Curve Group Holdings Limited Privacy Policy

This privacy policy governs the collection, storage and use of personal information collected by Curve (“Curve“, “we” or “us“), both via our website at http://www.thecurvegroup.co.uk/ (the “Site“) and through our provision of recruitment, resourcing and HR services to you and our clients (“Services“), either as an individual candidate or consultant or as a contact at one of our clients.

Specifically, this privacy policy provides you with details about the personal information we collect and hold about you, how we use your personal information, and your rights regarding the personal information we hold about you. It does not cover any specific use of your personal information by an actual or potential employer or hirer to whom we may provide your personal information. That use will be governed by the relevant employer’s or hirer’s privacy policy.

Please read this privacy policy carefully – by accessing or browsing the Site or requesting the provision of Services from us, you confirm that you have read and understood this privacy policy in its entirety.

Overview

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.

Further details of how we do so is set out in each section of our privacy policy as follows:

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.

You can contact us in relation to this privacy policy by email at DPO@thecurvegroup.co.uk.

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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 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 e mail 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 co-ordinate recruitment and/or temporary resourcing supplies.

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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 fulfil 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 allows you to be contacted about roles which 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; and

to provide any Services that you request.

Sometimes, our use of your personal information is for purposes which are ancillary to the provision of the Site and then Services, or which are desirable in order to make them to operate more effectively. In those circumstances, we believe we have 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.

Anonymous data

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.

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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.

  • Compliance with laws and legal proceedings: When we respond to court orders, or legal process, or to establish or exercise our legal rights or defend against legal claims. When we believe it is necessary to share information in order to investigate, prevent or take actions against illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of our terms of use, or as otherwise required by law.
  • 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.

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International transfers

We do not currently 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 update our Privacy Policy and put in place measures to ensure it is afforded appropriate protection.

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Cookies

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 use cookies, for example, to remember users’ settings (e.g. language preference) and for authentication. Users can control the use of cookies at the individual browser level. If you reject cookies, you may still use our Site, but your ability to use some features or areas of our Site may be limited.

Please read more about how we use cookies and what information is collected using cookies in our cookie policy here https://www.thecurvegroup.co.uk/cookies-policy/

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Security

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.

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Data Retention

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

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Your rights

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 information necessary to confirm your identity before responding to any request you make.

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Third party sites

This website contains links to other websites operated by third parties. Please note that this privacy policy applies only to the personal information that we collect through the Site or the Services, and we cannot be responsible for personal information that third parties may collect, store and use through their website. You should always read the privacy policy of each website you visit carefully.

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Changes to this Privacy Policy

This privacy policy was last updated in February 2018.

Please check back regularly to keep informed of updates to this privacy policy. Where we make significant changes to this privacy policy, and we have your email address, we will send you notification of the changes.

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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

In the EEA, 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.

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