Ten2Two Privacy Policy

(Updated June 2023)

1.    Our contact details

Name:         Deborah O’Sullivan
Address:    Berkhamsted Hse, 121 High Street, Berkhamsted, Herts, HP4 2DJ
Phone:        01442 503737
Email:        ruth@ten2two.org

At Ten2Two we are committed to keeping your personal data safe and secure, and handling it in accordance with our legal obligations. This Privacy Policy sets out the purposes for which we process your personal data, who we share it with, what rights you have in relation to that data and everything else we think it's important for you to know.

Ten2Two (the Company) is a recruitment business which provides work-finding services to its clients and work-seekers. The Company must process personal data (including sensitive personal data) so that it can provide these services – in doing so, the Company acts as a data controller. 

You may give your personal details to the Company directly, such as on an application or registration form or via our website, or we may collect them from another source such as a jobs board. The Company must have a legal basis for processing your personal data. For the purposes of providing you with work-finding services and/or information relating to roles relevant to you we will only use your personal data in accordance with the terms of the following statement. 

2.    Collection and use of personal data

a. Purpose of processing and legal basis

The Company will collect your personal data (which may include sensitive personal data) and will process your personal data for the purposes of providing you with work-finding services. This includes for example, contacting you about job opportunities, assessing your suitability for those opportunities, updating our databases, putting you forward for job opportunities, arranging payments to you and developing and managing our services and relationship with you and our clients. 

In some cases we may be required to use your data for the purpose of investigating, reporting and detecting crime and also to comply with laws that apply to us. We may also use your information during the course of internal audits to demonstrate our compliance with certain industry standards.

The legal bases we rely upon to offer these services to you are:

•    Your consent
•    Where we have a legitimate interest 
•    To comply with a legal obligation that we have
•    To fulfil a contractual obligation that we have with you

b. Legitimate interest

This is where the Company has a legitimate reason to process your data provided it is reasonable and does not go against what you would reasonably expect from us.  Where the Company has relied on a legitimate interest to process your personal data our legitimate interests is/are as follows:

•    Managing our database and keeping your work-seeker records up to date; 
•    Contacting you to seek your consent where we need it; 
•    Providing work-finding services to you, including sending your information to clients where you have demonstrated an interest in doing a particular role; 
•    Contacting you with information about similar products or services you have used from us recently.

c. Recipient/s of data

The Company may process your personal data and/or sensitive personal data with the following categories of recipients:

•    Clients that we introduce or supply individuals to.
•    Candidates’ former or prospective new employers to obtain or provide references to.
•    Payroll service providers who manage payroll on our behalf
•    Some public information sources and third party organisations to carry out suitability checks on work-seekers
•    Other recruitment agencies in the supply chain 
•    IT and CRM providers contracted by Ten2Two
•    Government, law enforcement agencies and other regulators 
•    Any of Ten2Two group companies or companies Trading As Ten2Two; and 
•    Any other organisations you ask us to share your data with. 

d. Statutory/contractual requirement

Your personal data is required by law and/or a contractual requirement (e.g. our client may require this personal data), and/or a requirement necessary to enter into a contract.  Recruitment businesses must collect certain personal data to meet statutory obligations, such as the Conduct of Employment Agencies and Employment Businesses Regulations 2003 – for example, they have to check identity, right to work, suitability for the role, qualifications and experience

You are obliged to provide the personal data and if you do not the consequences of failure to provide the data are that we may not be able to introduce or supply a work seeker to a client.

e.    Categories of data

The Company may collect the following personal data on you from your registration form and CV:

•    Name, address, mobile number, email
•    Career history
•    Any other data included on your CV

3.    Overseas Transfers  

The Company will not transfer the information you provide to us to countries outside the European Economic Area (‘EEA’) for the purposes of providing you with work-finding services. The EEA comprises the EU member states plus Norway, Iceland and Liechtenstein. 

4.    Data retention

The Company will retain your personal data only for as long as is necessary for the purpose we collect it. Different laws may also require us to keep different data for different periods of time. 

The Conduct of Employment Agencies and Employment Businesses Regulations 2003, require us to keep work-seeker records for at least one year from (a) the date of their creation or (b) after the date on which we last provide you with work-finding services.

We must also keep your payroll records, holiday pay, sick pay and pensions auto-enrolment records for as long as is legally required by HMRC and associated national minimum wage, social security and tax legislation. 

Where the Company has obtained your consent to process your personal and sensitive personal data we will do so in line with our retention policy. Upon expiry of that period the Company will seek further consent from you. Where consent is not granted the Company will cease to process your personal data and sensitive personal data. 

5.    Your rights

Please be aware that you have the following data protection rights:

•    The right to be informed about the personal data the Company processes on you;
•    The right of access to the personal data the Company processes on you;
•    The right to rectification of your personal data;
•    The right to erasure of your personal data in certain circumstances;
•    The right to restrict processing of your personal data;
•    The right to data portability in certain circumstances;
•    The right to object to the processing of your personal data that was based on a public or legitimate interest;
•    The right not to be subjected to automated decision making and profiling; and
•    The right to withdraw consent at any time.

Where you have consented to the Company processing your personal data and sensitive personal data you have the right to withdraw that consent at any time by contacting the Data Protection Officer Deborah O’Sullivan at deborah@ten2two.org or calling 01442 503727.

There may be circumstances where the Company will still need to process your data for legal or official reasons. We will inform you if this is the case. Where this is the case, we will restrict the data to only what is necessary for the purpose of meeting those specific reasons. 

If you believe that any of your data that the Company processes is incorrect or incomplete, please contact us using the details above and we will take reasonable steps to check its accuracy and correct it where necessary. 

You can also contact us using the above details if you want us to restrict the type or amount of data we process for you, access your personal data or exercise any of the other rights listed above.

6.    Automated decision-making

The company sometimes uses automated decision-making, including profiling, to target job vacancies to appropriate individuals.  This involves considering geographic proximity to the role in question along with key skills searching from CV’s.  The aim is to present as broad a selection of roles to candidates as possible.

7.    Data security

The Company takes every precaution to protect our users’ information. We use industry standard encryption software, virus protection and secure servers to protect your data.

Only employees who need the information to perform a specific job (for example, Consultants, Resourcers) are granted access to your information.

The Company uses all reasonable efforts to safeguard your personal information.  However, you should be aware that the use of email/the Internet is not entirely secure and for this reason the Company cannot guarantee the security or integrity of any personal information which is transferred from you or to you via email/ the Internet.

If you share a device with others we recommend that you do not select the “remember my details” function when that option is offered.

For your own on-line security, make sure you do not share passwords and do not include the following details on your CV:

•    National Insurance number
•    Passport number
•    Driving licence details
•    Date of Birth
•    Any bank details
•    Any credit card details

8.    Complaints or queries

We are committed to keeping your personal data safe and secure, and handling it in accordance with our legal obligations. However, if you wish to complain about this privacy policy or any of the procedures set out in it please contact: Deborah O’Sullivan on 01442 503727 or deborah@ten2two.org and we will do our very best to resolve any issues.

You also have the right to raise concerns with Information Commissioner’s Office on 0303 123 1113 or at https://ico.org.uk/concerns/, or any other relevant supervisory authority should your personal data be processed outside of the UK, if you believe that your data protection rights have not been adhered to.

9.    Other Information

Ten2Two also collects other information that enables us to track website usage, assess the effectiveness of our marketing campaigns and improve site design and usability.

10.    Email Newsletters

Members of our service will receive regular e-mail newsletters. This service is entirely optional and you may unsubscribe at any time.

11.    Other Websites Links

This website contains links to many other websites. This privacy policy applies only to our website. We are not responsible for the privacy practices within any other websites. You should always be aware of this and we encourage you to read the privacy statement on any other website which collects personal information.

12.    Cookies policy

You can view our cookies policy here.

13.    Changes to this privacy statement

We will update this privacy statement from time to time.  We will post any changes on the statement with revision dates.  If we make any material changes, we will notify you.

14.    How to Contact Us

Should you have other questions please send us an email at: ruth@ten2two.org