Curve Group Holdings Limited Privacy Notice
Last update 17th September 2021
We respect your right to privacy. Our overall aim is to ensure that our collection and use of personal information is appropriate to the provision of services to you and our clients and is in accordance with applicable data protection laws.
- Who we are
- The personal information we collect about you
- How we store and use your personal information
- How we share your personal information and who we share it with
- International transfers
- Data Retention
- Your rights
- Third party sites
- Complaints, questions, and suggestions
Who We Are
Curve Group Holdings Limited is the data controller of the personal information that we collect from you. It is a company registered in England and Wales (registration number 06774645), whose registered office is at Charlton House Estate, Hinton-In-The-Hedges, Brackley, NN13 5LH.
The Personal Information We Collect About You
When you access and browse the Site (including when you submit personal information to us through data entry fields on the website) and where we provide Services to you or an actual or a potential employer or hirer of your services, we will usually collect the following information from or about you:
- your name
- your postal address
- your phone, [fax] and e-mail details
Your current and previous employment/work details, including job title and employer;
- recruitment specific details such as any professional certifications, education and qualifications, skills, career history, salary range, right to work status, citizenship, referee details and any other information relevant to help us provide recruitment services
- any other information which you include in your CV, a completed application form or in a subsequent specific request for further information sent by us to advance the recruitment process
- any information which has been published or made available on a social media profile or job board (whether by you or a third party), or in any news media
- references from third parties such as previous employers and nominated referees
- the results of pre-employment screening or vetting checks which we are asked or required to undertake in relation to you
- any email communications, including attachments, which you send to us
This applies whether your services are provided to a hirer direct, or via a third party in relation to whom Curve is appointed to coordinate recruitment and/or temporary resourcing supplies.
How We Store and Use Your Personal Information
Recruitment candidates and individual consultants
We collect, store and use your name, addresses and employment information for our legitimate interests, so that we can recommend opportunities and jobs to you that you may be interested in and to help us to provide suitable candidates and consultants for our clients who engage us to assist them fulfill their recruitment and resourcing requirements.
We will store information that we obtain in relation to you so that we are able to contact you about future roles and opportunities.
This storage and use of your personal information allow you to be contacted about roles that may be of interest to you, now or in the future, and we do not believe that this storage and use will unduly prejudice your rights or freedoms.
We will only share your name, addresses and employment information with our clients and any other third parties involved in the supply of resourcing services with your express consent. You can withdraw your consent at any point, but this may affect our ability to offer our recruitment services to you.
Contacts at our clients and other third parties involved in the supply of resourcing services
We collect, store, and use your name and contact details for our legitimate interests, so that we can send you the details of candidates and consultants and contact you about our Services.
This allows you to be contacted to receive and administer any Services which you or your organisation has requested. We do not believe that this storage and use of your personal information will unduly prejudice your rights or freedoms.
All users of the Site and our Services
We collect, store, and use your personal information for the following purposes:
- to make the Site available to you
- to provide any Services that you request
Sometimes, our use of your personal information is for purposes that are ancillary to the provision of the Site and the Services, or which are desirable in order to make them operate more effectively. In those circumstances, we can demonstrate a legitimate interest in handling your personal information, and do not believe that this storage and use of your personal information will unduly prejudice your rights or freedoms.
The relevant circumstances are:
- detecting and preventing fraud
- keeping our websites, apps, products, and IT systems secure
- ensuring that our own processes, procedures, and systems are as efficient as possible
- analysing and enhancing the information that we collect
- determining the effectiveness of our promotional campaigns and advertising
- and where you have given us your consent, contacting you (including by SMS and e-mail) with products and services which we think may interest you
In some, relatively limited, circumstances we need to handle your personal information in a certain way to be able to comply with our legal obligations – for example: if we are requested to disclose your personal information to regulatory bodies; if we need to demonstrate our compliance with applicable law; for the purposes of compliance with: the Conduct of Employment agencies and Employment Businesses Regulations 2003, any tax and national insurance legislation relating to the payment of personal service company contractors and umbrella workers, and immigration law.
We collect anonymised details about visitors to our website for the purposes of aggregate statistics or reporting purposes. However, no single individual will be identifiable from the anonymised details we collect for these purposes.
How We Share Your Personal Information and Who We Share It With
We will disclose information under the following circumstances:
- Service and Site usage information: When we share anonymous information generated by our Services with our customers
- Third-party service providers: When we share information with third-party service companies for them to facilitate or to provide certain services on our behalf. This will include:
- IT support service providers
- Providers of pre-employment evaluation, vetting and screening services (but only with your specific consent)
- Third-party service providers who track our customers’ use of the Site and the Services for us
- These companies are authorised to use your personal information only as necessary to provide the relevant services to us
- Merger or acquisition: When we need to transfer information about you if we are acquired by or merged with another company. If we are involved in a merger, acquisition, or sale of all or a portion of its assets, you will be notified by email and/or a prominent notice on our Site of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information
- Recruitment and resourcing services: When we are using your personal information in the context of our recruitment and resourcing services, then we may share your personal information with our clients or hirers where we believe that you may be appropriate for a particular role or vacancy with that client or hirer. This will only be done with your express consent
- Umbrella companies and personal service companies: When you inform us that you are supplying or intend to supply your services via Curve to a client or hirer through an umbrella company or personal service company
- Recruitment Process Outsourcing and Managed Service Providers: In certain cases, there may be an organisation such as a recruitment process outsourcing company or managed service provider acting as a gateway for the supply of Services made via Curve to the end client. Where this is the case, we will share your information with such organisations to the extent that it is necessary for the purposes of the supply
Where personal information is shared with clients, hirers, umbrella companies, personal services companies, recruitment process outsourcing companies or managed service providers in the circumstances described above, then those organisations will handle your personal information in line with their own privacy policies.
We may transfer personal information that we collect from you to third parties located in countries that are outside of the UK or the European Economic Area.
If we transfer personal information to third parties which are outside of the UK or the European Economic Area, then we will put in place measures to ensure it is afforded appropriate protection.
Technologies such as cookies, beacons, tags, and scripts are used by us and our affiliates, or analytics or service providers. These technologies are used in analysing trends, administering the Site, tracking users’ movements around the Site and to gather demographic information about our user base as a whole. We may receive reports based on the use of these technologies by these companies on an individual as well as aggregated basis.
We employ comprehensive, reasonable, and appropriate security measures to protect against the loss, misuse, and alteration of the personal information we process. This includes organisational security (passwords and access controls), physical security ( data centre protection) and IT security (encryption). Please note that no transmission over the Internet can ever be guaranteed secure. Consequently, please note that we cannot guarantee the security of any personal information that you transfer over the Internet to us.
We retain information (including personal information) for the minimum reasonable time period to allow us to provide our services and will delete it after that time except where we need to keep any personal information to comply with our legal obligations, resolve ongoing disputes, or enforce our agreements.
Should you require more detail about our retention timescales for a specific category of data or information please contact us at DPO@thecurvegroup.co.uk.
You have certain rights in relation to your personal information. If you would like further information in relation to these or would like to exercise any of them, please contact us at DPO@thecurvegroup.co.uk at any time. You have the right to request that we:
- provide access to any personal information we hold about you;
- update any of your personal information which is out of date or incorrect;
- delete any personal information which we are holding about you;
- restrict the way that we process your personal information;
- prevent the processing of your personal information for direct-marketing purposes;
- provide your personal information to a third-party provider of services;
- provide you with a copy of any personal information which we hold about you; or
- consider any valid objections which you have to our use of your personal information.
We will consider all such requests and provide our response within a reasonable period (and in any event within any time period required by applicable law). Please note, however, that certain personal information may be exempt from such requests in certain circumstances.
If an exception applies, we will tell you this when responding to your request. We may request you provide us with the information necessary to confirm your identity before responding to any request you make.
Third party sites
Complaints, questions, and suggestions
We have a Data Protection Officer to assist with all queries regarding our processing of personal information who can be contacted via DPO@thecurvegroup.co.uk.
If you have any complaints about our Site or services, please contact us at DPO@thecurvegroup.co.uk.
You may also make a complaint to our supervisory body for data protection matters (the Information Commissioner’s Office in the UK) or seek a remedy through local courts if you believe your rights have been breached. Here is a link to the ICO website : https://ico.org.uk/.
Our EU representative (Article 27) can be contacted for any EU and EEA data protection matters @ email@example.com who will act as your direct contact for data subjects outside of the UK and is the contact for the EU and EEA supervisory authorities.