Privacy Notice

(when personal data is obtained directly from the data subject)

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

You may give your personal details to Engage Education 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. Engage Education 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.

1. Collection and use of personal data

a. Purpose of processing and legal basis

Engage Education 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 Engage Education 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 Engage Education has relied on a legitimate interest to process your personal data, our legitimate interests
is/are as follows:

● Managing our database and keeping work-seeker records up to date;
● Providing work-finding services to you and our clients;
● Contacting you to seek your consent where we need it;
● Giving you information about similar products or services that you have used from us recently;

c. Recipient/s of data

Engage Education will process your personal data and sensitive personal data with the following
recipients:
● Clients (whom we may introduce or supply you to)
● Former employers from whom we may seek references
● Payroll service providers who manage payroll on our behalf or other payment intermediaries
whom we may introduce you to
● Other recruitment/employment agencies in the supply chain
● Auditors who are assessing the compliance and processes of the business to ensure its
adherence to all relevant legislation and good practice guidance.
● Where required by law, including but not limited to sharing relevant information with the local
authority, social services and the Police

d. Statutory/contractual requirement

Your personal data is required by law and a contractual requirement (e.g. our client may require this
personal data), and a requirement necessary to enter into a contract. You are obliged to provide the
personal data and if you do not, then we will not be able to find you suitable work.

Overseas Transfers

The Company may transfer only the information you provide to us to countries outside the UK and/or the European Economic Area (‘EEA’) for the purposes of providing you with work-finding services. We will take steps to ensure adequate protection is in place to ensure the security of your
information. The EEA comprises the EU member states plus Norway, Iceland and Liechtenstein.

2. Data retention

Engage Education will retain your personal data only for as long as is necessary for the purpose for
which it was collected. 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 Engage Education 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, Engage Education will
seek further consent from you. Where consent is not granted, Engage Education will cease to
process your personal data and sensitive personal data.

3. Your rights

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

● The right to be informed about the personal data Engage Education processes on you;
● The right of access to the personal data Engage Education 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 Engage Education processing your personal data and ]sensitive
personal data you have the right to withdraw that consent at any time by contacting our Data
Protection Officer: Andy Carter GDPR@engagepartners.co.uk

There may be circumstances where Engage Education 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 the data that Engage Education 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.

4. Automated decision-making

If your Company uses automated decision-making, including profiling, the Company will provide
meaningful information about the logic involved, as well as the significance and the envisaged
consequences of such processing for the individual.

5. Complaints or queries

If you wish to complain about this privacy notice or any of the procedures set out in it please contact
our Data Protection Officer: Andy Carter GDPR@engagepartners.co.uk
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.

Annex A

a) The lawfulness of processing conditions for personal data are:

1. Consent of the individual for one or more specific purposes.
2. Processing is necessary for the performance of a contract with the individual or in order to take steps at the request of the individual to enter into a contract.
3. Processing is necessary for compliance with a legal obligation that the controller is subject to.
4. Processing is necessary to protect the vital interests of the individual or another person.
5. Processing is necessary for the performance of a task carried out in the public interest or in
the exercise of official authority vested in the data controller.
6. Processing is necessary for the purposes of legitimate interests pursued by the controller or
a third party, except where such interests are overridden by the interests or fundamental rights or freedoms of the individual which require protection of personal data, in particular where the individual is a child.

b) The lawfulness of processing conditions for sensitive personal data are:

1. Explicit consent of the individual for one or more specified purposes, unless reliance on
consent is prohibited by UK law.
2. Processing is necessary for carrying out data controller’s obligations under employment,
social security or social protection law, or a collective agreement, providing for appropriate
safeguards for the fundamental rights and interests of the individual.
3. Processing is necessary to protect the vital interests of the individual or another individual where the individual is physically or legally incapable of giving consent.
4. In the course of its legitimate activities, processing is carried out with appropriate safeguards by a foundation, association or any other not-for-profit body, with a political, philosophical, religious or trade union aim and on condition that the processing relates only to members or former members (or those who have regular contact with it in connection with those purposes) and provided there is no disclosure to a third party without the consent of the individual.
5. Processing relates to personal data which are manifestly made public by the individual.
6. Processing is necessary for the establishment, exercise or defence of legal claims or whenever courts are acting in their judicial capacity.
7. Processing is necessary for reasons of substantial public interest on the basis of UK law which shall be proportionate to the aim pursued, respects the essence of the right to data protection and provide for suitable and specific measures to safeguard the fundamental rights and interests of the individual.
8. Processing is necessary for the purposes of preventative or occupational medicine, for assessing the working capacity of the employee, medical diagnosis, the provision of health or social care or treatment or the management of health or social care systems and services on the basis of UK law or a contract with a health professional and subject to the necessary conditions and safeguards.
9. Processing is necessary for reasons of public interest in the area of public health, such as protecting against serious cross-border threats to health or ensuring high standards of quality and safety of healthcare and of medicinal products or medical devices, on the basis
of UK law which provides for suitable and specific measures to safeguard the rights and freedoms of the individual, in particular professional secrecy

10. Processing is necessary for archiving purposes in the public interest, scientific or historical
research purposes or statistical purposes, which shall be proportionate to the aim pursued, respect the essence of the right to data protection and provide for suitable and specific measures to safeguard fundamental rights and interests of the individual.

Key Contacts

Data Protection Officer – Andy Carter – GDPR@engagepartners.co.uk
Technology Success Manager – Amy Jones – amy.jones@engagepartners.co.uk
Associate Director – Joseph Raffell – joseph.raffell@engagepartners.co.uk