Zenjob Limited Privacy Policy

  1. Overview

Zenjob is committed to protecting the privacy and security of individuals’ personal data.  In this notice, “Zenjob”, “we”, “us” or “our” refers to Zenjob Limited (company number 13668885), whose registered address is at First Floor, 1 Cottesbrooke Park, Heartlands Business Park, Daventry, Northamptonshire, NN11 8YL.  We are registered with the Information Commissioner under registration number ZB241769.

This privacy notice describes how we collect and use your personal data via the website at www.zenjob.co.uk, via our mobile app or otherwise during your relationship with us.  We will always act in accordance with the UK General Data Protection Regulation (UK GDPR) and other applicable data protection laws in the UK. Zenjob is a “controller”. This means that we are responsible for deciding how we hold and use personal data about you. We are required under data protection law to notify you of the information contained in this privacy notice.

Should you have any queries about anything in this privacy notice, please contact us by email at [email protected].

Please note that links from our website or app may take you to external websites which are not covered by this policy. We recommend that you check their privacy policies before submitting any personal data to such sites. We will not be responsible for the content, function or information collection policies of these external websites.

Data protection principles

We will comply with data protection law. This says that the personal data we hold about individuals must be:

  • Used lawfully, fairly and in a transparent way.
  • Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
  • Relevant to the purposes we have told you about and limited only to those purposes.
  • Accurate and kept up to date.
  • Kept only as long as necessary for the purposes we have told you about.
  • Kept securely.

 

  1. The kind of information we hold about you

Personal data means any information about an individual from which that person can be identified, either on its own or together with other information. This term does not include anonymous data.

There are certain types of more sensitive personal data that require a higher level of protection, such as information about a person’s health, beliefs, trade union membership or sexual orientation. Information about criminal convictions also warrants this higher level of protection.

We will collect, store and use the following categories of personal data about all users of our website or app:

  • Name
  • Email address
  • IP addresses, device information, mobile network information, language settings and other online identifiers from your use of our website/app
  • Information that you may make available when contacting us

 

If you are a client contact, we may also collect, store and use the following categories of personal data about you:

  • Role
  • Telephone number
  • Work address
  • Bank account details

If you complete a profile to register as an agency worker (“talent”), we may also collect, store and use the following categories of personal data about you:

  • Date of birth
  • Gender
  • Passport, driving licence or other identification documents used in verifying your identity
  • Evidence of your right to work in the UK, if applicable
  • National Insurance number
  • Bank account details and tax status information
  • Current/historic salary and benefits information or similar information about your current or recent role(s)
  • Details of your qualifications, experience and any professional memberships
  • Information about any assignments you undertake via Zenjob, including start and end date, remuneration, any performance information provided by our client
  • Feedback our clients may provide if you attend an interview for a potential assignment
  • Location data from your mobile device
  • Photographs, video footage and any other information you may make available via social media if you choose to interact with Zenjob’s social media channels

 

We may also collect, store and use the following more sensitive types of personal data about talents, such as:

  • Information about your race or ethnicity, religious beliefs, sexual orientation and political opinions.
  • Any medical condition and, where relevant to the role in question, your covid-19 vaccination status
  • Information about criminal convictions and offences.

This is explained in more detail at section 5 below.

  1. How is your personal data collected?

We collect personal data from you directly.  If you are a client, we may also gain information about your organisation from your own website, social media feeds, the press and Companies House.  If you are a talent, we may sometimes collect additional information from:

  • clients to whom we have introduced you
  • individuals or organisations you name as referees
  • the Disclosure and Barring Service, if DBS checking is relevant to the role in question or you have provided evidence of an existing DBS check
  • social media accounts you use to interact with Zenjob’s social media accounts
  • the electoral register or other public records we may use to verify your identity or eligibility to work
  1. How we will use information about you

We will only use your personal data when the law allows us to do so. Most commonly, we will use your personal data in the following circumstances:

  • Where we need to perform the contract we have entered into with you.
  • Where we need to comply with a legal obligation.
  • Where it is necessary for legitimate interests pursued by us or a third party and your interests and fundamental rights do not override those interests.
  • Where you have consented to the use of your data. Any consent must be freely-given, specific, informed and unambiguous, and you are entitled to withdraw consent if you later change your mind.

Situations in which we will use your personal data

We need all the categories of information in the list above to provide our website or app for your use.  If you are a client seeking workers, or a talent seeking work, we also need to use personal data in order to perform our contract with you and to enable us to comply with related legal obligations. In some cases, we may use your personal data to pursue legitimate interests, provided your interests and fundamental rights do not override those interests. The situations in which we will process your personal data are listed below.

Purpose/Activity

 

Type of data

 

Lawful basis for processing including basis of legitimate interest  
All website/app users
Creation and management of online user accounts Name, email address Necessary to provide our services  
Contacting you with service messages or to respond to any enquiries or complaints you may have Name, email address; information you may share in connection with an enquiry or complaint Legitimate interest in bringing key service messages to your attention and also in ensuring good customer service  
Contacting to you to promote opportunities, services or events you may find useful Name, email address (a)      Legitimate interest for client contacts

(b)      Consent, where individuals have signed up for such mailing list options

 
To ensure network and information security, including preventing unauthorised access to our computer and electronic communications systems and preventing malicious software distribution. IP addresses, device information and other online identifiers Legitimate interest in providing secure online systems and protection of data

Consent given to the installation of our app on your device, if using the app

 
To collect and analyse information about your use of our services and ensure you are easily able to navigate our website/app. Data collected by cookies in use on our website/app (see section 12 below for more information) (a)      Legitimate interest for essential cookies needed for our website/app to function

(b)      Consent, if cookies are non-essential

 
Clients
To take and keep a record of opportunities we are assisting (or have assisted) you with and to provide suitable candidates Name, email address, telephone number, postal address; any information you may share about your personal requirements for the role or your ways of operating; any information that may be publicly available about your organisation. (a)      Necessary to perform our contract with you

(b)      Legitimate interest in providing a good service to clients

 

 
To liaise with you regarding contract management and payment Name, email address, telephone number, postal address; bank account details. Necessary to perform our contract with you

 

 
Confirm identity and complete new client due diligence and anti-money laundering checks, along with credit checks where appropriate Passport, driving licence or other identification documents; Companies House or other publicly-available information about key individuals (a)      Legal obligation

(b)      Legitimate interest in ensuring new client are of good credit standing

 
Talents
To put you forward for relevant assignments in which you express an interest Name, contact details, date of birth; work and education history, professional memberships; any information you have made available that is relevant to client requirements for the assignment Performance of a contract  
To undertake any necessary identification and eligibility to work checks Name, address, date of birth; work history; identification documents; publicly-available information (a)      Legal obligation to confirm identification and eligibility

(b)      Legitimate interest in assisting clients with such checks in connection with a potential assignment

 
To show you work opportunities that are convenient to your location Mobile device location data Legitimate interest in suggesting suitable local opportunities to you  
Paying you (and deducting tax and National Insurance contributions (NICs)) and providing other contractual benefits, or assisting clients in undertaking these obligations Name, addresses; bank details; any health information relevant to benefit provision; contact details and health information relating to other beneficiaries of benefits, if applicable (a)      Legal obligation to deduct at source and report on tax matters

(b)      Legitimate interest in assisting clients with such obligations

 
To generate internal reports to analyse efficiency of procedures and improve service provision Name; details of assignment history via Zenjob; any feedback provided by you or by clients Legitimate interest in developing and improving services for both clients and talents  
In monitoring premises security by the use of CCTV Images/video footage Legitimate interest in ensuring secure environments for working and training  

Some of the above grounds for processing will overlap and there may be several grounds which justify our use of your personal data.

If you fail to provide personal data

If you fail to provide certain information when requested, we may not be able to perform the contract we have entered into with you, such as putting a talent forward for a potential assignment.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent where this is required or permitted by law.

  1. How we use particularly sensitive personal data

“Special categories” of personal data, such as information about your health, racial or ethnic origin, sexual orientation or beliefs, require higher levels of protection. We need to have further justification for collecting, storing and using this type of personal data. In general, we will not process sensitive personal data about you unless it is necessary for performing or exercising obligations or rights in connection with assignments. On rare occasions, there may be other reasons for processing, such as it is in the public interest to do so. We have in place an appropriate policy document (where applicable) and safeguards which we are required by law to maintain when processing such data.

We may process special categories of personal data in the following circumstances:

  • Where we need to carry out legal obligations or exercise rights in connection with recruitment for assignments, for example in verifying identity.
  • Where it is needed in the public interest, such as monitoring covid-19 infection rates (including vaccination status) or managing safeguarding concerns if client work relates to vulnerable persons.
  • If we reasonably believe that you or another person are at risk of harm and the processing is necessary to protect you or them from physical, mental or emotional harm or to protect physical, mental or emotional well-being.
  • In limited circumstances, with your explicit written consent.
  • Less commonly, we may process this type of information where it is needed in relation to legal claims or where you have already made the information public.
  • We may use information about your race or national or ethnic origin, religious, philosophical or moral beliefs, or your sexual life or sexual orientation, to ensure meaningful equal opportunity monitoring and reporting.

Information about criminal convictions

We may only use information relating to criminal convictions where the law allows us to do so. This will usually be where such processing is necessary to carry out our obligations and provided we do so in line with our data protection policy.

We will only collect information about actual or alleged criminal convictions if it is appropriate when collecting information about talents’ appropriateness for assignments, as part of the onboarding process or in connection with any additional information disclosed to us during our relationship.

We are permitted to use personal data in this way for reasons of substantial public interest. We have in place an appropriate policy and safeguards which we are required by law to maintain when processing such data.

  1. Automated decision-making

Automated decision-making takes place when an electronic system uses personal data to make a decision without human intervention. If we make an automated decision we must also put in place appropriate measures to safeguard your rights. We do not envisage that any decisions will be taken about you using automated means, however we will notify you in writing if this position changes.

  1. Data sharing

Service providers

We may have to share your data with third parties in order to provide services to you, including third-party service providers, other entities within our group as part of our regular reporting activities, or in the context of a business reorganisation. We do not allow our third-party service providers to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions.

We require such third parties to respect the security of your data and to treat it in accordance with the law.

Which third-party service providers process my personal data?

“Third parties” includes third-party service providers and other entities within our group. The following activities are carried out by third-party service providers who may have access to personal data: IT services including web/app hosting, data/document management systems, marketing and website design agencies.

What about other third parties?

We will share client data with talents and talent data with clients in accordance with this privacy policy and as required to provide the relevant recruitment or work-finding services.

We may need to share your personal data with a regulator or otherwise to comply with the law. This may include providing information to HMRC, disclosures to stock exchange regulators and disclosures to shareholders such as directors’ remuneration reporting requirements.

We may also share your personal data with other third parties, for example in the context of the possible sale or restructuring of our business. In this situation we will, so far as possible, share anonymised data with the other party before the transaction completes. Once the transaction is completed, we will share your personal data with the other parties if and to the extent required under the terms of the transaction.

Please note that these third parties will use data for their own purposes and in accordance with their own privacy policies.  Talents should also remember that any data they provide directly to a client will be used in accordance with the client’s own privacy policy.

  1. Transferring information outside the UK

We may transfer the personal data we collect about you outside the UK. If this is the case, we will ensure appropriate safeguards are in place so your data is protected to the same standard as would be required by laws in the UK.

  1. Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality. Details of these measures are available on request.

We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.

Please note that we are not responsible for third parties who use your personal data for their own purposes.  You should refer to the privacy policy of any relevant third party for more information.

  1. Data retention

How long will you use my information for?

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

For talents, we will retain information relating to your current and historic roles, professional memberships and education for a period of six months following any unsuccessful application for an assignment, unless you have opted to be included within our talent pool, in which case this information will be retained for use in connection with other suitable assignments.

In some circumstances we may anonymise your personal data so that it can no longer be associated with you, in which case we may use such information without further notice to you. Once we no longer need your personal data, or you ask us to delete anything, we will securely destroy your personal data.

  1. Data subject rights

Your duty to inform us of changes

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes.

Your duty in respect of other data subjects

If you provide us with personal data relating to anyone other than yourself – for example, if clients disclose information about current employees or a talent discloses identification paperwork in the joint name of a spouse – you are responsible for bringing this privacy notice to their attention and ensuring they understand and agree to your sharing their personal data with us.

Your rights in connection with personal data

Under certain circumstances, by law you have the right to:

  • Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
  • Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
  • Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have exercised your right to object to processing (see below).
  • Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object if we are processing your personal data for direct marketing purposes.
  • Request the restriction of processing of your personal data. This enables you to ask us to suspend the processing of personal data about you, for example if you want us to establish its accuracy or the reason for processing it.
  • Request the transfer of your personal data to another party.

If you want to exercise any of these rights, please contact us (see contact details at section 1 above).

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal data is not disclosed to any person who has no right to receive it.

Right to withdraw consent

In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal data for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact us (see contact details at section 1 above). Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.

  1. Cookies

A cookie is a small file of letters and numbers that we may store on your browser or the hard drive of your device. Cookies contain information that is transferred to your device’s hard drive.

We may use the following cookies:

  • Strictly necessary cookies. These are cookies that are required for the operation of our website/app. They include, for example, cookies that enable you to log into secure areas.
  • Analytical cookies. These allow us to recognise and count the number of visitors and to see how visitors move around our website/app when they are using it. This helps us to improve the way our services works, for example, by ensuring that users are finding what they are looking for easily.
  • Preference cookies. These are used to recognise you when you return to our website/app. This enables us to personalise our content for you, greet you by name and remember your preferences.
  • Marketing cookies. These cookies record your visit to our website/app, the pages you have visited and the links you have followed. We will use this information to make our website/app and any advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.

For details of the cookies we use, please see the cookie notice on our website/app.

Please note that the following third parties may also use cookies, over which we have no control. These named third parties may include, for example, advertising networks and providers of external services like web traffic analysis services. To deactivate the use of third party advertising cookies, you may change your browser settings.

  1. Changes to our Privacy Policy

Any changes we make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by email. Please check back frequently to see any updates or changes to our privacy policy.

This version was last updated on 1 February 2022.

  1. Complaints

If you wish to make a complaint about our collection or use of your personal data, please contact us (see contact details at section 1 above) in the first instance so that we may seek to resolve your complaint.

You have the right to lodge a complaint with the Information Commissioner’s Office (ICO), the UK data protection regulator, but we would prefer to try and resolve any queries with you directly.