1.1 This privacy notice in relation to our website at www.peoplechiefs.com (“Website”).

1.2 This privacy notice is issued on behalf of Department of People and Performance Limited (“we”, “us” or “our”, a company incorporated under the Companies Acts with registered number 06288096 and having its registered office at 20-22 Wenlock Road, London, N1 7GU.

1.3 This privacy notice informs you about what data we collect from you, how we use it, circumstances where we may disclose this data to others and how we keep it secure.

We provide three core people related services :

1. Recruitment for mid to senior level professionals across a variety of industry sectors and to a range of clients (“our services”) throughout the world.
2. HR consulting and outsourcing services for Start Up’s and SMEs and 3) Career Development and Coaching services. A more detailed outline of our services can be found on the website.

This policy applies to you whether you are a candidate or a client,or a source or referee in respect of a candidate or an employee of one of our clients.

Additionally, this policy will also apply to you if you attend one of our events or have subscribed to receive information about our services or events or have agreed to receive marketing materials such as our HR Insight or Career Events.

For the purposes of this policy:

candidate(s) means an individual who is a candidate, applicant, potential candidate, employee of a client; or receiving personalised one to one career coaching.

client(s) means any, business, firm, organisation, government body or individual that mandates us to perform any of our services;

a referee is a person who provides a personal or work reference in respect of a candidate and;

a source is a person who provides us with information or intelligence about a candidate.

1.4 We take the issue of security and data protection very seriously and strictly adhere to applicable data protection legislation. In accordance with the General Data Protection Regulation (EU) 2016/679 we are the data controller of any personal data that you provide us.

1.5 Any questions or information requests relating to this policy and our privacy practices should be directed to privacy@peoplechiefs.com

2.1 We collect and process your personal information in the following ways:

• You may give us information about you via our Website, using our contact forms. These forms capture basic contact details to allow us to prepare service quotes for clients. Additionally, as candidates may provide information when you register for career opportunities , this includes your CV.
• You may provide us with information when you register for our HR or Career development events
• You may give us information by corresponding with us by mail, text, e-mail, (or other form of electronic communication), telephone or in person;

We may receive personal data about you from various third parties and public sources including, but not limited to, job boards on third party websites such as Indeed or Linkedin.

2.2 It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.

3.1 Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data from which an individual can no longer be identified (anonymous data).

3.2 We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:

4.1 We will only use your personal data when the law allows us to. We use the information we collect about you:

• To enable us to perform the contract we have entered with you, including provision of the services, recruitment ,HR Consulting & Outsourcing Services and Career Coaching & Development Services.
• To facilitate the recruitment process, to submit your CV for job applications;
• To assess data about you against job vacancies which we judge may be suitable for you
• To be able to send you communications that may be of interest to you (such as details of job vacancies), either electronically, by email, by text or otherwise;
• To provide you with Vacancy Email alerts (where you have subscribed for this information);
• To send your information to clients in order to apply for jobs or to assess your eligibility for jobs;
• if we place you with our clients, we shall also request and hold copies of documentation showing your legal right to work in the UK;
• for compiling salary and other market surveys, although you do not have to respond to them;
• to be able to respond to your query;
• to help us with understanding more about how our Website is used;
• if required to comply with a legal or regulatory obligation;
• if necessary, for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests;
• if needed to protect your interests (or someone else’s interests);
• for all other purposes consistent with the proper performance of our operations.

4.2 We may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground, we are relying on to process your personal data.

4.3 We usually do not rely on consent as a legal basis for processing your personal data other than in relation to sending direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

5.1 It is your choice whether you receive marketing communications and information from us. If you indicated that you are interested in receiving regular information about our activities, we may send you communications electronically. We will not contact you for marketing purposes unless you have given your prior consent. If, at any time, you no longer wish to receive this information, please send a written request to privacy@peoplechiefs.com.

5.2 All of our email marketing correspondence gives you the option to opt-out of receiving further marketing emails. Please note that you will still receive emails directly related to an enquiry you raised with us.

6.1 Please be aware that the transmission of information via the internet is not always completely secure. Although we will do our best to protect your personal data, we cannot guarantee the complete security of your data transmitted to us electronically; any transmission is at your own risk.

6.2 We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

6.3 We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

7.1 The information you provide to us will be treated by us as confidential. We may also disclose your information to our suppliers and service providers for the purposes set out in the policy or for purposes approved by you.

7.2 We will disclose your information to other third parties, such as prospective employers, clients with vacancies and other representatives in relation to jobs and vacancies in which you indicate an interest.

7.3 We require all third parties to respect the security of your personal data and to treat it in accordance with
data protection legislation.

7.4 If our business enters into a joint venture with or is sold to or merged with another business entity, your information may be disclosed to our new business partners or owners.

Your personal data will only be shared on a confidential basis to our administrative partners (IT, Finance. Each partner has been fully vetted for data and GDPR compliance and these service agreements are governed by strict adherence to a live and monitored Data Processing Agreements. For ongoing compliance, regular due diligence exercises are performed to ensure the highest levels of data integrity are maintained. Additionally, any new service partners are subject to rigorous Data and GDPR compliance checks.

In the event that your data is transferred outside the UK and EEA, to any third parties or a location that does not have the Adequacy STATUS, we require all participants to agree fully and sign agreements that contain the appropriate terms and conditions to safeguard your personal data.

We do not sell your personal data to any third parties.

We review our data retention periods regularly and will only hold your personal data for as long as is necessary for the relevant activity, or as required by law.

10.1 Under Data Protection and GDPR regulations, you have the following rights in connection with your personal data, which can be exercised at any time:

• Right of access: you can request a copy of the personal information we hold about you and check we
  are processing it lawfully;
• Right to rectification: you can request that any incomplete or inaccurate information we hold about you is corrected;
• Right to erasure: you can request that we delete your personal information where there is no good reason for us to continue to process it. You must provide valid reasoning for your request. This can be exercised in conjunction with the right to object (see below);
• Right to object: you can object to our processing of your personal information where we are processing on the basis of our ‘legitimate interest’ or that of a third party. We shall cease processing your personal data unless there are compelling and legitimate grounds for processing which override your interests;
• Right to restrict processing: you can request that we restrict our processing of your personal information. Information will be retained but not further processed;
• Right to data portability: where processing of personal data is carried out by automated means, you can request the transfer of your personal information to another party;
• Right to withdraw consent: where we are processing your personal data based on consent, you have the right to withdraw your consent at any time;
• Right to not be subject to decision making based on automated processing: you shall have the right to not be subject to decision making based solely on automated means including profiling; and
• Right to complain :you have a right to lodge a complaint with a Supervisory Authority, which is an independent public authority established in each EU member state in accordance with Data Protection Legislation. The Supervisory Authority for data protection issues in the United Kingdom is the
  Information Commissioner’s Office (ICO).

10.2 If you would like to exercise any of your rights above, please contact us at privacy@peoplechiefs.com
10.3 You also have the right to complain to the Information Commissioner’s Office in relation to our use of your information. In the United

Upon receipt of a valid request, you you can request the following information:

• Identity and the contact details of the person or organisation that has determined how and why to process your data.
• Contact details of the data protection officer, where applicable.
• The purpose of the processing as well as the legal basis for processing.
• If the processing is based on legitimate interests or a third party, information about those interests.
• The categories of personal data collected, stored and processed.
• Recipient(s) or categories of recipients that the data is/will be disclosed to.
• How long the data will be stored.
• Details of your rights to correct, erase, restrict or object to such processing.
• Information about your right to withdraw consent at any time.
• How to lodge a complaint with the supervisory authority.
• Whether the provision of personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract, as well as whether you are obliged to provide the personal data and the possible consequences of failing to provide such data.
• The source of personal data if it wasn’t collected directly from you.
• Any details and information of automated decision making, such as profiling, and any meaningful information about the logic involved, as well as the significance and expected consequences of such processing.

We will only use your personal data in line with the laws. Our legal basis for processing your personal data apply in the following circumstances:

• To deliver a contract of services we have agreed upon or about to enter with you (UK GDPR Article 6(1)(b));
• For the purposes of our legitimate interests (UK GDPR Article 6(1)(f));
• To comply with the legal and regulatory obligations of the UK GDPR Regulations (UK GDPR Article 6(1)(c)); and
• You have provided your consent (UK GDPR Article 6(1)(a)) and Data Protection Act 2018.

Any changes we make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by email.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

If you have any questions or if there is anything you are unclear about this privacy policy notice, including any requests to exercise your legal rights, please contact us at privacy@peoplechiefs.com

The GDPR Leader is the owner of this document and is responsible for ensuring that this record is reviewed in line with the review requirements of GDPR.