Privacy Notice
1. Introduction
Clearstep Recruitment Limited (“Clearstep”, “we”, “us”, “our”) is committed to protecting the privacy, confidentiality, and security of personal data and to processing personal data fairly, lawfully, and transparently in accordance with the UK General Data Protection Regulation (“UK GDPR”), the Data Protection Act 2018, and all applicable data protection laws.
This Privacy Notice explains how we collect, use, store, disclose, and protect personal data when individuals engage with our recruitment services, apply for work, are matched to vacancies, communicate with us, or otherwise interact with Clearstep.
By engaging with our services, you acknowledge that your personal data will be processed in accordance with this Privacy Notice.
We apply the principles of data minimisation, ensuring we only process personal data necessary for the purposes described in this Notice.
2. Who This Privacy Notice Applies To
This Privacy Notice applies to:
- Job applicants
- Candidates
- Workers
- Contractors
- Consultants
- Agency workers
- Employees placed through Clearstep
- Client contacts
- Supplier contacts
- Business contacts
- Website users
- Any individual who provides personal data to us
3. Data Controller
Clearstep Recruitment Limited is the Data Controller for the personal data we collect and process.
Questions regarding this Privacy Notice or our processing of personal data should be directed to our Privacy Team using the contact details published on our website.
4. Personal Data We Collect
We may collect, store, use, and process the following categories of personal data.
Identity Data
Full name; previous names; date of birth; nationality; gender; photograph; passport details; driving licence details; National Insurance number; right-to-work documentation.
Contact Data
Residential address; correspondence address; telephone numbers; email addresses; emergency contact details.
Recruitment & Employment Data
Curriculum vitae; employment history; assignment history; qualifications; professional memberships; training records; skills and competencies; interview notes; references; availability information; work preferences.
Financial & Payroll Data
Bank account information; payroll information; salary details; tax information; pension information; payment history; expenses information.
Compliance Data
Right-to-work records; identity verification records; compliance screening results; anti-fraud checks; regulatory checks.
Technical Data
IP address; browser information; device information; login data; website usage information; cookie data.
Communications Data
Email correspondence; telephone records; SMS messages; WhatsApp messages; notes relating to communications.
5. Special Category Personal Data
Where necessary and permitted by law, we may process special category personal data including:
Health information; disability information; occupational health information; racial or ethnic origin; religious or philosophical beliefs; trade union membership.
Such data will only be processed where an appropriate legal condition exists under applicable legislation.
6. Criminal Offence Data
Where required by law, regulation, client requirements, or legitimate business necessity, we may process information relating to criminal convictions, offences, allegations, sanctions, and background screening.
Such processing will only occur where legally permitted.
7. How We Collect Personal Data
We may collect personal data:
Directly from you; through application forms; registration forms; CV submissions; interviews; communications; our website; recruitment agencies; employment businesses; umbrella companies; clients and end hirers; referees; publicly available sources; identity verification providers; compliance providers; regulatory authorities; service providers acting on our behalf.
8. Purposes of Processing
We may process personal data for the following purposes:
Recruitment activities; candidate assessment; candidate matching; vacancy sourcing; assignment management; onboarding; compliance checks; right-to-work verification; employment administration; payroll coordination; contractor management; workforce management; client servicing; business administration; financial management; risk management; fraud prevention; security management; legal proceedings; regulatory reporting; service improvement; business development; marketing.
Candidate Communications
We may contact individuals using the contact details provided to us, including telephone calls, SMS text messages, WhatsApp messages, and email. These communications relate to recruitment activities, candidate matching, assignment opportunities, onboarding, compliance requirements, payroll matters, and other services described in this Privacy Notice. This includes job lists, vacancy alerts, assignment updates, and role-matching communications.
Use of WhatsApp and Third-Party Messaging Platforms
Where we contact individuals via WhatsApp or similar platforms, this may involve processing through the platform provider, which operates outside our direct control. WhatsApp may process metadata and device information in accordance with its own privacy policy, which operates independently of ours.
Service Communications vs Marketing
Communications relating to job opportunities, assignments, onboarding, compliance, and payroll are service communications, not marketing. Marketing communications will only be sent where legally permitted.
9. Lawful Bases for Processing
We process personal data under one or more of the following lawful bases:
Contract
Processing necessary for entering into a contract, performing contractual obligations, managing employment relationships, or providing requested recruitment services.
Legal Obligation
Processing required to comply with employment law, tax law, immigration law, regulatory obligations, court orders, or statutory requirements.
Legitimate Interests
We may process personal data where necessary for our legitimate interests, including:
Operating recruitment services; matching candidates to vacancies; workforce management; business administration; security management; fraud prevention; client relationship management; service improvement; business development; communicating relevant work opportunities using WhatsApp, SMS, telephone, and email.
We rely on legitimate interests to contact individuals about relevant work opportunities, as such communications are necessary to deliver recruitment and employment services requested by individuals.
We ensure that our legitimate interests do not override the rights and freedoms of individuals.
Consent
We do not rely on consent for recruitment, employment, or payroll processing. Consent may be used only where appropriate and can be withdrawn at any time.
10. Sharing Personal Data with Associated Businesses
Definition of Associated Businesses
“Associated Businesses” refers to:
- Clearstep Recruitment Limited
- The Umbrella Team Limited
- Any umbrella, payroll, contractor management, or workforce management companies operated by the same directors
- Any successor or replacement entities performing similar functions
Data Sharing
We may share personal data with Associated Businesses for:
Identifying suitable candidates; matching individuals with vacancies; recruitment activities; employment administration; payroll administration; contractor management; workforce management; assignment administration; compliance checks; identity verification; right-to-work verification; client servicing; business administration; future employment opportunities; future assignments; fraud prevention; regulatory compliance; legal compliance.
Associated Businesses may act as independent controllers, joint controllers, or processors depending on the circumstances.
Business Continuity & Corporate Events
Where an Associated Business ceases trading, enters administration, liquidation, dissolution, or undergoes a merger, acquisition, restructuring, or transfer of operations, personal data may be retained and processed by the remaining Associated Businesses or any successor entity. This ensures continuity of recruitment, employment, payroll, contractor management, workforce management, compliance, and related services.
Any such processing will continue in accordance with this Privacy Notice and applicable data protection legislation.
11. Other Recipients of Personal Data
We may share personal data with recruitment agencies; employment businesses; umbrella companies; end clients; hirers; payroll providers; pension providers; accountants; auditors; solicitors; insurers; banks; HM Revenue & Customs; the Home Office; government departments; regulators; compliance providers; identity verification providers; technology providers; cloud service providers; professional advisers; law enforcement authorities where required by law.
12. International Transfers
Where personal data is transferred outside the United Kingdom, we will ensure appropriate safeguards are implemented in accordance with applicable data protection legislation.
13. Data Security
We implement appropriate technical and organisational measures designed to protect personal data against unauthorised access, unauthorised disclosure, loss, alteration, destruction, and misuse.
Access to personal data is restricted to authorised personnel who require access for legitimate business purposes.
14. Data Retention
Personal data will be retained only for as long as necessary to fulfil the purposes for which it was collected, including satisfying legal, regulatory, tax, accounting, and reporting obligations.
Retention periods may vary depending upon the nature of the information and applicable legal requirements.
Retention Following Business Closure
Personal data may be retained beyond the closure of an Associated Business where required for legal, regulatory, tax, accounting, or continuity purposes.
Further information regarding retention periods may be requested from us.
15. Your Rights
Subject to applicable law, individuals may have the right to:
- access personal data;
- rectify inaccurate personal data;
- erase personal data;
- restrict processing;
- object to processing;
- data portability;
- withdraw consent; and
- lodge a complaint with a supervisory authority.
We may request proof of identity before responding to rights requests.
16. Automated Decision-Making
We do not ordinarily make decisions based solely on automated processing that produce legal or similarly significant effects. Should this change, we will provide appropriate information and safeguards.
17. Complaints
If you have concerns regarding our handling of personal data, we encourage you to contact us first. You also have the right to lodge a complaint with the Information Commissioner’s Office (ICO) at ico.org.uk.
18. Contact Details
Questions relating to this Privacy Notice or our processing of personal data may be directed to our Privacy Team using the contact details published on our website:
- Email: hello@clearsteprecruitment.com
- Phone: 0333 070 5906
19. Changes to this Privacy Notice
We may update this Privacy Notice from time to time to reflect legal, regulatory, operational, or business changes. The most current version will be made available through our website and other appropriate channels.