SENITOR ASSOCIATES LTD
Table of Contents
2 Who we are and how to contact us
3 The data we collect about you
4 How we collect personal data
5 How and why we use personal data
7 Automated decision-making
8 Change of purpose
9 If you fail to provide personal data
11 Who we disclose personal data to
12 International transfers
13 Data security
14 Data retention
15 Your rights in respect of your personal data
16 Changes to your personal data
We are a “data controller” for the purposes of data protection legislation. This means that we are responsible for deciding how we hold and use personal information about you. We are committed to protecting and respecting your privacy.
By using our site and services, we may collect, use, store and transfer different kinds of personal data about you. In respect of all users of our site, the personal data we may collect includes information you send to us when making an enquiry and electronic data which is processed when accessing or browsing our site. If you are using our site or our services as a job applicant ("applicant"),apply for a job or sign up to receive marketing emails from us, for example. We may also collect your personal data from third party sites when you respond to a job advertisement we have placed on a third party site or when you upload your details to a third party site to indicate you are looking for work.
Our site is not intended for children and we do not knowingly collect data relating to children.
We, Senitor Associates are a limited company registered in England and Wales under company number 3836767 and have our registered office at Senitor Associates Ltd, 3 Mellor Road, Cheadle Hulme, Cheadle, Cheshire, SK8 5AT
To contact us, please email firstname.lastname@example.org or telephone us on 0800 980 9535.
Personal data, or personal information, means any information relating to an identifiable individual. It does not include any data or information which relates to a person that cannot be identified or where the person's identity has been removed (ie anonymous data). It also does not include information relating solely to a business or other organisation, rather than to a person.
By using our site, we may collect, use, store and transfer different kinds of personal data about you, which we have grouped together as follows:
We do not collect any special categories of personal data about you, without gaining your explicit written consent (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). We will only collect information about criminal convictions and offences (including via DBS checks) where such processing is authorised by law and necessary for the role you have applied for. We shall inform you before collecting any such data.
We may also obtain your personal data from third parties, primarily when you respond to an advertisement we have placed on a third party job board or when you have uploaded your CV or other information to a third party site looking for work. From time to time, we may also obtain your information through third party social media platforms, such as LinkedIn, and from other referrers and clients who we work with. .
When you interact with our site, our systems will automatically collect Technical Data and Usage Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our Cookies Policy www.senitor.com/cookies and section 10 below for further details.
We also use automated Boolean searching to match applicants with available roles.
We will only collect and process your personal data where we have a legal basis to do so. The legal basis will vary depending on the manner and purpose for which we are collecting your personal information. Most commonly, we will use your personal data in the following circumstances:
We have set out in the table below a description of the ways we plan to use your personal data, and which of the legal bases we shall rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data on the basis of more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you require further detail about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
Type of data
Lawful basis for processing including basis of legitimate interest
To set up, manage access to, and maintain the security of, your online account for our site
Identity, Contact, Profile, Technical and Usage Data
Necessary for our legitimate interests (to conduct our business and perform our contracts with clients)
Consent – given at the time of registering an online account for our site and/or the Portal
To provide recruitment services to clients by displaying job adverts on our site or third party job boards, which may include assisting with the processing of applications (including CVs) submitted by individuals in response to such job adverts
Identity, Contact and Profile Data (of client representatives)
In the case of applicants, to process and manage job applications on behalf of and/or in consultation with clients
Identity, Contact, Profile and CV, Application Data and DBS checks (which will only be conducted where relevant/necessary to the role and with your prior knowledge)
Consent – we will ask you to consent to us passing on your personal data to clients at the point of submitting your application
If DBS checks are carried out, we will generally rely on the following grounds:
In some cases we will hire applicants directly to fulfil contract work on our behalf for a client. We will select which applicant is most suitable for the position.
Identity, Contact, Profile and CV, Application Data and DBS checks
To manage our relationship with you which will include:
Identity, Contact, Profile, Application, Social Media and Marketing and Communications Data
Necessary for our legitimate interests (to conduct our business and keep our records updated)
Necessary to comply with a legal obligation
To administer and protect our business and our site (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
Identity, Contact, Usage and Technical Data
Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security and to prevent fraud)
To deliver relevant website content and advertisements to you based upon your content preferences
Identity, Contact, Profile, Usage and Marketing and Communications Data
Necessary for our legitimate interests (to develop our services and grow our business)
To use data analytics to improve our website, services, marketing, customer relationships and experiences
Identity, Contact Technical and Usage Data
Necessary for our legitimate interests (to define types of customers for our services, to keep our business updated and relevant, to develop our business and to inform our marketing strategy)
To deal with and respond to queries submitted to us via our site, social media accounts, by post, email or by telephone
Identity, Contact, Social Media, Profile, Application and Marketing and Communications Data
Consent – given at the time of contact
Our legitimate interests (to conduct our business and correspond with applicants and clients)
Marketing and Recruitment communications from us: We may send you marketing and Recruitment communications if you:
We do not currently use purely automated decision-making.
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 wish 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.
We may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
Where we need to collect personal data from you in order to comply with our legal obligations or to perform a contract we have with you or your employer/hirer and you fail to provide that data when requested, we may not be able to perform the relevant contract (for example, to engage you as a contractor or provide your employer with services). In this case, we may have to cancel the relevant contract.
We may share personal data with the third parties set out below for the purposes set out in the table above. These third parties process your personal data on our behalf in connection with the performance of certain services for us. :
Name of Service Provider
Types of Personal Data
IT Support Provider
Identity, Contact, Profile CV, Application, Financial, Marketing and Communications Data
Identity, Contact, CV, Profile, Application, Technical and Usage Data.
This type of personal data is only shared through the website host as a processor if a data subject creates an online account with us
Data Analytic Software
Identity, Contact, CV and Application Data
Identity, Contact, Profile, CV, Application, Financial, Marketing and Communications Data
Time Sheet Solution Software
Identity, Contact, CV and Application Data
Email Marketing Platform
We have entered into a data processing agreement with the service providers listed above.
We require all our data processors to respect the security of your personal data and to treat it in accordance with the law. We do not allow our data processors to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions as set out in our data sharing agreements.
Many of our external third parties are based outside the Economic European Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data outside of the EEA.
We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need-to-know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality
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.
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for.
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.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) in order to develop our business methods and strategy or for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
If you are an applicant, we will retain your personal data for a period of 36 months from the point of last meaningful contact with you, with an additional month to process the deletion of data. Meaningful contact includes any email or telephone correspondence with you that has resulted in submission of an updated CV or a change to your personal information. We will keep this under review and may periodically delete some of your personal data which we no longer require for the purposes set out in the table above.
In some circumstances we may be entitled to retain your data for a longer period where we are under a legal obligation to do so, for example in the event of a legal dispute. We will also need to keep a record of your contact details if you have opted-out of receiving marketing communications from us to ensure we do not send these to you in future.
You have the following rights in respect of the personal data that we process about you (where we determine the purpose and means for which that personal data shall be processed):
If you wish to exercise any of the rights set out above in respect of your personal data, please contact our Data Compliance Officer at email@example.com .
We may ask you to verify your identity if you make a request to us to exercise any of the rights set out above. We may also contact you to ask you for further information in relation to your request to speed up our response. 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 is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO, so please do contact us in the first instance and we shall endeavour to resolve your complaint.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data (such as your contact details) changes during your relationship with us.
AP Last Updated 04.11.21 REVISION NO.4
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