Privacy Policy

Your privacy is extremely important to us. We respect your privacy and comply with the General Data Protection Regulation with regard to your personal information.

This privacy policy applies between you, the User of this Website, www.lkpeople.com, and the owner and provider of this Website, LK People Ltd.

This privacy notice will inform you as to how we look after your personal data which you provide to us, or which we obtain, when you are a Client, when you are a Candidate, when you use our website (www.lkpeople.com), or when we deal with you in the course of our business. This website is not intended for children and we do not knowingly collect data relating to children.

This privacy policy should be read alongside, and in addition to, our Terms which are also published on this website. We may update this privacy policy from time to time — you can find our latest policy on our website at www.lkpeople.com or by asking us for a copy.

Data Privacy Manager

Our appointed data privacy manager is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below:

Data Privacy Manager: Kate Cook

Contact email: kate@lkpeople.com

For the purposes of these policies:

‘Data Protection Laws’ means any applicable law relating to the processing of Personal Data, including, but not limited to the Directive 95/46/EC (Data Protection Directive) or the GDPR.

‘GDPR’ means the General Data Protection Regulation (EU) 2016/679.

‘Data Controller’, ‘Personal Data’ and ‘Processing’ shall have the same meaning as in the GDPR.

We are a Data Controller of the Personal Data we process in providing Services to you.

Where you supply Personal Data to us so we can provide Services to you, and we process that Personal Data in the course of providing the Services to you, we will comply with our obligations imposed by the data protection laws.

Before or at the time of collecting Personal Data, we will identify the purposes for which information is being collected; we will only Process Personal Data for the purposes identified; we will respect your rights in relation to your Personal Data; we will implement technical and organisational measures to ensure your Personal Data is secure.

The data we collect

We collect, use, store and transfer:

  • technical data: information we collect automatically when you visit our website or interact with us by email, including your IP address, browser details, and device details.
  • identity and contact data: personal and identity data, including your name, date of birth, copies of ID, postal address, email address, telephone numbers, and information relating to immigration status and right to work.
  • recruitment data: references and other information included in a CV, covering letter and employment history.
  • financial data: information regarding remuneration packages including information about salaries, fee rates, bonuses, expenses and benefits in kind. In the case of Candidates applying for temporary positions, we also collect, use, store and transfer information regarding pensions and tax details.
  • marketing and communications data: includes your preferences in receiving marketing from us and your communication preferences.
  • transaction data: details of services we provide to you.

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with our services).

We may also collect, store and use the following particularly sensitive categories of personal data:

  • information about your race or ethnicity, and/or gender;
  • information about your health, including any medical condition, health or disability.

How we use your personal data

We will only use your personal data when the law allows us to.

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that 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 using the details given above if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/Activity

Lawful basis for processing including basis of legitimate interest

To administer and protect our business and our website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

  • Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
  • Necessary to comply with a legal obligation

To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you

  • Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)

To use data analytics to improve our website, products/services, marketing, customer relationships and experiences

  • Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)

To register you as a new Client, Candidate or Supplier

  • Performance of a contract with you
  • Necessary for our legitimate interests (to build our database where you have requested to be included or made your details available for inclusion).

To provide services to you and carry out your instructions in connection with our services

  • Performance of a contract with you

To provide your details as a Candidate to our Clients

  • Performance of a contract with you
  • Necessary for our legitimate interests (to inform our Clients of Candidates who are interested in roles with those Clients)

To carry out administration in connection with the provision of services to you, including:

  • Managing payments, fees and charges
  • Collect and recover money owed to us
  • Performance of a contract with you
  • Necessary for our legitimate interests (to recover debts due to us)

To manage queries relating to services we have provided to you historically

  • Performance of a contract with you
  • Necessary for our legitimate interests (to be able to respond to queries about our services)

To manage our relationship with you as a Client, Candidate, Supplier or professional contact, which will include:

  • Notifying you about changes to our terms or privacy policy
  • Asking you to leave a review or take a survey
  • Performance of a contract with you
  • Necessary to comply with a legal obligation
  • Necessary for our legitimate interests (to keep our records updated and to study how Clients and Candidates use our products/services)

To enable you to partake in a competition or complete a survey

  • Performance of a contract with you
  • Necessary for our legitimate interests (to study how Clients and Candidates use our products/services, to develop them and grow our business)

To send updates to you about vacancies that may be of interest to you

  • Consent (where you have provided positive consent)
  • Necessary for our legitimate interests (to develop our products/services and grow our business)

To invite you to networking and professional events, and to inform you about developments in our business or market trends.

  • Consent (where you have provided positive consent)
  • Necessary for our legitimate interests (to develop our products/services and grow our business)

We will only use your personal data for the purposes for which it was collected, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact our Data Privacy Manager (kate@lkpeople.com).

Your Data Protection Rights

Under data protection law, you have rights including:

  • Your right of access — You have the right to ask us for copies of your personal information.
  • Your right to rectification — You have the right to ask us to rectify personal information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.
  • Your right to erasure — You have the right to ask us to erase your personal information in certain circumstances.
  • Your right to restriction of processing — You have the right to ask us to restrict the processing of your personal information in certain circumstances.
  • Your right to object to processing — You have the right to object to the processing of your personal information in certain circumstances.
  • Your right to data portability — You have the right to ask that we transfer the personal information you gave us to another organisation, or to you, in certain circumstances.

Please contact us at info@lkpeople.com if you wish to make a request. You are not required to pay any charge for exercising your rights. If you make a request, we have one month to respond to you. 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 these circumstances.

Disclosure

We may disclose your personal information if we are required to do so by law or if you violate our Terms of Service.

We may transmit your personal data outside of the EEA to the Rocket Science Group LLC, trading as Mailchimp, a provider of marketing and email platforms. Mailchimp is located in the United States of America and is a registered member of the Privacy Shield Scheme which guarantees appropriate safeguards are in place in respect of the personal data we transfer to it. You can find out more about how Mailchimp collects and stores personal information at: https://mailchimp.com/legal/privacy/.

We use Google Analytics to track website traffic. Google Analytics is a web analytics service offered by Google. Google uses the data collected to track and monitor the use of our websites. This data is shared with other Google services. Google may use the collected data to contextualise and personalise the ads of its own advertising network. For more information on the privacy practices of Google, please visit the Google Privacy Terms web page: https://policies.google.com/privacy/.

We may provide data to HMRC and other UK based authorities who, in certain circumstances, may require us to provide data.

We provide information to third parties who we interact with on your behalf, including: Clients’ employees and Candidates, our payrolling service providers, our pension providers, our IT and system administration providers, organisations who provide background checking/referencing services, our professional advisors within legal, accounting and auditing capacities and event providers.

In the event that we sell, transfer or merge part or whole of our business, then the new owners may use your personal data, as set out in this Privacy Policy.

Our third party providers are only permitted to process your personal data for specified purposes, in accordance with our instructions. We do not allow our third party providers to use your data for their own purposes.

We will not provide your personal information to third parties except as outlined in this policy.

Third-Party Services

In general, the third-party providers that we use will only collect, use and disclose your information to the extent necessary to allow them to perform the services they provide to us. However, certain third-party service providers have their own privacy policies in respect to the information we are required to provide to them.

Once you leave our website or are redirected to a third-party website or application, please note that you are no longer governed by this Privacy Policy or our website’s Terms of Service. When you click on links on our store, they may direct you away from our site. We are not responsible for the privacy practices of other sites and encourage you to read their respective privacy statements.

International Transfers

We may transfer your personal data to third parties providing services to us who are based outside of the European Economic Area (EEA). This includes parties providing IT administration services and hosting services and parties providing assistance with managing our marketing databases.

Whenever we transfer your personal data outside of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

  • you have expressly consented to the transfer of data;
  • transferring data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission;
  • using specific contracts approved by the European Commission which give personal data the same protection it has in Europe; or
  • for providers based in the US, we may transfer data to them if they are part of the Privacy Shield.

Data Retention

We will only retain your personal data 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, regulatory, tax, accounting or other requirements.

In some circumstances you can ask us to delete your data: see Your Data Protection Rights above for further information.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

Security

To protect your personal information, we take reasonable precautions and follow industry best practices to make sure it is not inappropriately lost, misused, accessed, disclosed, altered or destroyed. We follow all PCI-DSS requirements and implement additional generally accepted industry standards.

Cookies

The LK People website uses “cookies” to help improve your online experience. A cookie is a text file that is placed on your hard disk by our web page server. Cookies cannot be used to run programs or deliver viruses to your computer and are safe.

Cookies are uniquely assigned to you, and can only be read by a web server in the LK People domain that issued the cookie to you. None of these cookies on our website collect or store personal data, we only store standard internet log data for our internal reporting purposes. We do this to find out things such as the number of visitors to the various parts of the LK People website. We collect this information in a way which does not identify anyone, keeping your privacy as well as allowing us to improve the website wherever possible.

The LK People website does collect some personal/identifiable information but this is always done through asking you, the user to enter details such as your email address. We will not capture personal information without making you aware first.

You still have the ability to accept or decline cookies. Most Web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. If you choose to decline cookies, you may not be able to fully experience all the interactive features of the LK People website or Services.

Changes to this Privacy Policy

We reserve the right to modify this privacy policy at any time, so please review it frequently. Changes and clarifications will take effect immediately upon their posting on the website. If we make material changes to this policy, we will notify you here that it has been updated, so that you are aware of what information we collect, how we use it, and under what circumstances, if any, we use and/or disclose it.

If we are acquired by, or merged with, another company, your information may be transferred to the new owners so that we may continue to provide our services/products to you.

Questions and Contact Information

For any queries, comments, requests or concerns you may have regarding this Privacy Policy, including any request to exercise your rights over your data, please do not hesitate to contact our Data Privacy Manager, Kate Cook at kate@lkpeople.com.

If you have any concerns about our use of your personal information, you can also complain to the ICO if you are unhappy with how we have used your data.

ICO website: https://www.ico.org.uk.