Spinnaker Global Ltd and Spinnaker Global (Singapore) Pte Ltd (hereafter ‘Spinnaker’) need to gather and use certain information about individuals in order to deliver our services.
This Privacy Policy applies to all living persons whose data we hold in their capacity as private individuals and forms part of our efforts to ensure that we comply with data protection regulations and with our Data Protection Policy. How we handle personal data relating to individuals who are clients or prospective clients of Spinnaker is explained in our Client Data Processing and Sharing Policy and in our Legitimate Interest Assessment and Business to Business Marketing Policy.
We are subject to data protection regulations in multiple jurisdictions worldwide, including the relevant General Data Protection Regulations (GDPR).
This Privacy Policy explains how we use and protect your personal data if you are a private individual regardless of your nationality.
We reserve the right to revise or supplement this Privacy Policy from time to time at our sole discretion. The most up to date version is published online at spinnaker-global.com/privacy. You agree to review it regularly to ensure that you are familiar with the most current version.
General Provisions
By providing your personal data to us, you consent to the use, processing and transfer of your information on the terms set out in this Privacy Policy. If you do not agree to our processing of your data in the manner outlined below, please do not submit any personal data to us.
You may ask us at any time to delete your data by exercising your right to be forgotten.
Only our employees who need access to personal data to perform a specific job are granted access to your information and they are all aware of the importance of data privacy and security and of their and our obligations under data protection regulations.
To register with Spinnaker as a jobseeker and to apply for vacancies we are handling, you need to agree to our Work Seeker terms and conditions, which are published on our website spinnaker-global.com/work-seeker-terms. This Privacy Policy should be read in conjunction with those terms and conditions.
Spinnaker is committed to protecting the privacy of all users of our website but whilst we take what we believe are the usual prudent precautions to protect our users’ personal data and information, the use of the internet is not entirely secure and for this reason we cannot guarantee the security or integrity of any personal information which is transferred from you or to you via the internet.
Spinnaker uses cloud-computing services, customer relationship management software, recruitment database and CV management software. These are all provided by third party suppliers who may from time to time need access to Spinnaker’s systems and data in order to provide their services including maintenance, repairs and upgrades. Spinnaker ensures that such suppliers and their personnel are aware of their and our data protection obligations and that they are contractually obliged to take appropriate data protection precautions.
The information we collect
Spinnaker is governed by the Conduct of Employment Agencies and Employment Businesses Regulations 2003 (EAA) in the UK and by similar legislation in other jurisdictions.
We are required by the EAA to obtain confirmation of your identity, that you are legally entitled and willing to work in the location and position which the hiring company is seeking to fill and that you have the experience, training, qualifications and any authorisations which the hiring company considers necessary or are required by law or by any professional body.
Spinnaker will collect and store your personal data to enable us to comply with these obligations, which may include but is not limited to your name, contact details, career history, qualifications, evidence of nationality / entitlement to work, salary and benefits data and other relevant information, which may include sensitive personal information.
This is undertaken through:
- Our Website when you register with us and apply for vacancies;
- Written correspondence whether by email, text, letter or facsimile;
- Over the telephone; and
- When you authorise us to do so, contact with third parties such as referees.
We will contact you from time to time to ensure your registered information is up to date.
We may record, store or monitor any telephone calls you have with our employees for record keeping, training and quality control purposes
We may also need to take references and to verify your information via third parties such as examination boards, schools and colleges, former employers, etc. We will only do so having first notified you of our intention to do so and having obtained your authorisation.
What we use it for
Your personal data is held, used and disclosed by us in the conduct of our business to provide our services to you including the following:
Work finding services: In particular, this means registering you in our recruitment candidate database which we use to conduct job-matching searches for the vacancies on which we are instructed.
Should your data, typically your career history and qualifications, match job-matching searches, we may:
- Send you an email or other form of correspondence inviting you to express an interest in a vacancy or vacancies; or
- Manually review your CV and any additional relevant information you have given us to determine whether you are a close-enough match to our client’s requirements to warrant us making personal contact with you to invite you to express an interest in the vacancy.
Should you apply to us for a specific vacancy, whether in response to the above or having seen a vacancy advertised on our website or elsewhere, we will manually review your CV and any additional relevant information you have given us to determine whether you are a close-enough match to our client’s requirements to conduct a preliminary interview with you to enable us to reach a decision whether to shortlist you for the vacancy. In the event that we do so, we will seek your authorisation to submit your CV and other necessary personal data, including our opinion as to why you are suitable for the vacancy.
In addition to or instead of seeking your authorisation to submit you for specific vacancies, we may seek your authorisation to submit you to clients for other roles for which they consider you are suitable.
For further information on your obligations and our obligations when submitting you to clients, please see our Work Seeker terms and conditions.
Employment / Payroll services: In the event that we find you temporary, contract or interim employment or a contract for services, we will use your personal data to enable us to process payments to you or to facilitate payments to you by third parties and to account to the appropriate authorities, including, where necessary, the withholding of income tax and social security contributions.
Benchmarking services: We use anonymous aggregated pay data gathered from our clients and from work seekers to produce salary survey reports. We never disclose identifiable personal data to third parties.
We may contact you when carrying out research such as salary surveys.
News and Marketing: In addition to sending you emails or other correspondence to inform you of vacancies, we will send you our newsletters if you have opted in to receive them. To opt in, please visit our website. You may unsubscribe at any time by following the unsubscribe link on every edition.
Disclosure to authorities: We may release personal data where required to do so by regulatory or law enforcement agencies.
How long we will keep your data
Spinnaker will retain your personal data for as long as you ask us to do so. In practice this means that we will maintain your work seeker status as active until you ask us to make you inactive or to delete your data.
The nature of recruitment is that individuals’ wishes vary from making single job applications to registering with recruitment providers as passive work seekers to be kept informed for the longer term of suitable opportunities. Spinnaker has experience of placing work seekers who have been registered with us for over ten years.
We reserve the right to delete your personal data if in our opinion your experience and qualifications are not relevant for the types of vacancies which our clients ask us to fill.
What are your rights?
Should you no longer have any interest in our services, you have the right to ask us to delete your data and ‘to be forgotten’ at any time. We will undertake that task without delay.
You have the right to make a Subject Access Request at any time by writing to Spinnaker’s Data Protection Lead. Requests will be responded to as prescribed by GDPR.
If at any point you believe the information we process on you is incorrect you may request to see this information and have it corrected or deleted.
If you wish to raise a complaint on how we have handled your personal data, you can contact our Data Protection Lead who will investigate the matter.
Upon any contact with us, we reserve the right to require verification of your identity and to ask you to put your request in writing
Contacting us
Please submit any questions or concerns you have about this Privacy Policy or any requests concerning your personal data to our Data Protection Lead by email to [email protected]
Alternatively, please write to us at the following address:
Spinnaker Global Ltd
Cobat House
1446-1448 London Road
Leigh-on-Sea
Essex SS9 2UW
United Kingdom
