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Privacy Notice

INTRODUCTION

This Privacy Notice explains how we manage your personal data.  We will ensure that the information you submit to us, or which we collect (via various channels including our websites, through written correspondence, e-mails, conversations or meetings with our employees, or through any of our offices), is only used for the purposes set out in this notice.

It describes how we collect, use and process your personal data, and how, in doing so, we comply with our legal obligations to you. Your privacy is important to us, and we are committed to protecting and safeguarding your data privacy rights.

It is a long document.  It needs to be to comply with the standards set by the General Data Protection Regulation (Regulation (EU) 2016/679) ("GDPR").  To assist you, we have created a ‘Summary’ section which provides some basic information, with links to the ‘Detail’ section below.

 

Nigel Wright Group (“NWG”)

This is a group-wide Privacy Notice which applies in relevant countries throughout our international network.  For the purpose of applicable data protection legislation (including but not limited to GDPR), the NWG company responsible for your personal data can be found here.

Different countries may approach data privacy in slightly different ways and so we also have country-specific parts to this Privacy Notice. You can find country-specific terms for your jurisdiction here. This allows us to ensure that we're complying with all applicable data privacy protections, no matter where you are.

 

Data Subject (“you”, “your”)

Whether we are in the process of helping you find a job, continuing our relationship with you once we have found you a role, providing you with a service, receiving a service from you, or you are visiting & using our website, we may be processing your personal data.

We have identified certain categories to help you understand what type of data we collect at any given time in our relationship.  But at NWG we recognise these are not mutually exclusive – at any point in time or over time you may fall in to one, two or possibly more categories.

Therefore, this Privacy Notice applies to the personal data of our CandidatesClientsSuppliersWebsite users, and Other People.  It also applies to the emergency contacts of our employees. To be clear, if you are an employee of NWG you should refer to the NWG Employee Fair Processing Notice which you received and is available via the HR department.

It is important to point out that we may amend this Privacy Notice from time to time. Please just visit this page if you want to stay up to date, as we will post any changes here.

If you are dissatisfied with any aspect of our Privacy Notice, you may have legal rights and, where relevant, we have described these as well.

 

SUMMARY SECTION

1.    What kind of personal data do we collect?

A number of elements of the personal data we collect from you are required to enable us to fulfil our contractual duties to you or to others. Where appropriate, some are required by statute or other laws. Other items may simply be needed to ensure that our relationship can run smoothly.

Depending on the type of personal data in question and the grounds on which we may be processing it, should you decline to provide us with such data, we may not be able to fulfil our contractual requirements or may not be able to continue with our relationship.

We have identified certain categories to help you understand what type of data we collect at any given time in our relationship.  But at NWG we recognise these are not mutually exclusive – at any point in time or over time you may fall in to one, two or possibly more categories.

 

1.1.  WEBSITE USERS: We collect a limited amount of data from our Website Users which we use to help us to improve your experience when using our website and to help us manage the services we provide. This includes information such as how you use our website, the frequency with which you access our website, and the times that our website is most popular. For more detail, please click here.

1.2.  CANDIDATE DATA: In order to provide the best possible employment opportunities that are tailored to you, we need to process certain information about you. We only ask for details that will genuinely help us to help you.  In addition to the obvious, such as your name, age, contact details, education and employment history etc, we may also need to know your immigration status, financial information (where we need to carry out financial background checks), and social security number.  Where appropriate and in accordance with local laws and requirements, we may also collect information related to your health, diversity information or details of any criminal convictions if you supply them. For more detail, please click here.

1.3.  CLIENT DATA: If you are a Client, we need to collect and use information about you or individuals at your organisation, in the course of providing services such as finding Candidates who are the right fit for you or your organisation; or assisting other organisations providing you with services. We may also notify you of content published by NWG which is likely to be relevant and useful to you (for example Salary Surveys). For more detail, please click here.

1.4.  SUPPLIER DATA: We need a small amount of information from our Suppliers to ensure that things run smoothly. We need contact details of relevant individuals at your organisation so that we can communicate with you. We also need other information such as your bank details so that we can pay for the services you provide (if this is part of the contractual arrangements between us). For more detail, please click here.

1.5.  OTHER PEOPLE:  In order to provide Candidates with suitable employment opportunities safely and securely and to provide for every eventuality for them and our employees, we need some basic background information. We only ask for very basic contact details, so that we can get in touch with you either for a reference or because you’ve been listed as an emergency contact for one of our Candidates or Employees members. For more detail, please click here.

For details of the legal bases that we rely on to be able to use and process your personal data, please click here.

 

2.    How do we collect your personal data?

There are two main ways in which we collect your personal data:

-       Directly from you; and

-       From third parties.

2.1.  As a Candidate please click here if you want to know more about how we collect personal data.

2.2.  As a Client please click here if you want to know more about how we collect personal data.

2.3.  As a Supplier we collect your personal data during the course of our work with you.

2.4.  For Other People we may receive your data from Candidates and employees, for example as their emergency contact or in order for you to serve as a referee.

2.5.  All Website Users; we collect your data automatically via cookies when you visit our website, in line with cookie settings in your browser. If you would like to find out more about cookies, including how we use them and what choices are available to you, please click here. We will also collect data from you when you contact us via the website, for example by submitting detail to receive research and articles.

 

3.    How do we use your personal data?

3.1.  CANDIDATE DATA: The main reason for using your personal details is to help you find employment or other work roles that might be suitable for you. The more information we have about you, your skillset and your ambitions, the more bespoke we can make our service. Where appropriate and in accordance with local laws and requirements, we may also use your personal data for things like marketing and diversity monitoring. Where appropriate, we will seek your consent to undertake some of these activities.  For more detail, please click here.

3.2.  CLIENT DATA: The main reason for using information about Clients is to ensure that the contractual arrangements between us can properly be implemented so that the relationship can run smoothly. The more information we have, the more bespoke we can make our service.  For more detail, please click here.

3.3.  SUPPLIER DATA: The main reasons for using your personal data are to ensure that the contractual arrangements between us can properly be implemented so that the relationship can run smoothly, and to comply with legal requirements. For more detail, please click here.

3.4.  OTHER PEOPLE:  We use referees’ personal data to help our Candidates to find employment which is suited to them. If we are able to verify their details and qualifications, we can make sure that they are well matched with prospective employers. We may also use referees' personal data to contact them in relation to recruitment activities that may be of interest to them. For more detail, please click here.

3.5.  WEBSITE USERS: We use your data to help us to improve your experience of using our website, for example by analysing your recent job search criteria to help us to present jobs to you that we think you'll be interested in. If you are also a Candidates or Client of NWG, we may use data from your use of our websites to enhance other aspects of our communications with, or service to, you. 

 

If you would like to find out more about cookies, including how we use them and what choices are available to you, please click here
 

Please note that all communications to and from NWG employees including emails may be reviewed as part of internal or external investigations or litigation.

 

4.    Who do we share your personal data with?

4.1.  CANDIDATE DATA: We may share your personal data with various parties, in various ways and for various reasons. Primarily we will share your information with prospective employers to increase your chances of securing the job you want. Unless you specify otherwise, we may also share your information with any of our group companies and associated third parties such as our service providers where we feel this will help us to provide you with the best possible service.  For more detail, please click here.

4.2.  CLIENT DATA: We will share your data primarily to ensure that we provide you with a suitable pool of Candidates. Unless you specify otherwise, we may share your information with any of our group companies and associated third parties such as our service providers to help us meet these aims. For more detail, please click here.

4.3.  SUPPLIER DATA: Unless you specify otherwise, we may share your information with any of our group companies and associated third parties such as our service providers and organisations to whom we provide services. For more detail, please click here.

4.4.  OTHER PEOPLE: Unless you specify otherwise, we may share your information with any of our group companies and associated third parties such as our service providers and organisations to whom we provide services. For more detail, please click here.

4.5.  WEBSITE USERS: Unless you specify otherwise, we may share your information with providers of web analytics services, marketing automation platforms and social media services to make sure any advertising you receive is targeted to you.

 

5.    How do we safeguard your personal data?

We care about protecting your information. That's why we put in place appropriate measures that are designed to prevent unauthorised access to, and misuse of, your personal data. For more detail, please click here.

 

6.    How long do we keep your personal data for?

The length of time we will hold or store your personal information for will depend on the services we perform for you and for how long you require these.  As we use Suppliers and often support Clients and Candidates over many years, and potentially throughout their careers, the purpose for which we retain data is often an ongoing purpose. 

We conduct regular data-cleansing and updating exercises to ensure that (a) the data that we hold is accurate and (b) we are not holding data for too long.  If we have not had meaningful contact with you for an extended period of time, 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, because of our obligations to tax authorities or in connection with any anticipated litigation). For more detail, please click here.

 

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

Even if we already hold your personal data, you still have various rights in relation to it as listed below: 

7.1.  Right to object: If we are using your data because we deem it necessary for our 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.

7.2.  Right to withdraw consent: Where we have obtained your consent to process your personal data for certain activities (for example, for profiling your suitability for certain roles), or consent to market to you, you may withdraw your consent at any time.

7.3.  Data Subject Access Requests (DSAR): Just so it's clear, you have the right to ask us to confirm what information we hold about you at any time, and 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:

7.3.1.    we may ask you to verify your identity, or ask for more information about your request; and

7.3.2.    where we are legally permitted to do so, we may decline your request, but we will explain why if we do so. 

7.4.  Right to erasure: In certain situations (for example, where we have processed your data unlawfully), you have the right to request us to "erase" 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 will generally assume that you would prefer us to keep a note of your name on our register of individuals who would prefer not to be contacted. That way, we will minimise the chances of you being contacted in the future where your data are collected in unconnected circumstances. If you would prefer us not to do this, you are free to say so.

7.5.  Right of 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. 

7.6.  Right to lodge a complaint with a supervisory authority: You also have the right to lodge a complaint with your local supervisory authority, details of which can be found here
 

If you would like to know more about your rights in respect of the personal data we hold about you, please click here

To get in touch about these, please contact us. We will seek to deal with your request without undue delay, and in any event in accordance with the requirements of any applicable laws. Please note that we may keep a record of your communications to help us resolve any issues which you raise.

If your interests or requirements change, you can unsubscribe from part or all of our marketing content (for example job role emails or NWG newsletters) by clicking the unsubscribe link in the email, or by contacting us.

 

8.    How do we store and transfer your data internationally?

NWG is a multi-national organisation that operates as one company. In order for us to continue operating in this way, we may have to transfer or store your data internationally.  For more detail, please click here.
 

9.    Who is responsible for processing your personal data on the NWG website?

NWG uses a third-party web hosting agency with all personal data collected being transferred directly to NWG.  For more detail, please click here.
  

10.  What are cookies and how do we use them?

10.1. A "cookie" is a bite-sized piece of data that is stored on your computer's hard drive. They are used by nearly all websites and do not harm your system. We use them to track your activity to help ensure you get the smoothest possible experience when visiting our website. We can use the information from cookies to ensure we present you with options tailored to your preferences on your next visit. We can also use cookies to analyse traffic and for advertising purposes. 

10.2. If you want to check or change what types of cookies you accept, this can usually be altered within your browser settings. If you don’t want to receive cookies that are not strictly necessary to perform basic features of our site, you may choose to opt-out by changing your browser settings. 

10.3. Most web browsers will accept cookies but if you would rather we didn’t collect data in this way you can choose to accept all or some, or reject cookies in your browser's privacy settings. However, rejecting all cookies means that you may not be able to take full advantage of all our website's features. Each browser is different, so check the "Help" menu of your browser to learn how to change your cookie preferences. 
 

For more information generally on cookies, including how to disable them, please refer to aboutcookies.org. You will also find details on how to delete cookies from your computer.

If you want to find out more about cookies, including how we use them and what choices are available, please click here.   

 

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DETAIL SECTION - CONTENTS

11.    What kind of personal information do we collect?

As mentioned at the beginning of the Summary section, we recognise the categories below are not mutually exclusive – at any point in time or over time you may fall in to one, two or possibly more categories.

The information described below is in addition to any personal data we are required by law to process in any given situation.

 

11.1. CANDIDATE DATA: Depending on the relevant circumstances and applicable local laws and requirements, we may collect some or all of the information listed below to enable us to offer you employment opportunities which are tailored to your circumstances and your interests. In some jurisdictions, we are restricted from processing some of the data outlined below. In such cases, we will not process the data in those jurisdictions:

  • Name;
  • Age/date of birth;
  • Birth number;
  • Sex/gender;
  • Photograph;
  • Marital status;
  • Contact details;
  • Education details;
  • Employment history;
  • Emergency contacts and details of any dependants;
  • Referee details;
  • Immigration status (whether you need a work permit);
  • Nationality/citizenship/place of birth;
  • A copy of your driving licence and/or passport/identity card;
  • Financial information (where we need to carry out financial background checks);
  • Social security number (or equivalent in your country) and any other tax-related information;
  • Diversity information including racial or ethnic origin, religious or other similar beliefs, and physical or mental health, including disability-related information;
  • Details of any criminal convictions if this is required for a role that you are interested in applying for;
  • Details about your current remuneration, pensions and benefits arrangements;
  • Information on your interests and needs regarding future employment, both collected directly and inferred, for example from jobs viewed or articles read on our website;
  • Extra information that you choose to tell us;
  • Extra information that your referees choose to tell us about you;
  • Extra information that our Clients may tell us about you, or that we find from other third party sources such as job sites;
  • IP address;
  • The dates, times and frequency with which you access our services; and
  • CCTV footage if you attend our premises. 

 

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

 

11.2.  CLIENT DATA: The data we collect about Clients is actually very limited. We generally only need to have your contact details or the details of individual contacts at your organisation (such as their names, telephone numbers and email addresses) to enable us to ensure that our relationship runs smoothly. We also hold information relating to your online usage of material published by NWG, which we use to ensure that our marketing communications to you are relevant and timely. We may also hold extra information that someone in your organisation has chosen to tell us.

11.3.  SUPPLIER DATA: We don't collect much data about Suppliers – we simply need to make sure that our relationship runs smoothly. We'll collect the details for our contacts within your organisation, such as names, telephone numbers and email addresses. We'll also collect bank details, so that we can pay you. We may also hold extra information that someone in your organisation has chosen to tell us.

11.4.  OTHER PEOPLE WHOSE DATA WE RECEIVE FROM CANDIDATES AND EMPLOYEES, SUCH AS REFEREES AND EMERGENCY CONTACTS: All we need from referees is confirmation of what you already know about our Candidates or prospective member of employees, so that they can secure that job they really want. Emergency contact details give us somebody to call on in an emergency. To ask for a reference, we'll obviously need the referee's contact details (such as name, email address and telephone number). We'll also need these details if our Candidates or a member of our employees has put you down as their emergency contact so that we can contact you in the event of an accident or an emergency. 

11.5.  WEBSITE USERS We collect a limited amount of data from our Website Users which we use to help us to improve your experience when using our website and to help us manage the services we provide. This includes information such as how you use our website, the frequency with which you access our website, your browser type, the location you view our website from, the language you choose to view it in and the times that our website is most popular. If you contact us via the website, we will collect any information that you provide to us. 
 

 

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12.    How do we collect your personal data?

As mentioned at the beginning of the Summary section, we recognise the categories below are not mutually exclusive – at any point in time or over time you may fall in to one, two or possibly more categories.

 

12.1.  CANDIDATE DATA: We collect Candidates personal data in three primary ways:

1. Personal data that you, the Candidates, give to us;

2. Personal data that we receive from other sources; and

3. Personal data that we collect automatically.

 

12.1.1.  Personal data you give to us:

NWG needs to know certain information about you in order to provide you with the best opportunities.  There are numerous ways you can share your information with us. These may include:

  • Entering your details on our websites or via an application form, as part of the registration process;
  • Leaving a hard copy CV at a NWG office or event;
  • Emailing your CV to a consultant or being interviewed by them;
  • Applying for jobs through a third party website, which then redirects you to our website;
  • Entering your personal details into a NWG microsite.

 

12.1.2.  Personal data we receive from other sources:

We also receive personal data about Candidates from other sources. Depending on the relevant circumstances and applicable local laws and requirements, these may include personal data received in the following situations:

  • Your referees may disclose personal information about you;
  • Our Clients may share personal information about you with us;
  • We may obtain information about you from searching for potential Candidates from third party sources, such as LinkedIn and other job sites;

 

12.1.3.  Personal data we collect automatically:

To the extent that you access our website or read or click on an email from us, where appropriate and in accordance with any local laws and requirements, we may also collect your data automatically or through you providing it to us. 
 

12.2.  CLIENT DATA: We collect Client personal data in three ways:

  1. Personal data that we receive directly from you;
  2. Personal data that we receive from other sources; and
  3. Personal data that we collect automatically.

 

12.2.1.  Personal data that we receive directly from you:

  • We will receive data directly from you in two ways:
  • Where you contact us proactively, usually by phone or email; and/or
  • Where we contact you, either by phone or email, or through our consultants' business development activities more generally.

 

12.2.2.  Personal data we receive from other sources:

Where appropriate and in accordance with any local laws and requirements, we may seek more information about you or your colleagues from other sources generally by way of due diligence or other market intelligence including:

  • From third party market research and by analysing online and offline media (which we may do ourselves, or employ other organisations to do for us);
  • From delegate lists at relevant events; and
  • From other limited sources and third parties (for example from our Candidates to the extent that they provide us with your details to act as a referee for them).

 

12.2.3.  Personal data we collect via our website:

To the extent that you access our website or read or click on an email from us, where appropriate and in accordance with any local laws and requirements, we may also collect your data automatically or through you providing it to us. For more information please click here
 

12.3  WEBSITE USERS: 

When you visit our website there is certain information that we may automatically collect, whether or not you decide to use our services. This includes your IP address, the date and the times and frequency with which you access the website and the way you browse its content. We will also collect data from you when you contact us via the website, for example when downloading or requesting a marketing report. 
  

We collect your data automatically via cookies, in line with cookie settings in your browser. If you are also a Candidate or Client of NWG, we may use data from your use of our websites to enhance other aspects of our communications with or service to you. If you would like to find out more about cookies, including how we use them and what choices are available to you, please click here

  

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13.    How do we use your personal data?

We use it in a number of ways.  As mentioned at the beginning of the Summary section, we recognise the categories below are not mutually exclusive – at any point in time or over time you may fall in to one, two or possibly more categories.

 

13.1.  CANDIDATE DATA: We generally use Candidate data for recruitment activities, marketing activities, equal opportunities monitoring and although unlikely, to help us establish, exercise or defend legal claims.

Here are some more details about each:

 

13.1.1.  Recruitment:

Connecting the right Candidates with the right jobs.  We've listed below various ways in which we may use and process your personal data for this purpose, where appropriate and in accordance with any local laws and requirements. Please note that this list is not exhaustive.

  • Collecting your data from you and other sources, such as LinkedIn;
  • Storing your details (and updating them when necessary) on our database, so that we can contact you in relation to recruitment;
  • Providing you with our recruitment services and to facilitate the recruitment process;
  • Assessing data about you against vacancies which we think may be suitable for you;
  • Sending your information to Clients, in order to apply for jobs or to assess your eligibility for jobs;
  • Enabling you to submit your CV, apply online for jobs or to subscribe to alerts about jobs we think may be of interest to you;
  • Carrying out our obligations arising from any contracts entered into between us;
  • Carrying out our obligations arising from any contracts entered into between NWG and third parties in relation to your recruitment;
  • Facilitating our payroll and invoicing processes;
  • Carrying out customer satisfaction surveys;
  • Verifying details you have provided, using third party resources (such as psychometric evaluations or skills tests), or to request information (such as references, qualifications and potentially any criminal convictions, to the extent that this is appropriate and in accordance with local laws);
  • Complying with our legal obligations in connection with the detection of crime or the collection of taxes or duties; and
  • Processing your data to enable us to send you targeted, relevant marketing materials or other communications which we think are likely to be of interest to you.

We may use your personal data for the above purposes if we deem it necessary to do so for our legitimate interests. If you want to know more about what this means, please click here. If you are not happy about this, in certain circumstances you have the right to object and can find out more about how and when to do this here

Please note that in certain of the jurisdictions in which we operate, we comply with additional local law requirements. For more information in relation to your jurisdiction, please click here.

 

13.1.2.  Marketing Activities:

We may periodically send you information that we think you may find interesting, or to ask for your help with connecting other Candidates with jobs. In particular, we may wish to use your data for the purposes listed below, where appropriate and in accordance with any local laws and requirements. Please note that this list is not exhaustive. To:

  • enable us to develop and market other products and services;
  • market our full range of recruitment services to you;
  • send you details of reports, networking and Client events, and general information about the industry sectors which we think might be of interest to you;
  • display promotional excerpts from your details on our websites as a success story (only where we have obtained your express consent to do so).

 

13.1.2.1.  We need your consent for some aspects of these activities which are not covered by our legitimate interests (in particular, the collection of data via cookies, and the delivery of direct marketing to you through digital channels) and, depending on the situation, we'll ask for this via an opt-in or soft-opt-in (which we explain in the next point). Please note that in certain of the jurisdictions in which we operate, we comply with additional local law requirements. For more information in relation to your jurisdiction, please click here.
 

13.1.2.2.  Soft opt-in consent is a specific type of consent which applies where you have previously engaged with us (for example by submitting a job application or CV, or registering a vacancy to be filled), and we are marketing other recruitment-related services. Under ‘soft opt-in’ consent, we will take your consent as given unless or until you opt out. For most people, this is beneficial as it allows us to suggest other jobs to you alongside the specific one you applied for, significantly increasing the likelihood of us finding you a new position. For other types of e-marketing, we are required to obtain your explicit consent.
 

13.1.2.3.  If you want to know more about how we obtain consent, please click here. If you are not happy about our approach to marketing, you have the right to withdraw your consent at any time and can find out more about how to do so here.  We want to let you know that even if you have opted out from our marketing communications, it is possible that your details may be recaptured through public sources in an unconnected marketing campaign. We will try to make sure this doesn't happen, but if it does, apologies in advance. We would just ask please that in those circumstances you opt out again. 

 

13.1.3.  Equal opportunities monitoring and other sensitive personal data

13.1.3.1.  Some of the data you may provide and we therefore (in appropriate circumstances and in accordance with local law and requirements) collect about you comes under the umbrella of "diversity information". This could be information about your ethnic background, gender, disability, age, sexual orientation, religion or other similar beliefs, and/or social-economic background. Where appropriate and in accordance with local laws and requirements, we may disclose this (suitably anonymised where relevant) data to Clients where this is contractually required or the Client specifically requests such information to enable them to comply with their own employment processes. 
 

13.1.3.2.  This information is what is called ‘sensitive’ personal information and slightly stricter data protection rules apply to it. We therefore need to obtain your explicit consent before we can use it. We'll ask for your consent by offering you an opt-in. This means that you have to explicitly and clearly tell us that you agree to us collecting and using this information.
 

13.1.3.3.  We may collect other sensitive personal data about you, such as health-related information, religious affiliation, or details of any criminal convictions if this is appropriate in accordance with local laws and is required for a role that you are interested in applying for. We will never do this without your explicit consent. 
 

If you would like to find out more about consent, please click here. Please note that in certain of the jurisdictions in which we operate, different rules apply to this sensitive data. For more information in relation to your jurisdiction, please click here.
 

If you are not happy about this, you have the right to withdraw your consent at any time and you can find out how to do so here
 

 

13.2.  CLIENT DATAWe use Client information for Recruitment Activities, Marketing Activities and although unlikely, to help us to establish, exercise or defend legal claims.  Here are some more details: 

 

13.2.1.  Recruitment

We've listed below the various ways in which we use your data in order to facilitate this.

  • Storing your details (and updating them when necessary) on our database, so that we can contact you in relation to recruitment activities;
  • Keeping records of our conversations and meetings, so that we can provide targeted services to you;
  • Undertaking customer satisfaction surveys; and
  • Processing your data for the purpose of targeting appropriate marketing campaigns. 
  • We may use your personal data for these purposes if we deem this to be necessary for our legitimate interests. If you would like to know more about what this means, please click here
     

If you are not happy about this, in certain circumstances you have the right to object and can find out more about how and when to do this here 
 

13.2.2.  Marketing Activities

Subject to any applicable local laws and requirements, we will not, as a matter of course, seek your consent when sending marketing materials to a corporate postal or email address.

If you are not happy about this, you have the right to opt out of receiving marketing materials from us and can find out more about how to do so here.

Please note that in certain of the jurisdictions in which we operate, we comply with additional local law requirements regarding marketing activities. For more information in relation to your jurisdiction, please click here.
 

 

13.3.  SUPPLIER DATA:  we will only use your information to:

  • store (and update when necessary) your details on our database, so that we can contact you in relation to our agreements;
  • potentially offer services to you or to obtain support and services from you;
  • perform certain legal obligations;
  • help us to target appropriate marketing campaigns; and
  • In more unusual circumstances, to help us to establish, exercise or defend legal claims.

We may use your personal data for these purposes if we deem this to be necessary for our legitimate interests. If you want to know more about what this means, please click here

We will not, as a matter of course, seek your consent when sending marketing messages to a corporate postal or email address.

If you are not happy about this, in certain circumstances you have the right to object and can find out more about how to do so here

Please note that in certain of the jurisdictions in which we operate, we comply with additional local law requirements For more information in relation to your jurisdiction, please click here.

 

13.4.  OTHER PEOPLE

If a Candidate or employee has provided your details for an emergency contact, we'll contact you in the case of an accident or emergency affecting them; or

If you were put down as a referee, we will contact you in order to take up a reference. This is an important part of our quality assurance process and could be the difference between the individual getting a job or not.

We may sometimes use your details to contact you in relation to recruitment activities that we think may be of interest to you, in which case we will use your data for the same purposes for which we use the data of Clients. If you would like to find out more about what this means, please click here.

We may use your personal data for these purposes if we deem this to be necessary for our legitimate interests. If you would like to find out more about what this means, please click here.

If you are not happy about this, you have the right to object and can find out more about how to do so here 
  

 

13.5.  WEBSITE USERS: We use your data to help us to improve your experience of using our website, for example by analysing your recent job search criteria to help us to present jobs or Candidates to you that we think you'll be interested in. 

If you would like to find out more about cookies, including how we use them and what choices are available to you, please click here
 

 

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14.  Who do we share your personal data with?

Where appropriate and in accordance with local laws and requirements, we may share your personal data, in various ways and for various reasons, with the following categories of people:

  • Any of our group companies;
  • Any Client who is a potential employer and other recruitment agencies/organisations to increase your chances of finding employment;
  • Individuals and organisations who hold information related to your reference or application to work with us, such as current, past or prospective employers, educators and examining bodies and employment and recruitment agencies;
  • Tax, audit, or other authorities, when we believe in good faith that the law or other regulation requires us to share this data (for example, because of a request by a tax authority or in connection with any anticipated litigation);
  • Third party service providers who perform functions on our behalf (including external consultants, business associates and professional advisers such as lawyers, auditors and accountants, technical support functions and IT consultants carrying out testing and development work on our business technology systems);
  • Third party outsourced IT and document storage providers where we have an appropriate processing agreement (or similar protections) in place;
  • Marketing technology platforms and suppliers;
  • Third parties who we have retained to provide services such as reference, qualification and criminal convictions checks, to the extent that these checks are appropriate and in accordance with local laws;
  • If NWG merges with or is acquired by another business or company in the future, (or is in meaningful discussions about such a possibility) we may share your personal data with the (prospective) new owners of the business or company.

 

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15.  How do we safeguard your personal data?

We are committed to taking all reasonable and appropriate steps to protect the personal information that we hold from misuse, loss, or unauthorised access. We do this by having in place a range of appropriate technical and organisational measures. These include measures to deal with any suspected data breach.
 

If you suspect any misuse or loss of or unauthorised access to your personal information, please let us know immediately. Details of how to contact us can be found here.

 

16.  How long do we keep your personal data for?

The length of time we will hold or store your personal information for will depend on the services we perform for you and for how long you require these.  As we use Suppliers and often support Clients and Candidates over many years, and potentially throughout their careers, the purpose for which we retain data is often an ongoing purpose.  We conduct regular data-cleansing and updating exercises with our Candidates to ensure that (a) the data that we hold is accurate and (b) we are not holding data for too long.  If we have not had meaningful contact with you for an extended period of time, 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, because of our obligations to tax authorities or in connection with any anticipated litigation). 

 

When we refer to "meaningful contact", we mean, for example, communication between us (either verbal or written including email), or where you are actively engaging with our online services including applying for jobs or uploading your CV onto our website.  We will also consider it meaningful contact if you communicate with us about potential roles, either by verbal or written communication including email.  Your receipt of an email or other digital message from us will not count as meaningful contact – this will only occur in cases where you open, click-through or reply directly. 
 

 

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

One of the GDPR's main objectives is to protect and clarify the rights of EU citizens and individuals in the EU with regards to data privacy. This means that you retain various rights in respect of your data, even once you have given it to us. These are described in more detail below.  To get in touch about these rights, please contact us. We will seek to deal with your request without undue delay, and in any event within one month (subject to any extensions to which we are lawfully entitled). Please note that we may keep a record of your communications to help us resolve any issues which you raise.
 

17.1.  Right to object: this right enables you to object to us processing your personal data where we do so for one of the following four reasons: (i) our legitimate interests; (ii) to enable us to perform a task in the public interest or exercise official authority; (iii) to send you direct marketing materials; and (iv) for scientific, historical, research, or statistical purposes.
 

The "legitimate interests" and "direct marketing" categories above are the ones most likely to apply to you. If your objection relates to us processing your personal data because we deem it 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. 
 

17.2.  Right to withdraw consent: Where we have obtained your consent to process your personal data for certain activities (for example, for our marketing arrangements), you may withdraw this consent at any time and we will cease to carry out the particular activity that you previously consented to unless we consider that there is an alternative reason to justify our continued processing of your data for this purpose in which case we will inform you of this condition.
 

17.3.   Data Subject Access Requests (DSAR): You may ask us to confirm what information we hold about you at any time, and request us to modify, update or Delete such information. We may ask you to verify your identity and for more information about your request. If we provide you with access to the information we hold about you, we will not charge you for this unless your request is manifestly unfounded or excessive. If you request further copies of this information from us, we may charge you a reasonable administrative cost where legally permissible. Where we are legally permitted to do so, we may refuse your request. If we refuse your request, we will always tell you the reasons for doing so. 
 

Please note that in certain of the jurisdictions in which we operate, we comply with additional local law requirements regarding data subject access requests and may refuse your request in accordance with such laws. For more information in relation to your jurisdiction, please click here.
 

17.4.  Right to erasure: You have the right to request that we erase your personal data in certain circumstances. Normally, the information must meet one of the following criteria:

  • the data are no longer necessary for the purpose for which we originally collected and/or processed them;
  • where previously given, you have withdrawn your consent to us processing your data, and there is no other valid reason for us to continue processing;
  • the data has been processed unlawfully (i.e. which does not comply with GDPR);
  • it is necessary for the data to be erased in order for us to comply with our legal obligations as a data controller; or
  • 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 our continued processing.

Please note that in certain of the jurisdictions in which we operate, we comply with additional local law requirements regarding data subject right to erasure and may refuse your request in accordance with local laws. For more information in relation to your jurisdiction, please click here.
 

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

  • to exercise the right of freedom of expression and information;
  • to comply with legal obligations or for the performance of a public interest task or exercise of official authority;
  • for public health reasons in the public interest;
  • for archival, research or statistical purposes; or
  • 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.
 

17.5.  Right to restrict processing: You have the right to request that we restrict our processing of your personal data in certain circumstances. This means that we can only continue to store your data and will not be able to carry out any further processing activities with it until either: (i) one of the circumstances listed below is resolved; (ii) you consent; or (iii) further processing is necessary for either the establishment, exercise or defence of legal claims, the protection of the rights of another individual, or reasons of important EU or Member State public interest. 
 

The circumstances in which you are entitled to request that we restrict the processing of your personal data are:

  • where you dispute the accuracy of the personal data that we are processing about you. In this case, our processing of your personal data will be restricted for the period during which the accuracy of the data is verified;
  • where you object to our processing of your personal data for our legitimate interests. Here, you can request that the data be restricted while we verify our grounds for processing your personal data;
  • where our processing of your data is unlawful, but you would prefer us to restrict our processing of it rather than erasing it; and
  • where we have no further need to process your personal data but you require the data to establish, exercise, or defend legal claims.

 

If we have shared your personal data with third parties, we will notify them about the restricted processing unless this is impossible or involves disproportionate effort. We will, of course, notify you before lifting any restriction on processing your personal data.
 

17.6.  Right to rectification: You also have the right to request that we rectify any inaccurate or incomplete personal data that we hold about you. If we have shared this personal data with third parties, we will notify them about the rectification unless this is impossible or involves disproportionate effort. Where appropriate, we will also tell you which third parties we have disclosed the inaccurate or incomplete personal data to. Where we think that it is reasonable for us not to comply with your request, we will explain our reasons for this decision.
 

17.7.  Right of data portability: If you wish, you have the right to transfer your personal data between data controllers. In effect, this means that you are able to transfer your Hays account details to another online platform. To allow you to do so, we will provide you with your data in a commonly used machine-readable format that is password-protected so that you can transfer the data to another online platform. Alternatively, we may directly transfer the data for you. This right of data portability applies to: (i) personal data that we process automatically (i.e. without any human intervention); (ii) personal data provided by you; and (iii) personal data that we process based on your consent or in order to fulfil a contract.

 

17.8.  Right to lodge a complaint with a supervisory authority: You also have the right to lodge a complaint with your local supervisory authority. Details of how to contact them can be found here
 

If you would like to exercise any of these rights, or withdraw your consent to the processing of your personal data (where consent is our legal basis for processing your personal data), details of how to contact us can be found here. Please note that we may keep a record of your communications to help us resolve any issues which you raise.
 

You may ask to unsubscribe from job alerts or emails at any time. Details of how to do so can be found here.
 

It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during the period for which we hold your data.
  

 

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18.  Who is responsible for processing your personal data on the NWG website?

NWG uses a third-party web hosting agency to provide a platform for our website, with whom we have an appropriate processing arrangement in place. 

All personal data captured by the website is transferred directly to NWG.  You can find out which NWG entity is responsible for processing your personal data and where it is located by following this link
 

If you have any comments or suggestions concerning this Privacy Notice please contact us

 

19.  How do we store and transfer your data internationally?

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

  • between and within NWG entities;
  • to third parties such as advisers or others as noted above;
  • to overseas Clients;
  • to Clients within your country who may, in turn, transfer your data internationally;
  • to a cloud-based storage provider.

We want to make sure that your data are stored and transferred in a way which is secure. We will therefore only transfer data outside of the European Economic Area or EEA (i.e. the Member States of the European Union, together with Norway, Iceland and Liechtenstein) where it is compliant with data protection legislation and the means of transfer provides adequate safeguards in relation to your data, for example:

19.1.  by way of data transfer agreement, incorporating the current standard contractual clauses adopted by the European Commission for the transfer of personal data by data controllers in the EEA to data controllers and processors in jurisdictions without adequate data protection laws; or

19.2.   by signing up to the EU-U.S. Privacy Shield Framework for the transfer of personal data from entities in the EU to entities in the United States of America or any equivalent agreement in respect of other jurisdictions; or

19.3.  transferring your data to a country where there has been a finding of adequacy by the European Commission in respect of that country's levels of data protection via its legislation; or

19.4.  where it is necessary for the conclusion or performance of a contract between ourselves and a third party and the transfer is in your interests for the purposes of that contract (for example, if we need to transfer data outside the EEA in order to meet our obligations under that contract if you are a Client of ours); or

19.5.  where you have consented to the data transfer.

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

 

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20.  COOKIES POLICY

20.1.  What's a cookie?

A "cookie" is a piece of information that is stored on your computer's hard drive and which records your navigation of a website so that, when you revisit that website, it can present tailored options based on the information stored about your last visit. Cookies can also be used to analyse traffic and for advertising and marketing purposes. 
 

Cookies are used by nearly all websites and do not harm your system. If you want to check or change what types of cookies you accept, this can usually be altered within your browser settings. We also provide information about this in our Marketing preferences page on the Hays website.
 

20.2.  How do we use cookies?

We use cookies to do two things:

  • to track your use of our website. This enables us to understand how you use the site and track any patterns that emerge individually or from larger groups. This helps us to develop and improve our website and services in response to what our visitors want and need; and
  • to help us advertise jobs to you that we think you'll be interested in. Hopefully this means less time for you trawling through endless pages and will get you into the employment you want more quickly.

 

20.3.  Cookies are either:

  • Session cookies: these are only stored on your computer during your web session and are automatically deleted when you close your browser – they usually store an anonymous session ID allowing you to browse a website without having to log in to each page but they do not collect any information from your computer; or
  • Persistent cookies: a persistent cookie is stored as a file on your computer and it remains there when you close your web browser. The cookie can be read by the website that created it when you visit that website again. We use persistent cookies for Google Analytics and for personalisation (see below).

 

20.4.  Cookies can also be categorised as follows:

  • Strictly necessary cookies: These cookies are essential to enable you to use the website effectively, such as when applying for a job, and therefore cannot be turned off. Without these cookies, the services available to you on our website cannot be provided. These cookies do not gather information about you that could be used for marketing or remembering where you have been on the internet.
  • Performance cookies: These cookies enable us to monitor and improve the performance of our website. For example, they allow us to count visits, identify traffic sources and see which parts of the site are most popular.
  • Functionality cookies: These cookies allow our website to remember choices you make (such as your user name, language or the region you are in) and provide enhanced features. For instance, we may be able to provide you with news or updates relevant to the services you use. These cookies can also be used to remember changes you have made to text size, font and other parts of web pages that you can customise. They may also be used to provide services you have requested such as viewing a video or commenting on a blog. The information these cookies collect is usually anonymised.
  • Personalisation cookies: These cookies help us to advertise details of potential job opportunities that we think may be of interest. These cookies are persistent (for as long as you are registered with us) and mean that when you log in or return to the website, you may see advertising for jobs or content similar to that which you have previously browsed.

If you wish to understand more about the purpose of and how Cookies are used at NWG please contact us.

 

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21.  Our legal bases for processing your data

21.1.  LEGITIMATE INTERESTS

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

We don't think that any of the following activities prejudice individuals in any way.  They help us to offer you a more tailored, efficient service. However, you do have the right to object to us processing your personal data on this basis. If you would like to know more about how to do so, please click here.
 

Please note that in certain of the jurisdictions in which we operate, a different legal basis for data processing might apply in certain cases. For more information in relation to your jurisdiction, please click here.
 

21.1.1.  CANDIDATE DATA:

We think it's reasonable to expect that if you are looking for employment or have posted your professional CV information on a job board or professional networking site, you are happy for us to collect and otherwise use your personal data to offer or provide our recruitment services to you, share that information with prospective employers and assess your skills against our bank of vacancies. Once it's looking like you may be offered the job, your prospective employer may also want to double check any information you've given us (such as the results from psychometric evaluations or skills tests) or to confirm your references, qualifications and criminal record, to the extent that this is appropriate and in accordance with local laws.

We want to provide you with tailored job recommendations and relevant articles to read to help you. We therefore think it's reasonable for us to process your data to make sure that we send you the most appropriate content. 

We have to make sure our business runs smoothly, so that we can carry on providing services to Candidates like you. We therefore also need to use your data for our internal administrative activities, like payroll and invoicing where relevant. 

We have our own obligations under the law, which it is a legitimate interest of ours to insist on meeting. If we believe in good faith that it is necessary, we may therefore share your data in connection with crime detection, tax collection or actual or anticipated litigation. 
 

21.1.2.  CLIENT DATA:
 

To ensure that we provide you with the best service possible, we store your personal data and/or the personal data of individual contacts at your organisation as well as keeping records of our conversations, meetings, registered jobs and placements. From time to time, we may also ask you to undertake a customer satisfaction survey. We think this is reasonable – we deem these uses of your data to be necessary for our legitimate interests as an organisation providing various recruitment services to you. 
 

21.1.3.  SUPPLIER DATA:
 

We use and store the personal data of individuals within your organisation in order to facilitate the receipt of services from you as one of our Suppliers. We also hold your financial details, so that we can pay you for your services. We deem all such activities to be necessary within the range of our legitimate interests as a recipient of your services. 
 

21.1.4.  OTHER PEOPLE WHOSE DATA WE RECEIVE FROM CANDIDATES AND EMPLOYEES, SUCH AS REFEREES AND EMERGENCY CONTACTS:
 

If you have been put down by a Candidate or a prospective member of employees as one of their referees, we use your personal data in order to contact you for a reference. This is a part of our quality assurance procedure and so we deem this to be necessary for our legitimate interests as an organisation offering recruitment services and employing people ourselves. 
 

If a Candidate or employees member has given us your details as an emergency contact, we will use these details to contact you in the case of an accident or emergency. We are sure you will agree that this is a vital element of our people-orientated organisation, and so is necessary for our legitimate interests. 
 

 

21.2.  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." In plain language, this means that:

 

  • you have to give us your consent freely, without us putting you under any type of pressure;
  • you have to know what you are consenting to – so we'll make sure we give you enough information;
  • you should have control over which processing activities you consent to and which you don’t. We provide these finer controls within our privacy preference centre; and
  • 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. 
 

Please note that in certain of the jurisdictions in which we operate, we comply with additional local law requirements regarding consenting to receive marketing materials. For more information in relation to your jurisdiction, please click here.
 

As we have mentioned, you have the right to withdraw your consent to these activities. You can do so at any time, and details of how to do so can be found here
  

21.3.  ESTABLISHING, EXERCISING OR DEFENDING LEGAL CLAIMS

Sometimes it may be necessary for us to process personal data and, where appropriate and in accordance with local laws and requirements, sensitive personal data in connection with exercising or defending legal claims. Article 9(2)(f) of the GDPR allows this where the processing "is necessary for the establishment, exercise or defence of legal claims or whenever courts are acting in their judicial capacity".
 

This may arise for example where we need to take legal advice in relation to legal proceedings or are required by law to preserve or disclose certain information as part of the legal process.
 

 

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ANNEX 1 – HOW TO CONTACT US

 

The NWG entity responsible for processing the personal data of Candidates, Clients, Suppliers and the emergency contacts and referees of Candidates and employees will depend on which of the below companies is the counterparty associated with the relevant arrangement: 

 

  • Nigel Wright Group Holdings Limited
  • Nigel Wright Group Limited
  • Nigel Wright Consultancy Limited
  • Nigel Wright Employment Services Limited
  • Nigel Wright International Limited
  • Nigel Wright Consultancy Denmark ApS
  • Nigel Wright Consultancy Sweden AB
  • Nigel Wright Consultancy Norway AS
  • Nigel Wright Consultancy Deutschland GmbH
  • Nigel Wright Consultancy Espana S.L.
  • Nigel Wright Consultancy Switzerland Sarl
  • Nigel Wright Consultancy Netherlands BV

 

If you wish to:

  • access, amend or take back the personal data that you have given to us; or
  • if you suspect any misuse or loss of or unauthorised access to your personal information; or
  • to withdraw your consent to the processing of your personal data (where consent is the legal basis on which we process your personal data);
  • provide us with any comments or suggestions concerning this Privacy Notice
  • update your marketing preferences (you can easily unsubscribe by clicking the link in any marketing e-mail we send to you).  

 

You can write to us at the following address:

 

Privacy & Data Protection Team

Nigel Wright Group Ltd

Lloyds Court, 78 Grey Street, Newcastle, NE1 6AF, UK

 

Alternatively, you can send an email to: gdpr@nigelwright.com
 

 

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ANNEX 2 – HOW TO CONTACT YOUR LOCAL SUPERVISORY AUTHORITY

 

Country in which you use NWG services or supply NWG with services: UK

The Information Commissioner's Office: https://ico.org.uk/

Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

NOTE: FOR OTHER JURISDICTIONS PLEASE CONTACT US FOR FURTHER DETAILS.

 

 

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ANNEX 3 – COUNTRY-SPECIFIC VARIATIONS TO OUR PRIVACY NOTICE

JURISDICTION: UK

COUNTRY-SPECIFIC LEGAL REQUIREMENT: Where your personal data are processed in accordance with the fair processing condition relating to our rights and obligations under employment and social security law, this relates to our processing of your personal data which is necessary for compliance with legal obligations (such as ensuring that we pay you statutory sick pay, comply with the statutory employment protections that you enjoy, comply with health and safety laws, and ensure that appropriate National Insurance contributions are made). 

 

NOTE: FOR OTHER JURISDICTIONS THIS APPENDIX WILL BE UPDATED WHEN LOCAL IMPLEMENTING LAW HAS BEEN FINALISED.

Please contact us for further details.

 

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GLOSSARY

I.  Candidates – includes applicants for all roles advertised or promoted by NWG, including permanent, part-time and temporary positions and freelance roles with NWG Clients; as well as people who have supplied a speculative CV to NWG not in relation to a specific job. Individual contractors, employees of suppliers or other third parties put forward for roles with NWG will be treated as candidates for the purposes of this Privacy Notice. 
 

II.  Clients - while it speaks for itself, this category covers our customers, clients, and others to whom NWG provides services in the course of its business.
 

III.  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 employees. 
 

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

V.  Other people– these may include Candidates' and NWG employees emergency contacts and referees. We will only contact them in appropriate circumstances.
 

VI.  Employees – includes employees and interns engaged directly in the business of NWG (or who have accepted an offer to be engaged) as well as certain other workers engaged in the business of providing services to NWG (even though they are not classed as employees). For these purposes we also include employees of NWG who are engaged to work on Clients' premises under the terms of RPO or MSP agreements. To be clear, 'Employees' does not include individuals hired by NWG for the purpose of being placed with Clients. These individuals are treated in the same way as NWG Candidates and are covered by this Privacy Notice. Likewise, independent contractors and consultants performing services for NWG fall within the definition of a 'Supplier' for the purposes of this Privacy Notice.
 

VII.  Suppliers – refers to partnerships and companies (including sole traders), and atypical workers such as independent contractors and freelance workers, who provide services to NWG. In certain circumstances NWG will sub-contract the services it provides to Clients to third party suppliers who perform services on NWG’s' behalf. In this context, suppliers that are individual contractors, employees of suppliers will be treated as Candidates for data protection purposes. Please note that in this context, NWG requires Suppliers to communicate the relevant parts of this Privacy Notice (namely the sections directed at Candidates) to their employees.
 

VIII.  Website Users - any individual who accesses any of the NWG websites.