Introduction

We are committed to safeguarding your data privacy rights and your personal information which is protected by the Data Protection (Jersey) Law 2018. This Privacy Policy explains how we collect, use and process your personal data, whether we are in the process of helping you find a job, continuing our relationship with you once you have found a role, providing you with a service, receiving a service from you, using your data to ask for your assistance in relation to one of our candidates, or you are visiting our website.

This Privacy Policy applies to the personal data of our Candidates, Clients, Suppliers, Website Users, and other people whom we may contact in order to find out more about our Candidates or whom they indicate is an emergency contact. It also applies to the emergency contacts of our Employees.

If we decide to change our Privacy Policy, we will post those changes on this page. Policy changes will apply only to information collected after the date of the change.
We welcome your questions, comments, and concerns about privacy. Please send us any and all feedback pertaining to privacy, or any other issue.

This policy is written to outline personal data management for the 5 different categories of users:

1. Candidate Data
2. Client Data
3. Supplier Data
4. People whose data we receive from candidates and employees such as referees and emergency contacts
5. Website Users

Several elements of personal data we collect from you are required to enable us to fulfil our contractual duties to you or to others. 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, in extreme cases, may not be able to continue with our relationship.

Candidate Data

What kind of personal data do we collect?

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 for the purpose of recruitment and selection. The information described below is, of course, in addition to any personal data we are required by law to process in any given situation.

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.
 
-  Name;
-  Contact details;
-  Age/date of birth;
-  Marital status;
-  Education details;
-  Employment history;
-  Nationality/citizenship/place of birth;
-  Immigration status / Eligibility to work;
-  Details about your current remuneration, pensions and benefits arrangements;
-  Information on your interests and needs regarding future employment, both collected directly and inferred;
-  Referee details;
-  Financial information (where we need to carry out financial background checks);
-  Emergency contacts;
-  A copy of your driving licence and/or passport/identity card;
-  A copy of a utility bills;
-  Social security number and any other tax-related information;
-  Extra information that you choose to tell us (should you share any health or wellbeing details and/or criminal
   convictions, a note may be made however, details won’t be shared unless we have your explicit consent);
-  Extra information that your referees choose to tell us about you;
-  The dates, times and frequency with which you access our services;
-  Jobs applied for and placement details (salary, name, title, company); and
-  Service notes and comments

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

How do we collect it?

Optimus Limited needs to know certain information about you in order to provide a tailored recruitment and selection service. This will enable us to provide you with the best opportunities.
There are three main ways in which we collect your personal data:

1. Personal data that you, the candidate has provided to us
-  Face to face or telecommunications discussion;
-  Providing hard copy of documents;
-  Email;
-  Online registration; and
-  LinkedIn profile.
 
2. Personal data that we receive from other sources
-  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
-  If you 'like' our page on Facebook or 'follow' us on Twitter we will receive your personal information from those sites.
 
3. Personal data that 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.
    Refer to Website Users for more information.

How do we use your personal 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. We generally use Candidate data in the following ways:

1. Recruitment Activities
Obviously, our main area of work is recruitment – connecting the right Candidates with the right roles. 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; 
-  Allowing you to participate in the interactive features of our services, when you choose to do so;
-  Carrying out our obligations arising from any contracts entered into between us;
-  Carrying out our obligations arising from any contracts entered into between Optimus Limited and third parties in
   relation to your recruitment;
-  Facilitating our payroll and invoicing processes;
-  Carrying out customer satisfaction surveys;
-  Complying with our legal obligations in connection with the detection of crime; 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.
 
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 (permanent, temporary, contract, outplacement services) to you;
-  Send you details of reports, promotions, offers, networking and client events, and general information about the
   industry sectors which we think might be of interest to you; and
-  Display promotional excerpts from your details on the Optimus' website or social media pages as a success story
   (only where we have obtained your express consent to do so).

We need your consent for some aspects of these activities which are not covered by our legitimate interests (in particular, 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 further below).

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.

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. If you have chosen to opt out, there may be times 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, we apologise and simply ask that in those circumstances you opt out again.

3. To help us establish, exercise or defend legal claims
In more unusual circumstances, we may use your personal data to help us to establish, exercise or defend legal claims.

Who do we share your personal data with?

Primarily we will share your information with prospective employers to increase your chances of securing the job you want. Personal data may be shared with the following sources:

-  Potential employers to increase your chances of finding employment. Please refer directly to company websites
   for privacy details in relation to how potential employers manage candidate applications and personal data during
   the recruitment process;
-  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 local authority or in connection with any anticipated litigation);
-  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;
-  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;
-  Potential employers and other agencies/organisations to increase your chances of finding employment; and
-  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; and
-  If Optimus Limited 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.

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.

How long do we keep your data for?

If we have not had meaningful contact with you for a period of three years, we will either ask you to reconsent holding your data or 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 local 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), or where you are actively engaging with us and using our services. We will consider there to be meaningful contact with you if you submit your updated CV, communicate with us about potential roles, either by verbal or written communication or click through from any of our marketing communications. Your receipt, opening or reading of an email or other digital message from us will not count as meaningful contact – this will only occur in cases where you click-through or reply directly.

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

Even if we already hold your personal data, you still have various rights in relation to it. 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.

Rights:
-  Right of access;
-  Right to rectification;
-  Right to erasure (to be forgotten);
-  Right to restriction of processing;
-  Right of data portability;
-  Right to object to processing; and
-  Right not to be to be subject to a decision based solely on automated processing.

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

How do we store and transfer your data internationally?

Optimus Limited may deal with international Clients. Personal data may be transferred or stored internationally by Optimus Limited or by our Clients or Suppliers.

For more information on the steps we take when we transfer and store your data internationally, please click here.

Who is responsible for processing your personal data?

Optimus Limited controls the processing of personal data. If you have any comments or suggestions concerning this Privacy Policy, please follow this link. We take privacy seriously, so we'll get back to you as soon as possible.

Client Data

What kind of personal data do we collect?

As a client of Optimus Limited, we need to collect and use information about you, or individuals at your organisation. Generally, this data is limited and we only need to have your contact details or the details of individual contacts at your organisation (such as names, telephone numbers and email addresses) to enable us to ensure a positive, professional relationship. 

We also hold information relating to job descriptions and details of vacancies and your engagement with candidates submitted and any extra information that someone in your organisation has chosen to tell us in the course of providing you services such as: (i) finding Candidates who meet your requirements; (ii) providing you Temporary, Contractual or Consultant services; and//or (iii) providing you with Outplacement services.

How do we collect it?

We collect Client data in the following ways:

1. Personal data that we receive directly from you
-  Where you contact us proactively, usually by phone or email; and/or
-  Where we contact you, either by phone or email.

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 your organisation from other sources including:
-  Your organisations’ website or job boards;
-  From delegate lists at relevant events; and
-  From a third party mentioning of a potential vacancy; 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).

How do we use your personal 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. We use client information for:

1. Recruitment Activities
Our main area of work is recruitment providing you with Candidates. 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; and
-  Processing your data for the purpose of targeting appropriate marketing campaigns.

2. Marketing Activities
We may periodically 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:

-  Send you details of reports, networking and events, and general information about the industry sectors which we
   think might be of interest to you; and
-  Display job descriptions on the Optimus Recruitment website.

3. To help us to establish, exercise or defend legal claims
In more unusual circumstances, we may use your personal data to help us to establish, exercise or defend legal claims.

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:

-  Potential candidates being considered for the job vacancy;
-  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 local 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; and
-  If Optimus Limited 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.

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.

How long do we keep your data for?

If we have not had meaningful contact with you for a period of three years, 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 local authorities or in connection with any anticipated litigation). After this period, it is unlikely your data will be relevant for the purpose for which it was collected.

When we refer to "meaningful contact", we mean, for example, communication between us (either verbal or written), or where you are actively engaging with us and using our services. We will consider there to be meaningful contact with you if you communicate with us about potential services, either by verbal or written communication. Your receipt, opening or reading of an email or other digital message from us will not count as meaningful contact – this will only occur in cases where you click-through or reply directly.

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

Even if we already hold your personal data, you still have various rights in relation to it. 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.

Rights:
-  Right of access;
-  Right to rectification;
-  Right to erasure (to be forgotten);
-  Right to restriction of processing;
-  Right of data portability;
-  Right to object to processing; and
-  Right not to be to be subject to a decision based solely on automated processing.

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

How do we store and transfer your data internationally?

Optimus Limited may deal with international Clients. Personal data may be transferred or stored internationally by Optimus Limited or by our Clients or Suppliers.

For more information on the steps we take when we transfer and store your data internationally, please click here.

Who is responsible for processing your personal data?

Optimus Limited controls the processing of personal data. If you have any comments or suggestions concerning this Privacy Policy, please follow this link. We take privacy seriously, so we'll get back to you as soon as possible.

Supplier Data

What kind of personal data do we collect?

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.

How do we collect it?

We collect your personal data during the course of our work with you.

How do we use your personal data?

The main reasons for using your personal data are to ensure that the contractual arrangements between us can properly be implemented and to comply with legal requirements. 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;
-  To offer services to you or to obtain support and services from you;
-  To perform certain legal obligations; and
-  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.

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.

Who do we share your personal data with?

Unless you specify otherwise, we may share your information within Optimus Limited and associated third parties such as our service providers and organisations to whom we provide services.

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.

How long do we keep your data for?

If we have not had meaningful contact with you for a period of three years, 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 local authorities or in connection with any anticipated litigation). After this period, it is unlikely your data will be relevant for the purpose for which it was collected.

When we refer to "meaningful contact", we mean, for example, communication between us (either verbal or written), or where you are actively engaging with us and using our services. We will consider there to be meaningful contact with you if you communicate with us about potential services, either by verbal or written communication. Your receipt, opening or reading of an email or other digital message from us will not count as meaningful contact – this will only occur in cases where you click-through or reply directly.

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

Even if we already hold your personal data, you still have various rights in relation to it. 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.

Rights:
-  Right of access;
-  Right to rectification;
-  Right to erasure (to be forgotten);
-  Right to restriction of processing;
-  Right of data portability;
-  Right to object to processing; and
-  Right not to be to be subject to a decision based solely on automated processing.

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

How do we store and transfer your data internationally?

Optimus Limited may deal with international Clients. Personal data may be transferred or stored internationally by Optimus Limited or by our Clients or Suppliers.

For more information on the steps we take when we transfer and store your data internationally, please click here.

Who is responsible for processing your personal data?

Optimus Limited controls the processing of personal data. If you have any comments or suggestions concerning this Privacy Policy, please follow this link. We take privacy seriously, so we'll get back to you as soon as possible.

People whose data we receive from candidates and employees, such as referees and emergency contacts

What kind of personal data do we collect?

In order to provide candidates with suitable employment opportunities safely and securely, we may need some basic background information. All we need from referees is confirmation of what you already know about our candidate or employee, so that they may secure new employment. 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 candidate or employee has put you down as their emergency contact so that we can contact you in the event of an accident or an emergency.

How do we collect it?

We collect your contact details only where a candidate/employee puts you down as their emergency contact or where a candidate gives them to us in order for you to serve as a referee.

How do we use your personal data?

We will only use the information that our Candidate gives us about you for the following purposes:

-  If our Candidates/Employee members put you down on our form as an emergency contact, we'll contact you
   in the case of an accident or emergency affecting them; or
-  If you were put down by our Candidate or a prospective Employee as a referee, we will contact you in order
   to take up a reference. This is an important part of our Candidate quality assurance process and could be the
   difference between the individual getting a job or not.

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.

Who do we share your personal data with?

Unless you specify otherwise, we may share your information within Optimus Limited and associated third parties such as our service providers and organisations to whom we provide services.

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.

How long do we keep your data for?

If we have not had meaningful contact with the Candidate or Employee whom your details are related to for a period of three years, 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 local authorities or in connection with any anticipated litigation). After this period, it is unlikely your data will be relevant for the purpose for which it was collected.

When we refer to "meaningful contact", we mean, for example, communication between us (either verbal or written), or where the Candidate is actively engaging with us, using our services or an Employee is employed by us.

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

Even if we already hold your personal data, you still have various rights in relation to it. 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.

Rights:
-  Right of access;
-  Right to rectification;
-  Right to erasure (to be forgotten);
-  Right to restriction of processing;
-  Right of data portability;
-  Right to object to processing; and
-  Right not to be to be subject to a decision based solely on automated processing.

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

How do we store and transfer your data internationally?

Optimus Limited may deal with international Clients. Personal data may be transferred or stored internationally by Optimus Limited or by our Clients or Suppliers.

For more information on the steps we take when we transfer and store your data internationally, please click here.

Who is responsible for processing your personal data?

Optimus Limited controls the processing of personal data. If you have any comments or suggestions concerning this Privacy Policy, please follow this link. We take privacy seriously, so we'll get back to you as soon as possible.

Website Users

What kind of personal data do we collect?

We collect a limited amount of data from our Website Users. This includes aggregate data from the information supplied by you to help us understand our users as a group so that we can provide you a better service and improve your experience when using our website.

How do we collect it?

We collect data from you when you contact us via the website, for example by using the online registration form and when you email us your details

How do we use your personal data?

We use your data to help us deal with your enquiries, help us to present you with information about job roles and services offered by Optimus Limited and carry out customer and marketing research. 

Who do we share your personal data with?

We may share aggregate information with selected third parties, without disclosing individual names or identity information.

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.

How long do we keep your data for?

We will process and retain any data you may provide when completing the online registration form or provided to us via email when using our recruitment services as a Candidate

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

Even if we already hold your personal data, you still have various rights in relation to it. 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.

Rights:
-  Right of access;
-  Right to rectification;
-  Right to erasure (to be forgotten);
-  Right to restriction of processing;
-  Right of data portability;
-  Right to object to processing; and
-  Right not to be to be subject to a decision based solely on automated processing.

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

How do we store and transfer your data internationally?

Optimus Limited may deal with international Clients. Personal data may be transferred or stored internationally by Optimus Limited or by our Clients or Suppliers.

For more information on the steps we take when we transfer and store your data internationally, please click here.

Who is responsible for processing your personal data?

Optimus Limited controls the processing of personal data. If you have any comments or suggestions concerning this Privacy Policy, please follow this link. We take privacy seriously, so we'll get back to you as soon as possible.


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

One of the GDPR's main objectives is to protect and clarify your rights 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.

Right of access: You may ask us to confirm what information we hold about you at any time. 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 vexatious, unfounded or excessive”. 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.

Right to rectification: You 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.

Right to erasure (to be forgotten): 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 is 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. in a manner which does not comply with the 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.

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.

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, or the protection of the rights of another individual.

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.

Right of data portability: If you wish, you have the right to receive and transfer your personal data between data controllers where technically feasible. 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.

Right to object to processing: 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 our Website Users, Candidates, Clients and Suppliers. 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.

Right not to be to be subject to a decision based solely on automated processing: We do not base any decisions solely on automated processing of your personal data, but if we did you would have the right to restrict our use of your data for this purpose.

You also have the right to lodge a complaint with your local 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.

If registered for newsletters or job alerts, you may ask to unsubscribe from job alerts at any time.

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.


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 Policy, your data may be transferred:

-  Within Optimus Limited;
-  To third parties (such as advisers or other Suppliers to the business);
-  To overseas Clients;
-  To Clients within Jersey who may, in turn, transfer your data internationally;
-  To a cloud-based storage provider
   a) Optimus Data storage is with a reputable UK based provider
   b) Traffic to and from the Optimus database, is encrypted using the HTTPS protocol
   c) The servers are dedicated (not shared) and are on a private network protected by its own private firewalls; and
-  To other third parties, as referred to here.

We want to make sure that your data is 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:

-  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 controller
   and processors in jurisdictions without adequate data protection laws; or
-  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
-  Where it is necessary for the conclusion or performance of a contract between ourselves and a third party and the
   transfers are in your interests for the purpose 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
-  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.


Our Legal Bases for processing your data – Legitimate Interests

Schedule 2, Article 9 (5)(1) of the Data Protection (Jersey) Law 2018 is the one that is relevant here – it says that we can process your data where it “is necessary for the purposes of legitimate interests pursued by the controller or by the third party or parties” unless the processing is unwarranted in any particular case by reason of prejudice to the rights and freedoms or legitimate interests of the data subject”.

We don't think that any of the following activities prejudice individuals in any way – in fact, they help us to offer you a more tailored, efficient service which is beneficial to both parties. However, you do have the right to object to us processing your personal data on this basis. 

We think it's reasonable to expect that if you are looking for employment or have provided your professional CV information on a job post 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 and assess your skills against our bank of vacancies.

We must 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.


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 11 of the Data Protection (Jersey) Law 2018 states that consent “means 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, whether orally or in writing, signifies agreement to the processing of that data”.

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 policy; 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.

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.


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. Schedule 1, Article 9 substituted (3)(c) of the Data Protection (Jersey) Law 2018, allows this where processing is necessary “for the establishment, exercise or defence of a legal claim or whenever a court is acting in its 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.


How to contact us

Optimus Limited, based in Jersey, Channel Islands controls the processing of personal data of Candidates, Clients, Suppliers, Website Users and the Emergency Contact and Referees of candidates.

Email gdpr@optimus.je to exercise any of the below rights:

-  To access, amend or take back the personal data that you have given to us;
-  If you suspect any misuse or loss of or unauthorised access to your personal information;
-  To withdraw your consent to the processing of your personal data (where consent is the legal basis on which we
   process your personal data);
-  With any complaints, comments or suggestions concerning this Privacy Policy;
-  To update your marketing preferences or profile, you can email us at: info@optimus.je or by clicking the unsubscribe
   link in any marketing e-mail we send to you.;
-  Write to us at: Optimus recruitment, First Floor, Commercial House Annex, Commercial Street, St Helier, Jersey, JE2 3RU.


How to contact your local data protection authority

You can contact the Office of the Information Commissioner in the following ways:

-  Phone: +44 (0)1534 716530
-  Email: enquiries@dataci.org
-  Post: Office of the Information Commissioner, Brunel House, Old Street, St Helier, Jersey JE2 3RG
-  Website: www.dataci.je

Glossary

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

Clients - This category covers our clients, and others to whom Optimus Limited provides services in the course of its business.

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.

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

Data Protection (Jersey) Law 2018 – Will be implemented 25 May 2018 and will replace the Data Protection (Jersey) Law 2005.

Other people whom Optimus Limited may contact – these may include Candidates' and Employees’ emergency contacts and referees. We will only contact them in appropriate circumstances.

Employee – includes employees engaged directly in the business of Optimus Limited (or who have accepted an offer to be engaged) as well as certain other workers engaged in the business of providing services to Optimus Limited (even though they are not classed as employees).

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

Website Users - any individual who accesses the Optimus recruitment website.

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Optimus Recruitment

First Floor, Commercial House Annex
Commercial Street, St Helier
Jersey, JE2 3RU

Tel:        01534 832660
Email:   info@optimus.je