PRIVACY POLICY –
INSTANT IMPACT CANDIDATES

1. The information we hold about you

We will collect, store and use the following categories of personal data about you:

• Personal details such as name, title, gender, date of birth, marital / relationship status and dependants, work and home contact details (addresses, telephone numbers, and email addresses) and next of kin emergency contact information (“Personal Details”);
• Financial information such as remuneration, bonus benefits, profit share, equity shares and information on loans made and their repayment (“Financial Information”);
• Information related to benefits such as private healthcare and pensions (“Benefits Information”);
• Identification documents including passport details (“ID Information”);
• Professional information such as details of your experience, professional history, education history, qualifications, references, professional memberships and languages, (“Professional Information”);
• Work information such as job titles, description of current job, start dates, terms of employment or engagement, employment or engagement contract, location of workplace, flexible working arrangements, management responsibilities, work history, working days and hours, leave entitlement, absence records, disciplinary and grievance information,  continuing professional development information, experience, length of service, retirement eligibility, promotions, leaving date and reason for leaving and information about any professional conduct matters, allegations, complaints or professional criticism (“Work Information”);
• Recruitment information about your progress through the recruitment process, including jobs applied for, videos interviews, audio responses, text responses, interview notes, interview recordings, interview analysis, assessment participation and results, offers and counter-offers, and the outcome of the recruitment process (“Recruitment Information”);
• Information about your use of our information technology and communications systems and recruitment tools (“IT Use Information”);
• Communications, including via email and messaging, and any other information you decide to share during your engagement with Instant Impact (“Communications Information”);
• Results of background checks (“Background Checks Information”);
• Information on any personal services company you work through, and the results of any employment status checks carried out (“PSC Information”);
• Information on your marketing preferences and whether we send you marketing communications (“Marketing Preferences”).

We may also collect, store and use the following more sensitive types of personal data about you (known as “Special Category Data”): Information about your health; Information about your race or ethnicity; Information about your religious or philosophical beliefs; Information about your sexual orientation; Information about criminal convictions and offences.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes at any time.

2. How long will you keep my information for?

We will retain personal data relating to you for up to six (6) years (plus a further 12 months to allow for disposal or destruction) or (if longer) for as long as is necessary to fulfil any legal, professional regulatory, accounting or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means and the applicable legal requirements.

3. How is your personal data collected?

We collect personal data about you through the identification, application and recruitment process, either directly from you, or from third party sources including our clients, other recruitment businesses, job boards, reference providers or background check providers, or sometimes we collect information that is available in the public domain such as from professional or social media platforms (including LinkedIn).

If you do not provide certain information to us when requested, we may not be able to perform the contract we have entered into with you (such as providing our recruitment services to you).

4. How we use information about you

We will only process your personal data where we have a lawful basis to do so. The lawful basis will depend on the purposes for which we have collected and use your personal data. In almost every case, the lawful basis will be one of the following:

• Consent: This applies where you have given your consent to us processing your personal data.
• Performance of a contract with you: This applies where we process your personal data to fulfil the contract to provide services we have entered into with you (such as providing our recruitment services to you).
• Compliance with the law: This applies where we are subject to a legal obligation and need to use your personal data in order to comply with that obligation.
• Our legitimate business interests: This applies where we have a legitimate interest to use personal data regarding you in relation to the operation of our business.

We will only process your Special Category Data where we also have a lawful condition to do so. The lawful condition will depend on the purposes for which we have collected and use your personal data. In almost every case, the lawful condition will be one of the following:

• Employment or social security: This applies where the processing is necessary for the purposes of employment and social security and social protection law.
• Legal claims: This applies where the processing is necessary for the establishment, exercise or defence of legal claims.
• Substantial public interest: This applies where the processing is necessary for reasons of substantial public interest.

Please note that where you apply for a role with one of our clients, you may initially be allocated to that client’s talent pool and only considered for roles with that client. However, if your application to that client is unsuccessful, you will be moved into our general talent pool where you will be considered for roles with all our clients.

We will let you know when you are moved into our general talent pool, and you will have 7 days to opt out. If you do not opt out, we may contact you about roles with any of our clients that we believe are suitable for you. You can opt out of receiving communications from us at any time by emailing us at talent@instant-impact.com or by clicking the unsubscribe link on our communications.

5. Information about criminal convictions and offences

We envisage that we will hold information about criminal convictions and offences.

We will only collect information about criminal convictions and offences if it is appropriate given the nature of your actual or potential role and where we are legally able to do so.

6. Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another purpose and that purpose is compatible with the original purpose. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

7. Automated decision-making and AI

Automated decision-making

We use automated decision-making (a decision made solely by automated means without any human involvement) including profiling (automated processing of personal data to evaluate certain conditions about an individual) to assess whether your skills and experience are suitable for the role you applied for.

This automated decision-making is carried out by artificial intelligence (“AI”) powered tools, which are designed to increase the speed and accuracy of our decision-making.

We have implemented automated decision-making using AI to make the recruitment process more efficient for both you and our clients.

Your application will be analysed based on whether mandatory requirements are met as set out in the job advert and description as well as other criteria. If you are unsuccessful, you will receive a response detailing the reasons as per the analysis. Any successful candidates will be moved through the process as usual.

You have the right to speak to us and we may then review the decision, provide a more detailed explanation, and assess if the automated decision was made correctly. If you disagree with the outcome of the automated decision-making, you can ask us to review the decision.

Please use the details in section 12 below to contact us about any automated decision-making.

Chatbots

Instant Impact may enable chatbots and similar tools to allow you to complete certain tasks or functions, such as searching for jobs, uploading your CV or arranging interviews, without human involvement. We use the information you share with our chatbots to provide more personalised interactions with our chatbots so you receive more relevant information from them.

AI note takers

We also use AI powered tools during candidate interviews to record interviews, take notes and analyse interviews to help us and our clients make better hiring decisions.

Your right to object

If you object to the use of any of the tools referred to in this section 7, please let us know by contacting us using the details in section 12 below.

8. Data sharing

We may share your personal data with third parties where we deem it necessary to properly operate our business.

We may share your personal data with our clients as part of the recruitment process.

We may also share your personal data with our third-party service providers such as our IT service providers.

We require third parties to respect the security of your personal data and to treat it in accordance with the law.

We may transfer your personal data outside the UK. If we do, we will implement appropriate measures as required by the law designed to ensure your personal data receives a similar degree of protection as it would in the UK.

We will also share your personal data with third parties where required by law, for example with regulators, the Courts or the Police.

All our clients and third-party service providers are required to take appropriate security measures to protect your personal data in line with the law. Our service providers must only process your personal data for specified purposes and in accordance with our instructions.

We may also share your personal data in the context of the possible sale or restructuring of the Business. In this situation we will, so far as possible, share anonymised data with the other parties before the transaction completes. Once the transaction is completed, we will share your personal data with the other parties if and to the extent required under the terms of the transaction.

9. Data security

We have put in place security measures designed to prevent your personal data from being lost, used, accessed, altered or disclosed in an unauthorised way. In addition, we limit access to your personal data to those third parties who have a business need to access your personal data. Our service providers are required to only process your personal data on our instructions, and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any actual or suspected data security breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

10. Your rights

Under certain circumstances, by law you have the right to:

• Request access to your personal data, which enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it;
• Request correction of your personal data, which enables you to have any incomplete or inaccurate personal data we hold about you corrected;
• Request erasure of your personal data;
• Object to processing of your personal data, which enables you to ask us to stop processing your personal data;
• Request the restriction of processing of your personal data, which enables you to ask us to suspend the processing of personal data about you;
• Request the transfer of your personal data to another party.

If you exercise your data subject rights, please contact our Data Protection Responsible Person using the contact details below.

No fee usually required

You will not have to pay a fee to exercise any of your data subject rights. However, we may charge a reasonable fee in certain situations, such as if your request is manifestly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to exercise any of your data subject rights. This is another appropriate security measure to ensure that personal data is not disclosed to any person who has no right to receive it.

Right to withdraw consent

In the limited circumstances where you may have provided your consent to the processing of your personal data, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact our Data Protection Responsible Person using the contact details below. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.

11. Data Protection Responsible Person and other contact details

We have appointed a Data Protection Responsible Person to oversee compliance with this privacy policy. If you have any questions about this privacy policy or how we handle your personal data, or if you wish to exercise any of your data subject rights, please contact Amy Campbell, the Data Protection Responsible Person, at amy.campbell@instant-impact.com.

You have the right to make a complaint at any time to the ICO with respect to data protection issues.

The ICO’s address:

Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

Helpline number: 0303 123 1113
ICO website: https://www.ico.org.uk