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Privacy Policy & Cookies

Privacy Policy

Osborne Thomas Limited is committed to protecting your privacy both on and offline and our privacy policy describes how we collect, use and process your personal data. We fully accept our responsibilities in maintaining client and candidate confidentiality and we are committed to protecting your data privacy rights. We will never disclose any personal information to a third party without your permission and will only use that information with your permission as outlined in this policy.

This privacy policy applies to the personal data of our Website Users, Candidates, Clients, Suppliers and other people with whom we may be in contact. For the purpose of applicable data protection legislation (including but not limited to the General Data Protection Regulation (Regulation (EU) 2016/679), please contact our Data Protection Officer (Debbie Bridger) through the following details:

Email: debbie@osbornethomas.org
Phone: 0203 280 3671

Address:
Osborne Thomas Ltd,
71-75 Shelton Street,
Covent Garden,
London,
WC2H 9JQ

Osborne Thomas reserves the right to update or change our privacy policy at any time and without notice. Any changes will be posted on this website.

What Personal Data do we collect?

Candidate data:

In order to ensure the best levels of customer service and to provide you with the best possible employment opportunities, we may ask for details that will genuinely help us to help you. For example, name, contact details, education details, employment history, immigration status and any other relevant information that you may choose to share with us. In some situations, we may be required to carry out financial background checks, reference checks or request details of a referee.

Such information is accepted on the following basis: You undertake to guarantee that the information you provide is complete, true and accurate in all respects.

Client data:

If you are a Client of Osborne Thomas, we may need to collect and use information about you or individuals at your organisation in order to find Candidates who are the right fit for you or your organisation.

Supplier data:

To ensure that our processes run smoothly, we only require a small amount of data from our Suppliers, such as the contact details of relevant individuals within your organisation so that we can communicate with you. We may also need additional information such as bank details so that we can pay for the provided services (if this is a part of the contractual arrangement between us). We may also hold information that a person within your organisation has chosen to disclose to Osborne Thomas.

People whose data we receive from Candidates/Clients such as Referees:

In order to provide candidates with suitable employment opportunities, safely and securely, we may need some basic background information from their Referees. We only ask for very basic contact details (such as name, email and telephone number) so that we can get in touch with you for a reference.

How do we collect Personal data?

Candidate data:

The two ways in which we collect your personal data are as follows:

  1. Directly from you
    1. Emailing your CV to Osborne Thomas or an Osborne Thomas employee or being interviewed by a Consultant via telephone or in person.
    2. Leaving a hard copy of your CV with Osborne Thomas
  2. From third parties
    1. Your Referees may disclose personal information from you
    2. Clients may share personal information
    3. Personal information may be obtained from sources such as LinkedIn and job sites to which you subscribe, or through which you apply for jobs
    4. Social Media (Twitter, Facebook etc.)
    5. If you were referred to Osborne Thomas by an external source.

Client data:

In order to make sure that we achieve our goal of having the best Candidates for your organisation, we collect your personal data in two ways:

  1. Directly from you
    1. When you contact Osborne Thomas proactively, usually via telephone or email
    2. When an Osborne Thomas employee contacts you either via phone, email or in person
  2. From third parties (e.g. our Candidates or online/offline media)
    1. From third party market research and individuals/companies in Osborne Thomas’s network
    2. Delegate lists at relevant events
    3. Search engines, social media, online networking sites such as LinkedIn

Supplier data:

We collect personal data during the course of working with you.

People whose data we receive from Candidates/Clients such as Referees:

We only collect personal data when a Candidate provides it in order for you to serve as a Referee.

How do we use your personal data?

Candidate data:

Osborne Thomas’s main reason for collecting your personal data is to help you find employment. The more information we have about you, such as your skillset and career ambitions, the more bespoke we can make our service. In certain circumstances, we may use your data to ensure that we continue to be up to date with your situation, for diversity and equal opportunities monitoring or in legal situations.

Please see below for a list of ways in which we may process your personal data in order to find you a suitable role. Please note this list is not exhaustive:

  • Recruitment Activities:
  • Collecting data from you and other sources, such as LinkedIn
  • Storing (and updating where necessary) your details on our database so that we can contact you in relation to recruitment
  • Assessing data about you against vacancies that may be suitable for you and your skillset
  • Sending your information to Clients to assess your eligibility for jobs (please note, we will not send your personal information without your consent)
  • Verifying details you have provided, using third party sources, or requesting information
  • Complying with our legal obligations in connection with the detection of crime or collection of taxes
  • Processing your data to enable Osborne Thomas to send communications which we think may be of interest to you.

We may also use your personal data for the purposes below if we deem it necessary to do so. If you do not agree with this, you do have the right to object.

  • Marketing activities
  • Equal opportunities monitoring and other sensitive personal data
  • To help us establish, exercise or defend legal claims.

Client data:

Osborne Thomas’s main reason for using information on our Clients is to ensure we maintain our contractual arrangement and to ensure our relationship runs smoothly and efficiently. The more information we have, the more bespoke our service and our ability to identify Candidates we think will be right for your organisation. Client data may also be used for marketing activities, business development and in legal situations.

Supplier data:

The main reason for using your personal data is to ensure our contractual arrangements run smoothly and to comply with legal requirements.

People whose data we receive from Candidates/Clients such as Referees:

We use Referee’s personal data to help our candidates find employment by verifying their details, skills and qualifications to make sure they are matched with their prospective employers.

How do we use your personal data?

Candidate data:

We may share your information with various parties in various ways. Primarily, we will share your information with prospective employers to increase your chances of securing the job you want. Osborne Thomas will never disclose personal information without your permission and will only use your personal data as outlined in this privacy policy.

Client data:

Osborne Thomas will only share your data to ensure that we are able to provide you with a suitable shortlist of Candidates.

Supplier data:

Unless you specify otherwise, we may share your information with associated third parties such as our service providers and organisations to whom we provide services.

People whose data we receive from Candidates/Clients such as Referees:

Unless you specify otherwise, we may share your information with associated third parties to whom we provide services.

How do we safeguard and store your personal data?

Osborne Thomas is committed to protecting your privacy. Once we have your personal information (see above), it is stored on our online system which can only be securely accessed by employees of our company. We may also gather information and statistics collectively about visitors to our website.

All of our internal systems are password and firewall protected and can only be accessed by Osborne Thomas employees or a service provider hired by Osborne Thomas.

We protect your data by ensuring that we have appropriate organisational and technical measures and security in place. These include procedures to deal with any suspected data breaches.

If you suspect loss, misuse or unauthorised access to your personal information, please let us know immediately by contacting our Data Protection Officer.

How long do we keep your personal data for?

If we have not had meaningful contact with you, or, where appropriate, the company you are working for/with, for a period of two years, we will delete your personal data from our systems, unless we believe in good faith that the law (or other regulation) requires us to preserve it (for example, tax litigation). After this period, it is likely your data will no longer be relevant for the purposes for which it was collected.

When we refer to “meaningful contact” we mean, for example, communication between you and Osborne Thomas (either verbal or written) or where you are actively engaging with our online services. If you are a Candidate, we will consider there to be meaningful contact with you if you submit your updated CV via email, through a third party website or directly to an Osborne Thomas employee. We will also consider it meaningful contact if you communicate with Osborne Thomas, our employees or third parties regarding any potential roles, either via verbal or written communication.

How can you access, amend or take back the personal data you have given us?

One of the GDPR’s main objectives is to protect and clarify the rights of EU citizens and individuals within the EU with regards to data privacy. Even if we already hold your personal data, you still have various rights in relation to it. We will seek to deal with your request without undue delay within one month (subject to any extensions, to which we are lawfully entitled) and in accordance with the requirements of applicable laws. Please note, we may keep a record of your communications to help us resolve any issue which you raise.

To get in touch regarding any of the below rights, please contact our Data Protection Officer.

Right to object:

If we are using your data because we deem it necessary for your legitimate interests to do so and you do not agree, you have the right to object. We will respond to your request within 30 days, although we may be allowed to extend this period in certain cases. Generally, we will only disagree with you if certain limited conditions apply. This right enables you to object to Osborne Thomas processing your personal data where we do so for one of the following four reasons:

  1. Our legitimate interests
  2. To enable us to perform a task in the public interest of exercise of official authority
  3. To send your direct marketing materials
  4. For scientific, historical, research or statistical purposes.

If your objection relates to Osborne Thomas processing your personal data because we deem is necessary for your legitimate interests, we must act on your objection by ceasing the activity in question unless:

  • We can show that we have compelling legitimate grounds for processing which overrides your interests; or
  • We are processing your data for the establishment, exercise or defence of a legal claim.

If your objection relates to direct marketing, we must act on your objection by ceasing this activity.

Right to withdraw consent:

Where we have obtained your consent to process your personal data for a certain activity (i.e. for profiling your suitability for certain roles), or consent to let us contact you intermittently to ensure your details are up to date, you may withdraw your consent at any time. In this case, please contact any of our consultants or our Data Protection Officer.

Data Subject Access Requests (DSAR):

You have the right to ask us to confirm what information we hold about you at any time. You may ask us to modify, update or delete such information. At this point, we may comply with your request or, additionally do one of the following:

  1. We may ask you to verify your identity or ask for more information about the request
  2. Where we are legally permitted to do so, we may decline your request, but we will explain why if we do so.

Right to erasure:

In certain situations, you have the right to request that Osborne Thomas erases your personal data. We will respond to your request within 30 days (although we may be allowed to extend this period in certain cases) and will only disagree with you if certain limited conditions apply. If we do agree to your request, we will delete your data but generally assume that you would prefer Osborne Thomas to keep a note of your name on our register of individuals who prefer to not be contacted. This will ensure that we minimise the chances of your being contacted in the future when your data is collected in unconnected circumstances. If you would prefer for Osborne Thomas not to do this, please say so.

In order for your right to request that Osborne Thomas erases your data, the information must meet one of the following criteria:

  1. The data is no longer necessary for the purpose for which Osborne Thomas originally collected and/or processed the data
  2. Where consent was previously given, you have withdrawn your consent to the processing of your data and there is no other valid reason to continue processing
  3. The data has been processed unlawfully (i.e. in a manner which does not comply with the GDPR)
  4. It is necessary for the data to be erased in order for Osborne Thomas to comply with our legal obligations as a data controller; or
  5. If we process the data because we believe it necessary to do so for our legitimate interests, you object to the processing and we are unable to demonstrate overriding legitimate grounds for continued processing.

We would only be entitled to refuse to comply with your request for erasure for one of the following reasons:

  1. To exercise the right to freedom of expression and information
  2. To comply with legal obligations or for the performance of a public interest task or exercise of official authority
  3. For public health reasons in the public interest
  4. For archival, research or statistical purposes; or
  5. To exercise or defend a legal claim

When complying with a valid request for the erasure of data, we will take all reasonably practicable steps to delete the relevant data.

Rights to data portability:

If you wish, you have the right to transfer your data from us to another data controller. We will help with this – either by directly transferring your data for you, or by providing you with a copy in a commonly used machine-readable format.

Rights to data portability:

You also have the right to lodge a complaint with your local supervisory authority:

The Information Commissioner’s Office (ICO).

Telephone: 0303 123 11313
Email: casework@ico.org.uk

Postal Address:
Information Commissioner’s Office,
Wycliffe House,
Water Lane,
Wilmslow,
Cheshire,
SK9 5AF

Who is responsible for processing your personal data on the Osborne Thomas database?

Osborne Thomas and the employees of Osborne Thomas control the processing of personal data on its database and throughout the company.

Our legal bases for processing your data

Article 6(1)(f) of the GDPR states that we can process your data where it “is necessary for the purposes of legitimate interests pursued by [us] or by a third party, except where such interests are overridden by the interests or fundamental rights of freedoms of [you] which require protection of personal data.”

Consent

In certain circumstances, we are required to obtain your consent to the processing of your personal data in relation to certain activities. Depending on exactly what we are doing with your information, this consent will be opt-in consent or soft opt-in consent. Article 4(11) of the GDPR states that (opt-in) consent is “any freely given, specific, informed and unambiguous indication of the data subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.” This means that:

  1. you have to give us your consent freely, without us putting you under any type of pressure;
  2. you have to know what you are consenting to – so we’ll make sure we give you enough information;
  3. you should have control over which processing activities you consent to and which you don’t;
  4. you need to take positive and affirmative action in giving us your consent – we’re likely to provide a tick box for you to check so that this requirement is met in a clear and unambiguous fashion.

We will keep records of the consents that you have given in this way.

We have already mentioned that, in some cases, we will be able to rely on soft opt-in consent. We are allowed to market products or services to you which are related to the recruitment services we provide as long as you do not actively opt-out from these communications.

As we have mentioned, you have the right to withdraw your consent to these activities. Please contact our data protection officer.

How do we store and transfer your data internationally?

In order to provide you with the best service and carry out to purposes described in this privacy policy, your data may be transferred:

  1. To third parties (other suppliers of Osborne Thomas)
  2. To overseas Clients
  3. To Clients within your country who may, in turn, transfer your data internationally:
    1. To a cloud based storage provider
    2. To other third parties

To ensure that your data receives an adequate level of protection, we have put in place appropriate measures with the third parties we may share your information with to ensure that your personal information is treated by those third parties in a way that is consistent with the law on data protection.

What are cookies and how do we use them?

A cookie is a small data file which is stored on your computer’s hard drive. They are used by nearly all websites and do not harm your system. With your consent, cookies are used to remember your login when you visit our website. We also use cookies to ensure you get the smoothest possible experience when using our website and we can use the information from cookies to ensure we present you with the best options tailored to your preferences on your next visit.

If you want to check or change your cookie preferences, please refer to your internet browser instructions or the help screen.

Links

Our website may contain links to other sites. Please note that Osborne Thomas is not responsible for the privacy policies of other sites. It is your responsibility to check the privacy policy of such sites.

Disclaimer

Whilst Osborne Thomas uses reasonable care in compiling and presenting the information found on this website, it is provided for purely information purposes and you should seek further guidance and make independent enquiries before relying on it. The information supplied on this website has been compiled from a variety of sources and is subject to change without notice. Osborne Thomas makes no representation or warranty whatsoever regarding the completeness, accuracy, currency, adequacy, suitability or operation of this website, or of the information it contains, nor makes any such warranty in respect of any information carried on any website operated by a third party which may be accessed from this website, nor that the information on this or any third party website has in any way been verified by Osborne Thomas. All information on this website is provided on an “as is” basis. Osborne Thomas assumes no responsibility for information contained in this website and disclaims all liability arising from negligence or otherwise in respect of such information. Osborne Thomas makes no representations in respect of the existence or availability of any appointment advertised on this website. Osborne Thomas does not guarantee that any employer or client will ask for a candidate’s information, or to interview or hire a candidate, or that any candidates will be available or will meet the needs of any employer or client. Osborne Thomas cannot guarantee that any employer or client will keep confidential any candidate information or data provided to the employer or client. Osborne Thomas makes no representation or warranty as to the final terms and duration of any appointment obtained through this website. By using this website you assume the risk that the information on this website may be incomplete, inaccurate, out of date or may not meet your requirements. This website was created in England. Any interpretation of its contents, claims or disputes (of whatever nature and not limited to contractual issues) shall be subject to the exclusive jurisdiction of the English Courts under English law.

Copyright

All information incorporated within this website is copyright of Osborne Thomas Limited. This website has been created for and behalf of Osborne Thomas Limited. All copyright is the property of Osborne Thomas Limited and any unauthorised reproduction is prohibited. Unauthorised use of the Osborne Thomas Limited trademarks, trade names and logos is prohibited.

If you have any comments or suggestions regarding this Privacy Policy, please contact our Data Protection Officer

We take our privacy policy seriously and we will get back to you as soon as possible.

ANNEX

1. Candidate Data:

Please see a detailed list below of information we may collect from you in order to find you the best employment opportunities:

  • Gender
  • Contact details
  • Employment history
  • Immigration Status
  • Nationality
  • Education details
  • Marital status
  • Photograph
  • A copy of your passport / ID card / driving licence
  • Diversity information including racial or ethnic origin, religious or other similar beliefs as well as physical or mental health, including disability-related information
  • Details of any criminal convictions
  • Details about your current remuneration, pensions and benefits arrangements
  • Information of your interests and needs with regards to your next role
  • Extra information you choose to tell us such as date of birth
  • Extra information that we find out from the Client or third party sources, such as the job sites
  • Reference/Referee Checks
  • Financial background checks
  • IP Address

** Please note that the above list of categories of personal data we collect is not exhaustive

  1. We collect limited information about our Clients. We generally only need your contact details and details of individual contacts at your organisation (names telephone numbers and email addresses) to enable us to ensure that our relationship runs smoothly. We also hold information that someone in the organisation has chosen to tell us. If we need any additional personal data for any reason, we will let you know.
  2. Where appropriate and in accordance with local laws and requirements, we may share your personal data in the following ways:
    1. In the case of candidates, we may share your information with prospective employers to give you the best opportunity of securing a new role. This will not be shared without your permission.
    2. Tax, audit or other authorities who require us to share this data
    3. Third party outsourced IT and document storage providers where we have an appropriate processing agreement (or similar protections) in place
    4. In the case of candidates and prospective Referees: third parties who provide services such as reference, financial, qualification and criminal convictions checks, to the extent that these checks are appropriate and in accordance with local laws
    5. If at any stage in the future that Osborne Thomas is acquired or merged with another business or company, we may share information that relates to you with the new owners or Partners of the business without your consent. You will be sent notice of this event.

GLOSSARY

Candidates – includes applicants for all roles advertised or promoted by Osborne Thomas, including permanent, contract, interim with Osborne Thomas Clients as well as people who have supplied a speculative CV to Osborne Thomas, not in relation to a specific job.

Clients – this category covers our customers, clients, and others to whom Osborne Thomas provides services in the course of its business.

Delete – while we will endeavour to permanently erase your personal data once it reaches the end of its retention period or where we receive a valid request from you to do so, some of your data may still exist within our systems, for example if it is waiting to be overwritten. For our purposes, this data has been put beyond use, meaning that, while it still exists on an archive system, this cannot be readily accessed by any of our operational systems, processes or Staff

General Data Protection Regulation (GDPR) – a European Union statutory instrument which aims to harmonise European data protection laws. It has an effective date of 25 May 2018, and any references to it should be construed accordingly to include any national legislation implementing it.

Other people whom Osborne Thomas may contact – these may include Candidates and Osborne Thomas employees emergency contacts and referees. We will only contact them in appropriate circumstances.

Suppliers – refers to partnerships and companies (including sole traders), and atypical workers such as independent contractors and freelance workers, who provide services to Osborne Thomas.

Website Users – any individual who accesses the Osborne Thomas website.

List of cookies we collect

The table below lists the cookies we collect and what information they store.

COOKIE NAME COOKIE DESCRIPTION
__utma Google Analytics: We use Google Analytics to monitor traffic levels, search queries and visits to this website.
__utmb Google Analytics stores IP address anonamously on its servers in the US, and neither CIVIC or Google associate your IP address with any personally identifiable information.
__utmc and __utmz These cookies enable Google to determine whether you are a return visitor to the site, and to track the pages that you visit during your session.