or processor of third party data such as activity relating to direct marketing.
- A data processor or controller of candidate & client personal data
Buckleigh & Williams Ltd is registered as a Data Controller with the ICO, registration reference: ZA392879
- Following a full review and assessment of GDPR, Buckleigh & Williams is making changes to its activities and company policies/procedures where necessary in order to be fully compliant.
- Buckleigh & Williams is reviewing all of its suppliers for compliance with GDPR.
- Buckleigh & Williams is creating a detailed policy and ‘frequently asked questions’ document so that customers can clearly see Buckleigh & Williams’ activity in respect of GDPR.
- The Buckleigh & Williams website and any direct marketing that the organisation may send out is being updated so that customers have the confidence that any contact will be within GDPR guidelines. The website will contain Buckleigh & Williams updated privacy policies.
What we need.
Buckleigh & Williams Ltd only collect basic personal data which may include information about your current/previous job responsibilities and location based information for job purposes. This includes name, address, phone number, email address etc.
Why we need it.
We need to know your basic personal data in order to provide you with recruitment services in line with GDPR. We will not collect any personal data from you that we do not need in order to provide and oversee our recruitment services to you.
What we do with it.
All the personal data we have is processed by our staff in the UK, however for the purposes of IT hosting and maintenance, this information is located on our servers and no other parties have access to your personal data unless the law allows them to do so.
Please see the GDPR commitment statement from our CRM system ‘Bullhorn’ which is located online at:
Please also see below the GDPR statement from our timesheet system and payroll solution provider ‘Sonovate Limited’:
The General Data Protection Regulation, or GDPR, is due to come into force on 25th May 2018. This will replace the current Data Protection Act 1998 (DPA). Whilst many of the new legislation’s main concepts and principles are aligned with the current DPA there are new elements and significant enhancements to strengthen and unify data protection for all individuals within the European Union.
Over the last year, Sonovate has conducted a comprehensive cross-business review to identify any areas where changes are required to our current policies and procedures to achieve GDPR compliance. We have been engaging with legal data protection experts to ensure we interpret the new legislation correctly and apply it throughout the business. This approach has insured that Sonovate will establish and embed GDPR accountability principals to fully support our commitment to protecting all personal information held within our systems.
In conjunction with the GDPR compliance, we have conducted comprehensive reviews of all activities across our business and how supporting data is processed. As a result, we have full transparency of our data classifications, where data resides, including all aspects of our infrastructure architecture, backups & resilience, and how this is processed and secure.
Our platforms are all built on Microsoft Azure SaaS based cloud architecture, and we have again conducted comprehensive reviews of all additional third-party suppliers and their compliance with the new regulations.
At Sonovate, we have always taken data security and data privacy extremely seriously. Our aim has always been to provide our customers with the highest level of data security and be accountable for the information held on our applications. As such we regularly review and reinforce our security practices.
All customer data is stored within Microsoft UK & European data centres (for resilience purposes). Microsoft is committed to being GDPR compliant across all their cloud services when enforcement begins on May 25. Our commitment to using Microsoft cloud platforms stems from them being the first enterprise cloud services provider to implement rigorous controls governing the transfer of data outside of European Union, as the first cloud provider to achieve compliance with ISO’s important 27018 cloud privacy standards. Microsoft Azure has 53 major certifications and attestations – more than any other major public cloud provider.
When it comes to security, Microsoft’s visibility into the evolving threat landscape also helps us protect the data that moves through our systems. With a cloud footprint that includes over 100 datacentres and more than 200 cloud services, this ensures that we have robust solutions and procedures in place to support our business and secure our customer data.
Frequently asked questions
What personal data do you process?
Any data which relates to an identifiable person (Candidate). Name, address, mobile, email, National Insurance, passport, driving license, career history etc.
For what purpose do you process this personal data?
Data is collected for specific, legitimate and explicit purposes of providing recruitment services in order to help our clients find the right candidates for active and also non active positions within the hiring company’s organisation, and also to help candidates with their search for a new position either in the Contract or the Permanent job markets.
What are the risks to data subjects’ rights and freedoms if the personal data is destroyed, lost, altered, disclosed without authority, or accessed without authority.
Following a full review of our policies/procedures and also a full review of GDPR guidelines, we believe the risks are minimal as the information we obtain is contained solely in our CRM database or in some instances, the database of our timesheet/payroll solution providers CRM database (if permission is granted by the data subject). It is not shared with any outside third parties, except clients who a candidate’s skill set may be suitable for. In the event data is lost, altered or disclosed without authority etc. the candidate could report us to ICO which could mean fines of up 4% of our turnover. There could also potential compensation claims that can be made by the data subject. Non-financial risks include reputational damage as the ICO will name non-compliant organisations which would effect our reputation in the industry with our candidates & clients. The risks are high in relation to penalties, but this the same for all UK recruitment companies and we believe the risks are low. The worst case scenario is that the ICO could stop us processing personal data.
What provisions do you have in place to either delete or return the personal data once the service comes to an end?
When a data subject requests this, we will contact the data subject, discuss the deletion or return of records, and then remove accordingly. Otherwise it is our intention to keep the candidates details on our system, as this coincides with our “legitimate business interests” but is also in the interest of the data subject who may be seeking or open to a new job opportunity.
What provisions/training do you have in place to ensure that your employees process the personal data in accordance with Buckleigh & Williams’ instructions?
We have provided ‘on the job’ training to our staff so that they understand GDPR and have also prepared a specific training session including a PowerPoint presentation which fully explains GDPR and the responsibilities of Buckleigh & Williams and its staff members. All staff members have signed a document to confirm their understanding of the training provided in relation to GDPR.
What process do you have in place to avoid personal data breaches?
Adverts placed on job boards or similar recruitment websites will contain information outlining how we will process personal data in line with GDPR regulations.
Our GDPR policy is publicly available on our website.
Do you understand the GDPR requirements in detail and are you satisfied that you are aware of the impact these will have on your business?
Yes, we are happy that we have a good understanding of GDPR requirements and the impact they have on our business.
Do you anticipate full GDPR compliance by 25th May 2018 or before?
Has your work to date identified any changes that will be required to our relationship as a result of GDPR?
Buckleigh & Williams is committed to ensuring that your privacy is protected. Should we ask you to provide certain information by which you can be identified when using this website, then you can be assured that it will only be used in accordance with this privacy statement.
Buckleigh & Williams may change this policy from time to time by updating this page. You should check this page from time to time to ensure that you are happy with any changes.
What we collect
We may collect the following information:
Name and company name
Contact information including email address
Demographic information such as postcode, preferences and interests
Other information relevant to customer surveys and/or offers
What we do with the information we gather
We require this information to understand your needs and provide you with a better service, and in particular for the following reasons:
Internal record keeping.
We may use the information to improve our products and services. We may periodically send promotional emails about new products, special offers or other information which we think you may find interesting using the email address which you have provided.
We are committed to ensuring that your information is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect online.
Links to other websites
Our website may contain links to other websites of interest. However, once you have used these links to leave our site, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this privacy statement. You should exercise caution and look at the privacy statement applicable to the website in question.
Controlling your personal information
You may choose to restrict the collection or use of your personal information in the following ways:
We will not sell, distribute or lease your personal information to third parties. We may use your personal information to send you promotional information about third parties which we think you may find interesting if you tell us that you wish this to happen.
You may request details of personal information which we hold about you under the Data Protection Act 1998. A small fee of £10 will be payable. If you would like a copy of the information held on you please contact us via the form on our contact page.
If you believe that any information we are holding on you is incorrect or incomplete, please contact us. We will promptly correct any information found to be incorrect.
In this policy, “we” and “our” represents Buckleigh & Williams.
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