Privacy Policy
Oxbow Resourcing Limited, is registered in England and Wales under company number 14667021. The registered office is at 14a The High Street, Malmesbury, Wiltshire, SN16 9AU, UK
1. What is the purpose of this document?
1.1 We are committed to protecting and respecting your privacy. This privacy notice sets out the basis on which any personal data we collect about you or that is provided to us by our recruitment consultants, will be processed by us.
1.2 This privacy notice applies to: prospective or placed candidates, prospective and live client contacts, supplier contacts who provide business support services, employees, consultants, temporary workers, any other recipients of our services and enquirers who make contact with us via the "contact us" form or contact details made available on our website (you).
1.3 We are a data controller. This means that we are responsible for deciding how we hold and use personal information about you, and for explaining this clearly to you.
1.4 Where we obtain personal information, Oxbow Resourcing are responsible for deciding how we hold and use personal information about you, and for explaining this clearly to you.
1.5 Please read this privacy notice carefully to understand what we do with your personal information and what rights you have in relation to our activities.
2. What is personal data and our lawful basis for processing?
2.1 Personal data, or personal information, means any information relating to an individual from which that person can be identified. There are special categories of more sensitive personal information which require a higher level of protection (see further at section 4, below).
2.2 We will only use your personal information when the law allows us to. Our principle lawful basis for processing is set out in the table below. However, some of our grounds for processing will overlap and there may be several grounds which justify our use of your personal information
2.3 We may only rely on our legitimate interests (or those of a third party) to process your personal information if your interests and fundamental rights do not override those interests. Where we rely on legitimate interests for our processing, we have set out the relevant interest, below.
2.4 We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
2.5 Please note that we may process your personal information without your knowledge or consent where this is required or permitted by law.
3. Information we collect from you and how our use complies with the law
3.1 Information we collect from you
3.1.1 From prospective and placed candidates we collect your name and contact details, including telephone number, private and corporate email address, financial information and references verifying your qualifications and experience, your right to work in the United Kingdom, curriculum vitae and photograph, links to your professional profiles available in the public domain e.g. LinkedIn, Facebook or a corporate website.
(a) How we use your information
(i) To provide our services to you.
(ii) To add you to our database.
(iii) To contact you about potential vacancies.
(b) How our use complies with the law
(i) This information is necessary to enter and perform the contract between us and the client.
(ii) For the legitimate interest of providing our services to you and promoting our business, provided that you have not asked us to take you off our contact list.
3.1.2 From clients and prospective clients, we collect the name, job title and business contact information of your individual employees and other representatives.
(a) How we use your information
(i) To provide our services to you.
(ii) We add this information to our contacts database to manage our relationship with you.
(iii) To provide you with details of potential candidates.
(b) How our use complies with the law
(i) This information is necessary to enter and perform the contract between us and the client.
(ii) For the legitimate interest of providing our services to you and promoting our business, provided that you have not asked us to take you off our contact list.
3.1.3 From suppliers and prospective suppliers of services to our business, we collect the name, job title and business contact information of your individual employees and other representatives.
(a) How we use your information
(i) To receive your services.
(ii) We add this information to our contacts database to manage our relationship with you.
(iii) To provide you with information about our business.
(b) How our use complies with the law
(i) This information is necessary to enter and perform the contract between us and our supplier.
(ii) For the legitimate interest of promoting our business, provided that you have not asked us to take you off our contact list.
3.1.4 If you contact with us, we collect your name, email, organisation name, address, contents of any messages you send us.
(a) How we use your information
To enable us to respond to your queries.
(b) How our use complies with the law
For our legitimate interest of managing and improving our business.
3.1.5 We use the business contact information provided for individual employees and other representatives of our clients and suppliers (including prospective clients and suppliers) to provide updates and information about our services.
(a) How we use your information
We only send direct marketing by e-mail to corporate addresses if the individual has not opted out of receiving marketing from us.
(b) How our use complies with the law
Such processing is necessary for the legitimate interest of promoting our business.
3.1.6 We collect background information relating to our past dealings with you.
(a) How we use your information
To inform and improve our service.
(b) How our use complies with the law
For the legitimate interest of informing and improving the service we provide to you.
3.2 Information we collect from other sources.
3.2.1 We may collect background information from publicly available sources, including social media sites, such as LinkedIn, Facebook, twitter as well as corporate websites, job board websites, online CV libraries, your business card, or personal recommendations.
(a) How we use your information
To provide our services to you, manage our relationship with you and to add you to our candidate database.
(b) How our use complies with the law
For the legitimate interest of managing our business, and where this comprises special category information, only where you have made this public, unless required by law.
3.2.2 We may perform due diligence in the form of credit checks on companies, including checking photographic identification and proof of address of directors and, in some cases, your shareholders, and verifying their identity using publicly available sources, such as Companies House.
(a) How we use your information
For the purposes of fraud protection and credit risk reduction and to maintain the reputation of our business.
(b) How our use complies with the law
Such processing is necessary for the legitimate interest of protecting our business.
3.3 Information we collect when you visit our website.
Apart from any information you might provide to us via our Contact page, we do not collect any personal data from you when you visit our website. We do use cookies through your browser on your computer or device.
4. Special Category Data
4.1 We do not process particularly sensitive personal information as part of our usual course of business. However, we may process information:
4.1.1 relating to a health condition or disability in order to meet our legal obligation to make reasonable adjustments in the provision of our services.
4.1.2 where it is needed to protect your interests (or someone else's interests) and you are not capable of giving your consent (for example, in a medical emergency);
4.1.3 where it is necessary to establish, exercise or defend a legal claim;
4.1.4 where you have manifestly made the information public; or
4.1.5 otherwise with your explicit consent.
5. Sharing your information
5.1 We share your personal information with third party contractors and service providers to the extent necessary to provide our services to you.
5.2 We share your information with other third parties as follows:
5.2.1 our regulators, professional advisors, auditors and insurance provider;
5.2.2 HMRC or other government or law enforcement agencies;
5.2.3 Associates of Oxbow Resourcing Ltd for the purpose of providing services to candidates and clients;
5.2.4 if we sell any business or assets, in which case we may disclose your personal information to the prospective buyer of such business or assets; or
5.2.5 if we have a legal obligation to do so.
5.3 If you object to our sharing or continuing to use your personal data with any specific third party please contact us at katie@oxbowresourcing.com
5.4 We use third-party service providers, such as our website host server, IT support and maintenance service, cloud storage provider and email exchange server. All of our third-party service providers are required to take appropriate security measures to protect your personal information in line with our policies. We do not allow our third-party service providers to use your personal data for their own purposes.
6. Data security
6.1 We have put in place:
(a) Appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.
(b) Procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.
6.2 Any personal information that you submit to us will be held on secure servers, that may be based within the European Economic Area (EEA) or outside the EEA.
6.3 If we are required to transfer your information outside the EEA, we have put in place the appropriate measures to ensure that your personal information is treated by those third parties in a way that is consistent with, and which respects the EU and UK laws on data protection.
6.4 If you are based outside the EEA we may transfer personal information to the correspondence address you provide to us. We will take all reasonable steps to ensure that such transfers are secure. By instructing us from outside the EEA you acknowledge and agree that such transfers are necessary for us to provide services to you.
7. How long will we keep your personal information for?
7.1 We will only keep your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting or reporting requirements in line with our Data Retention Policy.
7.2 Where a minimum retention period is required by law (such as retaining records for HMRC purposes) we comply with that minimum period plus up to 12 months to allow time for us to anonymise or delete information in accordance with our internal data management processes.
8. Your rights
8.1 You have the following rights:
8.1.1 to be told what we are doing with your personal information. We do this by providing you with this privacy notice;
8.1.2 to correct or update the personal information we hold about you.
8.1.3 to object to the processing of your personal information;
8.1.4 to request a copy of the personal information we hold about you;
8.1.5 to ask us to delete the information that we hold about you where there is no good reason for us continuing to process it;
8.1.6 to ask us to stop processing your personal information where we are relying on a legitimate interest and there is something about your particular situation which makes you want to object to processing on this ground and where there is no good reason for us continuing to process it;
8.1.7 to ask us to restrict how we use your personal information for a period of time if you claim that it is inaccurate, and we want to verify the position or in some limited other circumstances;
8.1.8 to ask us to send your personal information to another organisation in a computer-readable format;
8.1.9 to complain to the Information Commissioner's office if you are unhappy with our use of your personal data: you can do this at https://ico.org.uk/concerns/ . Do contact us straight away if you consider that we are not handling your personal information properly so we can try and sort the problem out.
8.2 If we delete your personal information or restrict our use of it, we will not be able to provide our services to you.
8.3 If you want to exercise any of your rights, please contact katie@oxbowresourcing.com. We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights).
Last Updated 27th March 2023
