Privacy Notice

This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Winborough is committed to protecting and respecting the privacy of our clients, employees, candidates and any users of our services. Please read this privacy policy carefully so that you can understand our views and practices regarding your personal data and how we will treat it.

Identity and contact details of the Controller

Winborough Technologies Limited is a company registered in England and Wales (Registration number 4004007). Our registered offices are at Basepoint Business Centre, 377-399 London Road, Camberley, Surrey GU15 3HL and we are registered as a data controller in the United Kingdom for the purposes of the Data Protection Act 1998 or UK legislation resulting from EU General Data Protection Regulations (GDPR).

Personal data: Purposes of collection and use

Winborough may receive or collect your personal data including but not limited to your name and contact details (i.e., address, home and mobile numbers, e-mail address), age, date of birth, details of your qualifications, experience, employment history or any other relevant information from your CV, details of your referees, your nationality and immigration status and information from related documents, such as your passport or other identification and immigration documents (for example, identity card), a copy of your driving licence, emergency contacts and details of any dependants, financial information, and any other relevant information. On occasions, this may also include special categories of personal data (i.e., gender), medical information and information regarding your criminal record or security clearance for certain roles.

This information is held, processed, used and disclosed by us as follows:

  1. To provide our services to you;
  2. To assess data about you against vacancies which we judge may be suitable for you;
  3. To enable you to submit your CV, apply online for jobs or to subscribe to alerts about jobs we think may be of interest to you;
  4. To answer your questions and enquiries;
  5. To provide your services to our clients;
  6. To send your information to clients to apply for assignments/vacancies or to assess your eligibility for a project/assignment/vacancy;
  7. To carry out a fair recruitment process;
  8. To make an informed decision to shortlist for interview and (if relevant) recruit;
  9. To carry out our obligations arising from any contracts entered into between you and us;
  10. To take steps necessary at your request prior to entering into a contract;
  11. To maintain records and to comply with legal, regulatory and corporate governance obligations and good employment and/or recruitment practice;
  12. For reasons of substantial public interest;
  13. To maintain our business relationship, where you are a client or candidate;
  14. To fulfil contractual obligations with our clients;
  15. To maintain, expand and develop our business;
  16. To third parties where we have retained them to provide services that we, you or our client have requested including references, qualifications and criminal reference checking services (as required), verification of the details you have provided from third party source, psychometric evaluation or skill test;
  17. To process data where we are legally obliged to process such data or where the processing is necessary for the purposes of carrying out our obligations or exercising our rights in the field of employment and social security and social protection law;
  18. We may also release personal information to third parties if we believe in good faith that we are required by law to disclose it in connection with the detection of crime, the collection of taxes or duties, to comply with any applicable law or order of a court of competent jurisdiction, or in connection with legal proceedings;
  19. We reserve the right to transfer your information to a third party in the event of a sale, merger, liquidation, receivership or transfer of all or substantially all of the assets of our company provided that the third party agrees to adhere to the terms of this privacy policy and provided that the third party only uses your personal data for the purposes that you provided it to us. You will be notified in the event of any such transfer and you will be afforded an opportunity to opt-out.
  20. To third parties who perform functions on our behalf and who also provide services to us, such as professional advisors, payment services, and function co-ordinators. These third parties comply with similar undertakings of privacy and confidentiality as Winborough;
  21. To use your information on an anonymised basis to monitor compliance with our equal opportunities policy;
  22. Respond to and defend against legal claims;
  23. To notify you about changes to our service.

Legal basis for processing personal data

Our legal basis for the processing of personal data is as follows:

  1.  For the performance of a contract to which you are party to or to take steps to enter into a contract;
  2. For the purposes of our legitimate interests or those of a third party. We have set out our legitimate interests above under the section titled “Personal data: Purposes of collection and use”;
  3. For compliance with a legal obligation to which we are subject. This includes for the purposes of detecting crime, the collection of taxes or duties, and to comply with any applicable law;
  4. Where you give your consent to the processing of your personal data for one or more specific purposes, for example, some marketing activities we undertake. Should we want or need to rely on consent to lawfully process your data we will request your consent orally, by email or by an online process for the specific activity we require consent for and record your response on our system. Where consent is the lawful basis for our processing you have the right to withdraw your consent to this particular processing at any time;
  5. For the performance of a task carried out in the public interest or in the exercise of official authority vested in us.

Where we provide you with work finding services, the provision of personal data is a statutory requirement and a requirement necessary to enter into a contract with us. The provision of certain category of personal data may contractually be required as instructed by our clients. You will be obliged under these circumstances to provide us with such personal data.

We may not be able to enter into a contract with you if the information is not provided to us. Where you have entered into a contract with us and you refuse to provide any information required under the contract or by law, we reserve the right to terminate our business relationship with you. Where applicable, we may refer your refusal to the relevant statutory authority requesting such information.

Where your information is held

All the personal data we process is processed by our staff at our offices in the UK, Germany, Poland, India and the operations might extend to other countries in future. Some of these countries may not have similar data protection laws to the EEA. When we transfer your information outside of the EEA, we will take the appropriate steps to ensure that your privacy rights continue to be protected. In addition, if you use our services while you are outside the EEA, your information may be transferred outside the EEA in order to provide you with those services. Except as set out in this privacy policy, we will not disclose any personally identifiable information without your permission unless we are legally entitled or required to do so (for example, if required to do so by legal process or for the purposes of prevention of fraud or other crime) or if we believe that such action is necessary to protect and/or defend our rights, property or personal safety and those of our users/customers etc.

How long we keep your data

We will only hold your personal data for as long as is necessary to fulfil the purposes we collected it for, including for the purposes of complying with applicable legal or reporting requirements (for example, our obligations to the tax authorities or under immigration and nationality laws), our contractual obligations or our legitimate interests as a controller.

Some categories of personal data we hold will need to be retained for longer than others. 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 personal data, the purpose for which they are processed, the applicable legal requirements and our contractual obligations. Other personal data will be held for no longer than is necessary to protect our legitimate interest as a controller.

In some circumstances we may anonymise personal data so that it can no longer be associated to you, in which case we may use such information without further notice to you.

Data Security

We take the security of your data seriously. We have internal policies and controls to protect your personal information from unauthorised access, improper use or disclosure, unauthorised modification or unlawful destruction or accidental loss. We will update these measures as new technology becomes available, as appropriate.

Marketing

We may periodically contact you by telephone, email or other digital means for marketing purposes relating to our services. We will require your consent if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes. You have the right to withdraw your consent if you do not want to be contacted for such purposes (see Opt-Out below).

Where you have previously engaged with us (for example by submitting a job application or CV, or registering a vacancy to be filled), and we are marketing related services, we will take your consent as given unless or until you opt out. This is referred to as soft opt-in consent and is beneficial as it allows us to suggest other jobs to you alongside the specific one you applied for, significantly increasing the likelihood of us finding you a new position. In all other types of e-marketing, we are required to obtain your explicit consent.

Opt-Out – you are entitled to opt-out from receipt of marketing communication at any time and free of charge by sending an email to compliance@winborough.com.

Your rights

  1. You may request access to the information we hold about you at any time and may request us to rectify, update or restrict processing of such information. We may ask you to verify your identity and for more information about your request. We will seek to act on your request in the timescale required by applicable data protection laws.
  2. We will use reasonable endeavours to ensure that your personal data is maintained and up to date. However, you are under a duty to inform us of any and all changes to your personal data to ensure that it is up to date and we will update or delete your personal data accordingly.
  3. You may, in certain circumstances (for example, where we have processed your data unlawfully) have the right to request that we erase your personal data. We will respond to your request within the timescale required by applicable data protection laws and will only disagree with you if certain limited conditions apply. If we agree to your request, we will delete your data but will generally assume that you would prefer us to keep a note of your name on our register of individuals who would prefer not to be contacted. That way, we will minimise the chances of you being contacted in the future where your data are collected in unconnected circumstances. If you would prefer us not to do this, you are free to say so.
  4. Where we process your data based on consent you have provided to us, you have the right to withdraw your consent at any time and have such data deleted. Where we are legally permitted to do so, we may refuse your request and will give you reasons for doing so.
  5. If you wish to exercise any of these rights or raise a complaint on how we have handled your personal data, you can contact us on compliance@winborough.com

Changes to our Privacy Policy

Any changes to this privacy policy will be posted on this website. Where appropriate, we may notify you by email of the changes. Please check back frequently to see any updates or changes to our privacy notice.

For any other information, questions or concerns about this policy, please contact us at:

The Data Protection Officer
Winborough Technologies Limited
Basepoint Business Centre
377-399 London Road
Camberley
Surrey GU15 3HL
United Kingdom

Email: compliance@winborough.com