Who are Project People?
Project People Limited is part of a group of companies involved in recruitment, payment and corporate service provision. Our contact details and office locations within the group are available here.
Why do you process personal data?
Commercially, in order to place those available for work with our client base of national and international employers.
We also process personal data as an employer, business partners, and through surveillance of our places of business.
This notice, and its relevance to you, regards our commercial processing of data.
How might you collect personal data for your commercial purposes?
- Directly from you – we have an active website where you can set up a user account and submit your CV in order to be considered for roles. If you are placed by Project People, you would then provide additional personal data in order to service your employment contract.
- From LinkedIn – LinkedIn is a commonly used tool where professionals can share their personal information. We subscribe to facilities where members looking for roles can make their CVs searchable.
- From Job Boards – there are many websites which specialise in aggregating the CV information of those interested in new roles internationally. We subscribe to a select number where members looking for roles can make their CVs searchable.
- From your own contacts – if any of your contact circle are lawfully approached for a role by Project People, they may recommend you and pass on contact details.
What categories of data do you routinely process?
While we appreciate that every CV will be different, it is likely that all CVs we receive or acquire will contain some or all of:
- Your basic personal information (name, address, date of birth, education history, personal preferences)
- Your employment history and referee information
- Contact information (phone, email and/or applications).
If you are successfully placed into a role, we would go on to process:
- Tax and national insurance information
- Payment-related information (e.g. bank details)
- Usernames and passwords for our iResource timesheet application
A more extensive list of data fields we routinely process, including “special category” data (see below) can be viewed here.
Is there personal data I am compelled to provide?
Yes. Many of our clients have either contractual or statutory requirements including criminal records checks, security clearances and CV accuracy tests. If those requests are not satisfied, you will be unable to continue with your application.
What about sensitive data such as criminal records?
There are “special categories” of personal data which we need on an additional legal basis to process in the context of recruitment. The UK Data Protection Act contains conditions which allow for it, as listed below:
UK DPA Sch.3 s.1 – we check with you directly whether you have unspent criminal convictions during the qualification process. You do not have to consent to this, though our clients will not onboard anyone without having completed this check.
UK DPA Sch.1 s.2 – we process data relating to absences as a product of keeping time records for your payment
Racial or ethnic origin
UK DPA Sch.1 s.1 – if not already in your CV (e.g. nationality), by virtue of establishing your right to work or validating your identity prior to commencing a contract, we would process enough data to establish or infer your race or ethnicity.
We also have an internal Data Protection Policy which details our internal controls designed to offer additional protection to these categories.
Should we inadvertently process any “special category” data (for example, you provide it in the free text of a CV), it will be as secure as all other data stored at Project People, though we will not screen individual CV submissions to remove it.
On what basis do you do this?
- Contract – if we have a contract to provide services to you, we must process certain personal data in order to perform it.
- Consent – if we would like to hold your data and qualify you for future work opportunities, we will ask you for permission to hold it. You can withdraw that consent at any time by unsubscribing to our emails or directly with a consultant if telephoned.
- Legal requirement – if we are compelled to hold your personal information for legal reasons (for example, tax law), we would hold it until that reason is no longer valid.
- Legitimate Interest – if we lawfully acquire your personal data through a job board or other aggregation site, we would contact you if a role which matches your skillset emerges.
What are Project People’s “legitimate interests”?
Our interests are to place available candidates into permanent and contract roles available with our clients and profit from that activity.
We have assessed whether our interests outweigh your fundamental rights, and we believe that in this context our interests are actually aligned.
Can I withdraw consent?
Yes, at any time. This will constrain future processing, though it will not invalidate processing already performed.
Who will receive my data from you?
- Customers of Project People – and only with your consent
- Third parties involved in your onboarding – all of whom have contractual obligations to protect your data.
- Third parties involved in your payment – all of whom have contractual obligations to protect your data.
- Project People group companies – depending on both your and any prospective employer’s location.
Do you transfer personal data internationally?
Yes – while all candidate data under our control is stored in the United Kingdom, we process data (e.g. collect, administer, view, amend, etc.) both in the EEA and non-EEA territories in the Project People Group, with standard contractual clauses deployed where necessary to ensure your privacy is protected to EU standards.
Is any element of personal data storage outside of your control?
For contractors working through Project People, our time recording software is hosted by Amazon Web Services in an EU-based cloud storage system.
Outside of this, the other parties to whom we would transfer your data either have a legal right to it (e.g. tax authorities) or are clients of Project People.
All of Project People’s commercial parties and service providers have contractual commitments to lawfully process personal data transferred to them by us.
How long will you retain personal data for?
Subject to statutory obligations to retain personal data records:
- No longer than 6 years after you finish working through us
- No longer than 5 years after putting you forward for a role
- No longer than 6 months after processing “special category” data such as criminal record check
- No longer than 30 days after acquiring your data from a Job Board/aggregator without making contact with you
- We would always dispose of any personal data upon request, subject to any legal grounds for its retention
What rights do I have in respect of the personal data you control?
As a data subject, you have the right to:
- Access any data we process which relates to you
- Have that personal data provided in a machine readable format
- Have your personal data erased from our records
- Object to any processing by Project People
- Restrict any processing under certain circumstances, such as if you question its accuracy
- Not be subjected to automated processing
By simply issuing a request to Project People’s Head Office through a conventional route (post, email, phone), we will process that request. If for any reason we lawfully refuse it, we will inform you of the rationale and your options.
Is any of this processing automated?
Only operationally through the use of computers in running Project People.
Personal data is never processed within Project People though algorithms or automated decision making, and all profiling (for example, to produce a shortlist of candidates) is performed manually, using keyword searches.
Who can I complain to if I am unhappy about your personal data processing?
We would always endeavour to satisfy your requests in the first instance, and you can contact our Data Protection Officer with any queries.
You can at any time contact our Lead Supervisory Authority (the UK Information Commissioner’s Office) at this location, or if you prefer, use your national data protection authority to escalate issues regarding our conduct.
Who is your Data Protection Officer?
You can contact our Data Protection Officer on firstname.lastname@example.org or through our UK Head Office on +441179087000