PRIVACY NOTICE (EXTERNAL)

INTRODUCTION

We are Compare Recruitment Factoring Limited (Registered in England & Wales No. 12089430). Our registered office is at Singleton Court Business Park, Wonastow Road Industrial Estate, Monmouth, NP25 5JA. This Privacy Notice explains how we use personal data in the course of our business activities.

We reserve the right to update this Privacy Notice from time to time. Where appropriate, we shall contact you to notify you of any material changes to this Privacy Notice. You should also refer to our website periodically so that you may access and view our updated Privacy Notice. This will ensure that you understand (i) how we are using your personal data and (ii) your legal rights around our usage of such personal data.

 

DEFINITIONS

This Privacy Notice uses the following defined terms:

Client means a person who has asked to be introduced to suitable Funders. In some cases, our actual client will be an incorporated legal entity, such as a limited company. In that case, any information relating to the limited company is not personal data for the purposes of the Data Protection Legislation. However, certain information relating to the directors and shareholders of the limited company is personal data and shall be handled in accordance with this Privacy Notice.

Business Contact means an individual with whom we deal who is employed or engaged by a Funder or Supplier.

Data Protection Legislation means (i) the Data Protection Act 2018, the General Data Protection Regulation ((EU) 2016/679) and any national implementing laws, regulations and secondary legislation, as amended or updated from time to time, in the UK and (ii) any successor legislation to the GDPR or the Data Protection Act 2018.

Funder means a third-party provider of recruitment finance/factoring services to which we may introduce a Client.

Supplier means a business which provides services to us and which may process personal data relating to Clients and Business Contacts in the course of performing those services including:

- Professional advisers such as accountants, tax advisors and lawyers
- Insurers
- IT services providers and software providers
- Independent consultants and subcontractors

 

WHO SHOULD READ THIS PRIVACY NOTICE?

This Privacy Notice applies to any living, identifiable individuals about whom we may process personal data in the course of our business activities.
You should read this Privacy Notice if you are a:

 

- Client
- Business Contact

 

INFORMATION FOR CLIENTS

Where We Obtain Your Personal Data

We obtain personal data relating to you directly if you have:

- Submitted your details through our website and/or our online chat facility
- Asked us to provide any services to you
- Provided any such data on our social media pages
- Engaged with us at any networking activities or events
- Had any discussions with us about arranging funding for your business

We may also obtain your personal data indirectly from:

- Online professional networking sites such as LinkedIn
- Business contacts who inform us that you may be interested in receiving services from us
- Public records such as those held at Companies House

 

Types of Personal Data We Hold

We collect, store and process the following types of personal data about you:

- Personal contact details such as name, title, addresses, telephone numbers, and email addresses
- Your professional skills, experience and sector specialisation
- Proof of your identity and address, such as copies of your driving licence, utility bills or similar documents
- Information about your current or proposed ownership and/or participation in a business
- Details of any Funders to which you have been introduced by us and any dealings which you have with such Funders
- Information about your personal financial circumstances, where such information may be required by a Funder
- Any background information which you provide to us during the course of your dealings with us

We do not collect, store or use any “special categories” of sensitive personal information.

 

How We Use Your Personal Data

We use your personal data to:

- Let you know about our services and our market sector generally
- Determine the most suitable funding solution for your business
- Introduce you and/or your business to potential Funders.
- Stay in regular contact with you to understand your current position and any additional funding requirements which your business may have
- Carry out compliance checks to ensure that we have complied with our legal and contractual obligations
- Comply with our legal obligations, defend or bring any legal proceedings and prevent fraud or any other crime

 

Our Lawful Basis for Processing Your Personal Data

We have a legitimate interest to process your personal data where you are a Client, on the basis that our business function is to introduce Clients to Funders. We use your personal data solely for this purpose and do not process it in any way which you would not reasonably expect.

We may also process your personal data to comply with our legal obligations e.g. for compliance and auditing purposes.

 

Parties with Whom We May Share Your Personal Data

We will share your personal data for legitimate reasons with:

- Funders where you have expressed an interest in being introduced to such Funder. When we share your personal data in this way, the Funder will then become an independent data controller of your personal data.
- Our Funders’ appointed auditors for compliance-checking purposes
- Our Suppliers
- Governmental departments and agencies where we are permitted or required by law to do so

 

INFORMATION FOR BUSINESS CONTACTS

 

Where We Obtain Your Personal Data

We obtain personal data relating to you directly in the course of dealing with you as a representative of a Funder or Supplier

We may also obtain your personal data indirectly from:

- Online professional networking sites such as LinkedIn
- Your employer’s website and other industry-related websites
- Business information directories
- Other individuals within your organisation

 

Types of Personal Data We Hold

We collect, store, and use the following categories of personal data about you:

- Personal contact details such as name, title, addresses, telephone numbers, and email addresses;
- Your job title and position within the relevant organisation; and
- Any background information which you may provide to us in the course of your dealings with us.

We do not collect, store or use any “special categories” of sensitive personal information.

 

How We Use Your Personal Data

We use your personal data to:

- Contact you for reasons connected with our company’s dealings with your organisation;
- Liaise with you so that we may effectively perform the services to our Client;
- Contact you for invoicing and credit control purposes;
- Comply with our legal obligations, defend or bring any legal proceedings and prevent fraud or any other crime.

 

Our Lawful Basis for Processing Your Personal Data

We have a legitimate interest to process your personal data where you are a Business Contact on the basis that we need to be able to contact and interact with the individuals who are employed or engaged by Funders and Suppliers. This allows us to provide our services and operate our business effectively. We do not use your data in any way which could reasonably be considered to be prejudicial to your interests.

 

Parties with Whom We May Share Your Personal Data

We will share limited contact information relating to you with a Client where it is necessary and appropriate to do so.

We may also share your personal data for legitimate reasons with:

- Our Suppliers
- Governmental departments and agencies where we are permitted or required by law to do so

 

WHERE WE PROCESS PERSONAL DATA

Your personal data is held and processed by us in the United Kingdom.

We will put in place appropriate safeguards to ensure that your data is only transferred to jurisdictions with enforceable data subject rights and effective legal remedies in respect of data privacy breaches.  For example, we may from time to time use third party data storage services which are based overseas. These are typically based in the United States and are subject to the US Privacy Shield.

 

OUR WEBSITE

If you interact with our website at http://www.compare-recruitment-factoring.co.uk you need to be aware of the cookies which we use. A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree.  Cookies contain information that is transferred to your computer’s hard drive. Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a better experience when you browse our website and also allows us to improve our site.

We may use the following types of cookie:

You can find more information about the specific cookies we use and the purposes for which we use them in the table below:

 

Name

Type

Description

Expiry By Type

Google Analytics

Analytical

This cookie collects information about your computer, including where available your IP address, operating system and browser type, and geographic location. We use this information for website optimisation and to monitor our user’s browsing activities and navigation through the site. This information is anonymous and would not allow us to identify any individual user without the assistance of a third party such as an ISP.

 

You are able to opt out of Google Analytics by installing a browser add-in from https://tools.google.com/dlpage/gaoptout. Please note that this add-in is provided by Google and we offer no warranty, whether express or implied, as to its suitability or efficacy.

 

_ga  2 years

 

_gid  24 hours

 

_gat  1 minute

PHPSESSID

Strictly necessary

This links the actions of a user during a browser session. It only applies to authorised users of our website who are logged into the administration area. This will not apply to most website users.

Upon closure of browser session

Smartsupp

Analytical/

Targeting

Our website uses Smartsupp for our online chat facility. It also monitors your navigation through the website and records how you interact with our website.

 

For the above purposes, Smartsupp acts as a data processor to Compare Recruitment Factoring Limited. Their details are: Smartsupp.com, Lidická 20, 602 00 Brno, Czech Republic

ssupp.vid – Visitor ID (expires in 6 months)

ssupp.chatid – Conversation ID (expires when browser is closed)

ssupp.group – last group of visitor (expires when browser is closed)

ssupp.opened – is chat box opened (expires when browser is closed)

ssupp.barclicked – When chat box is opened, needed for automatic messages (expires when browser is closed)

ssupp.message – stores content in text area if page is refreshed (expires when browser is closed)

ssupp.unreaded – Number of unread messages (expires when browser is closed)

ssupp.position – Position of chat box, if moved by visitor (expires when browser is closed)

SL_C_23361dd035530_KEY – Project key (expires in 2 years)

SL_C_23361dd035530_SID – Session ID, that is assigned to each new session that is being recorded (expires in 2 years)

SL_C_23361dd035530_VID – Visitor ID, assigned to each new visitor (expires in 2 years)

 

You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to (i) access all or parts of our site and (ii) use all of our site’s features.

 

AUTOMATED DECISION MAKING

Automated decision-making takes place when an electronic system uses personal information to make a decision without human intervention. All decisions which are made in the course of our business processes involve human intervention. We do not make any decisions using automated means.

 

DATA SECURITY

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. Details of these measures may be obtained from the Managing Director.

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.

 

DATA RETENTION

We will only retain your personal information 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.

Our standard data retention period is three years from the last date on which we are in actual contact with you i.e. where we actually speak with you or exchange correspondence. After this time, we will usually delete your personal data from our records.

Where we are required to keep any information (i) for auditing or compliance purposes (ii) to comply with our contractual obligations to third parties or (iii) in respect of any potential or actual legal proceedings, we shall keep your data for as long as is strictly necessary for these purposes, which is typically for seven years in respect of audit data which we may be required to produce for HRMC and/or to prove compliance with our contractual and legal obligations.

 

RIGHTS OF ACCESS, CORRECTION, ERASURE & RESTRICTION

Your duty to inform us of changes. It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your working relationship with us.

Your rights in connection with personal information. Under certain circumstances, you have the right to:

Request access to your personal information (a Subject Access Request). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it. You will not usually have to pay a fee to access your personal information but 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 such circumstances.

Request correction of the personal information 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 information. This enables you to ask us to delete or remove personal information where the personal data is no longer necessary in relation to the purpose for which it was originally collected/processed or you have objected to the processing and there is no overriding legitimate interest for continuing the processing.

Object to processing of your personal information where we are relying on a legitimate interest and you object on “grounds relating to your particular situation.”

Request the restriction of processing of your personal information. This enables you to ask us to block or suppress the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it or if you have also objected to the processing as above.

Request the transfer of your personal information to another party when the processing is based on consent and carried out by automated means. This right is not usually applicable to any data processing carried out by us.

 

If you want to exercise any of the above rights, please contact the Managing Director in writing. We will consider your request and confirm the actions which we have taken in response to such request.

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 an appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.

In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information 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 the Managing Director. 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. We will confirm the actions which we have taken in respect of any such request.

If you are unhappy with any aspect of the manner in which we have processed your personal data or dealt with your decision to exercise any of the rights set out in this section, you have the right to complain to the Information Commissioners Office in the United Kingdom. Their details are: Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF

Tel: 0303 123 1113 (local rate) or 01625 545 745 Email: casework@ico.org.uk

 

CONTACTING US

If you have any questions about this Privacy Notice, you can write to the Managing Director at Compare Recruitment Factoring Limited, Singleton Court Business Park, Wonastow Road Industrial Estate, Monmouth, NP25 5JA. Alternatively, you may telephone us on 01600 735003 or email us at privacy@c-r-f.co.uk.