Source Privacy Policy

1.1 We are committed to safeguarding the privacy of our website visitors and service users; in this policy we explain how we will handle your personal data.

 

This website is owned and operated by Source Personnel Limited. We are registered in England and Wales under registration number 05107695, and our registered office is at Wessex House, Teign Road, Newton Abbot, United Kingdom, TQ12 4AA. Our principal place of business is at Source, Work.Life, Rivington House, 82 Great Eastern Street, London, EC2A 3JF.

 

We are registered as a Data Controller with the Information Commissioner's Office under registration number Z8634031.

 

You can contact us:

 

(a) by post, using the postal address given above;

(b) using our website contact us page, or by telephone, on 020 3116 0000.

 

Our data protection officer's contact details are: Brooke Strachan, Source Personnel Ltd (address as above) who can be contacted on operations@wearesource.co.uk.

 

1.2 Our website incorporates privacy controls which affect how we will process your personal data. By using the privacy controls, you can specify whether you would like to receive direct marketing. You can adjust your privacy settings at any time by amending your preferences on the Member Dashboard section of our website or by emailing us.

 

1.3 We use cookies to provide website visitors and service users the best experience on our website. You can find out more at https://www.wearesource.co.uk/cookies-policy or switch them off if you prefer. However by continuing to use our website without changing your settings, you are agreeing to our use of cookies in accordance with the terms of this policy.

 

2.1 In this Section 2 we have set out:

 

(a) the general categories of personal data that we may collect and process;

(b) the purposes for which we may process personal data; and

(c) the legal bases of the processing.

 

2.2 We collect data about your use of our website and services ("usage data"). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is our analytics tracking system. This usage data may be processed for the purposes of analysing the use of the website and services. The legal basis for this processing is our legitimate interests, namely monitoring and improving our website and services.

 

2.3 We may collect your account data ("account data"). The account data may include your name and email address and any other information necessary to process salary payments or contract payments to you. The source of the account data may be you, or any contractor, intermediary or employer or with whom you have a relationship. The account data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. Where you have provided us with this information, the legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract. Where a third party has provided us with your account data, the legal basis will be our legitimate interests, namely the proper administration of our website and business.

 

2.4 We may process your information included in your personal profile on the Member Dashboard section of our website ("profile data"). The profile data may include your name, address, telephone number, email address, identity pictures, gender, date of birth, educational and employment details. The source of the account data may be you, or any contractor, intermediary or employer or with whom you have a relationship, such as social networking platforms, geo-location applications or other third parties who you have authorised to share personal information in accordance with their own privacy policies. The profile data may be processed for the purposes of enabling and monitoring your use of our website and services. Where you have provided us with this information, the legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract. Where a third party has provided us with this information, the legal basis will our legitimate interests, namely the proper administration of our website and business.

 

2.5 We may collect your personal data that are provided in the course of the use of our services or in connection with any application to work directly for us ("service data"). The use of your personal data in connection with our services pertaining to any permanent, freelance or contractor placement with our clients is set out in more detail in the Privacy Notice attached to our terms of business. Similarly the use of your personal data in connection with any application to be employed directly by Source is set out in the Privacy Notice relating to our direct recruitment process, which will be provided separately. The service data may include any information necessary for you to be placed in work and/or any information necessary for the correct processing of payments for such work, including any appropriate deductions and statutory reporting. The source of service data may be you, or any contractor, intermediary or employer or with whom you have a relationship. The service data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. Where you have provided us with this information, the legal basis for this processing is the performance of a contract between you and us and/or taking steps, at you request, to enter into such a contract. Where a third party has provided us with your account data, the legal basis will our legitimate interests, namely the proper administration of our website and business. 

 

2.6 We may process information contained in any enquiry you submit to us regarding products and/or services ("enquiry data"). The enquiry data may be processed for the purposes of offering, marketing and selling relevant products and/or services to you by us or our partners. The legal basis for this processing is your consent.

 

2.7 We process information that you provide to us for the purpose of subscribing and/or unsubscribing to our email notifications and/or newsletters ("notification data"). The notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.

 

2.8 We may process information contained in or relating to any communication that you send to us ("correspondence data"). The correspondence data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and communications with users.

 

2.9 We may process any of your personal data identified in the other provisions of this policy where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of- court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.

 

2.10 In addition to the specific purposes for which we may process your personal data set out in this Section 2, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person, or in relation to a documented legitimate interest that we may have.

 

3.1 We may disclose your personal data to any member of our group of companies (this means our subsidiaries, our ultimate holding company and all its subsidiaries) insofar as reasonably necessary for the purposes set out in this policy.

 

3.2 We may be required to disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining and maintaining insurance coverage, managing risks, obtaining professional advice and managing legal disputes.

 

3.3 We may disclose your personal data to our suppliers, subcontractors and clients insofar as reasonably necessary either for performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract, or for the purposes of providing our services.

 

3.4 Financial transactions relating to our website and services are handled by our payroll bureau. We will share transaction data with our payroll bureau to the extent necessary for the purposes of processing your payments, dealing with complaints and queries relating to such payments. You can find information about the payroll bureau privacy policies and practices at www.rsmuk.co.uk  and www.engagetech.com.

 

3.5 We may disclose your personal data to one or more of those selected third party suppliers of goods and services identified on our website for the purpose of enabling them to contact you so that they can offer, market and sell to you relevant goods and/or services. Each such third party will act as a data controller in relation to the enquiry data that we supply to it; and upon contacting you, each such third party will supply to you a copy of its own privacy policy at the point when they first make contact with you, which will govern that third party's use of your personal data. 

 

3.6 We may disclose your personal data to formally contracted service providers to perform services on our behalf (“data processors”), such as hosting data centers, cloud service providers, customer relationship management systems and others. We only contract data processors that provide sufficient guarantees to implement appropriate technical and organisational measures in such a manner that processing will meet the requirements of data protection law and ensure the protection of your rights. Where those data processors engage sub-processors, their contractual relationship shall be subject to the same data protection obligations as those in our contract with them.

 

3.7 In addition to the specific disclosures of personal data set out in this Section 3, we may also disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person, or in relation to a documented legitimate interest that we may have.

 

4.1 Neither we nor any of our data processors transfer personal data to countries outside of the European Economic Area (EEA).

 

5.1 This Section 5 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.

 

5.2 Personal data that we process for any purpose or purposes shall not be kept for longer than necessary for the fulfillment of that purpose or those purposes.

 

5.3 Except where it is stated that we will retain your data for a shorter period in any separate applicable Privacy Notice, we will retain and delete your personal data for a period of 6 years from the date we receive your information, such as receiving your CV or registering on our website; you accept an interview through us with any potential hirer; you accept of any offer of a permanent or fixed term employment or engagement; or you have ceased any contracting role with us; whichever is the longer at the end of which period it will be deleted from our systems.

 

5.4 Notwithstanding the time periods set out in clause 5.3, where we have legitimate cause we may extend the period in which we hold your personal data by up to a further six years, subject to obtaining your permission to do so in writing.

 

5.5 Notwithstanding the other provisions of this Section 5, we may also retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person, or in relation to a documented legitimate interest that we may have.

 

6.1 In this Section 6, we have summarised the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights. This restatement is to serve as a reference and is not intended to extend in any way your statutory rights which are subject to certain limitations and exceptions. 

 

6.2 Your principal rights under data protection law are:

 

(a) the right to be informed;

 

(b) the right to access;

 

(c) the right to rectification;

 

(d) the right to erasure;

 

(e) the right to restrict processing;

 

(f) the right to object to automated decision making and profiling;

 

(g) the right to data portability;

 

(h) the right to complain to a supervisory authority; and

 

(i) the right to withdraw consent.

 

The exercise of the rights in 6.2 (d)-(f) shall be communicated to all parties we have disclosed your information to, in accordance with Section 3.

 

You can find more information on your statutory rights on the ICO's website.

 

6.3 You have the right to be informed about any processing we undertake relating to your personal data. The information we must provide in relation to such processing is prescribed in law and is set out in this Privacy Policy. We ask you to accept this policy before you provide us with your personal data. Where we have obtained your personal data from third parties, including parties hosting publicly available information, we will identify any such third parties and provide you with a copy of (or link to) this Privacy Policy at the time as we first contact you.

 

6.4 You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. You may access your own personal data by visiting the website address in the link provided at registration.

 

6.5 You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.

 

6.6 In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are certain general exclusions of the right to erasure. Those general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims.

 

6.7 In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.

 

6.8 You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.

 

6.9 You have the right to opt-out to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.

 

6.10 To the extent that the legal basis for our processing of your personal data is consent, or required for the performance of a contract, and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.

 

6.11 If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.

 

6.12 To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.

 

6.13 You may exercise any of your rights in relation to your personal data by way of a written request to us. Our actions taken with respect of enforcing your rights shall be free of charge, unless your requests are repetitive in nature. We must verify your identity before we can deal with your request. Insofar as it is possible, we shall respond to you within 30 calendar days of receiving your written request. 

 

7.1 We may update this policy from time to time by publishing a new version on our website.

 

7.2 You should check this page occasionally to ensure you are happy with any changes to this policy.

 

7.3 We may notify you of changes to this policy by email or through the private messaging system on our website.