Diverse Education/ Education Diverse LTD

1 BACKGROUND

Last updated: 11/07/2024
This policy tells you how Diverse Education look after your personal data when you register as a candidate with us in relation to our recruitment services. It sets out what information we collect about you, what we use it for and who we share it with. It also explains your rights and what to do if you have any concerns.

We may sometimes need to update this notice, to reflect any changes to the way we manage our dayto-day activities or to comply with new legal requirements. Please check back on this notice before you apply for a new role with us.

where we refer to 'Education Diverse Ltd', 'the company', 'Diverse Education', we or us we are referring to the company its self Education diverse ltd/Diverse Education.

2 WHO WE ARE AND OTHER IMPORTANT INFORMATION

We are EDUCATION DIVERSE LTD, registered in England and Wales with company number 14489406 with our registered address at C/O Universal Accountancy Ltd Kings House 202 Lower High Street, Watford, WD17 2EH

Diverse Education are the controller for your information (which means we decide what information
we collect and how it is used).

Education Diverse Ltd are registered as a controller with the Information Commissioner's Office (
ICO) under registered number : ZB643018

3 CONTACT DETAILS

3.1 If you have any questions about this privacy notice or the way that we use information, please get in touch using the following details:

4 THE INFORMATION WE COLLECT ABOUT YOU

At Diverse Education, We may collect the following types of personal date about you, Personal data means any information which does (or could be used to) identify a living person. We have grouped together the types of personal data that we collect and where we receive it from below:

  • Identity Data: name, title, date of birth, job title, gender, emergency contact name and their relationship to you, passport, driving licence.
  • Contact Data: personal email address, telephone numbers, home address.
  • Recruitment Data: copies of right to work documents, interview notes, information you provided in your CV or cover letter as part of the registration or wider recruitment process.
  • Employment and Qualification Data: current and/or previous job titles, work history, working hours, training records, professional memberships.
  • Feedback: information and responses you provide when completing surveys and questionnaires.
  • Photo and Image Data: profile picture, images, videos and audio (e.g. video calls), CCTV footage
  • Special Category Data: information about your racial or ethnic origin, political opinions, religious or philosophical beliefs, sexual orientation, trade union membership and/or information about criminal convictions and offences

We may also collect, store and use personal data, where you have provided this to us, in respect of third parties, such as spouses, civil partners or dependants. If you do so you are responsible for and confirm you are entitled to provide us with this information and that you have informed those third parties of our identity and the purposes for which their personal data will be processed. You should draw their attention to this Privacy Notice. We will not use information except for the purpose for which you have provided it.

5 HOW WE USE YOUR INFORMATION

We are required to identify a legal justification (also known as a lawful basis) for collecting and using your personal data. There are six legal justifications which organisations can rely on. The most relevant of these to us are where we use your personal data to:

  • to enter into and perform our contract with you (if we provide you with recruitment services);
  • comply with a legal obligation that we have;
  • pursue our legitimate interests (our justifiable business aims) but only if those interests are not outweighed by your other rights and freedoms (e.g. your right to privacy);
  • (in very rare circumstances) to protect yours or another person's vital interests (e.g. disclose medical information to an attending paramedic, inform your nominated emergency contact); and
  • do something that you have given your consent for.

Below is set out the lawful basis we rely on when we use your personal data. If we intend to use your personal data for a new reason that is not listed below, we will update our privacy notice and notify you.

Contract

  • To enter into a contract with you (for example, in relation to the provision of recruitment services to you).

Legal Obligation

  • Complying with our legal obligations as a recruitment business during the recruitment process.

Legitimate Interests

  • To review your CV information, and any information you provide during the recruitment process to ascertain your suitability for roles.
  • To operate CCTV or other security systems at our premises to ensure the security of our staff and property.
  • To deal with any disputes that arise.

Vital Interests

  • To use your personal data in an emergency to ensure your wellbeing or the wellbeing of another person.

Consent

  • Where we ask you to provide diversity information.
  • Where we have otherwise asked you to provide your consent.

Where we use personal data about you that is very sensitive (Special Category Data), we may require a second legal reason to use your personal data. This is most likely to occur where:
a) you have provided your express consent for us to do so; or
b) the processing is justified under UK law and the law allows us to use your data for a particular purpose.

6 WHO WE SHARE YOUR INFORMATION WITH

Diverse Education share (or may share) your personal data with:

  • Our personnel: our employees (or other types of workers) who have contracts containing confidentiality and data protection obligations.
  • Potential employers: so that the potential employer can assess your suitability for job roles. We always have a contract in place with other organisations containing confidentiality and data protection obligations.
  • Our suppliers: other organisations help us manage our infrastructure. We ensure these organisations only have access to the information required to provide the support we engage them for and have a contract with them that contains confidentiality and data protection obligations.
  • Regulatory authorities: such as HM Revenue & Customs.
  • Our professional advisers: such as our accountants or legal advisors where we require specialist advice to help us conduct our business.
  • Any actual or potential buyer of the business.
  • Third Party Companies - This relates to IT consultants who perform functions on our behalf to carry out developmental work on our business technology systems. We also share data with companies used by both the company and yourself such as Payroll who we will provide your personal data to including but not limited to; full name, contact details, date of birth and job title. For the purpose to ensure and process payment for hours worked.
  • Law Enforcement - we may also release personal information to regulatory or law enforcement agencies, if they require us to do so. We will also disclose your information where we are permitted and requested to do so by law

7 WHERE YOUR INFORMATION IS LOCATED OR TRANSFERRED TO

We store your personal data on our servers in the UK.

We will only transfer information outside of the UK or EEA where we have a valid legal mechanism in place (to make sure that your personal data is guaranteed a level of protection, regardless of where in the world it is located, e.g. by using contracts approved by the ICO).

If you access our systems whilst abroad then your personal data may be stored on services located in that country.

8 HOW WE KEEP YOUR INFORMATION SAFE

Diverse education have implemented security measures to prevent your personal data from being accidentally or illegally lost, used or accessed by those who do not have permission. These measures include:

  • access controls and user authentication (including multi-factor authentication)
  • internal IT and network security
  • regular testing and review of our security measures
  • staff policies and training
  • incident and breach reporting processes
  • business continuity and disaster recovery processes

If there is an incident which has affected your personal data and we are the controller, we will notify the regulator and keep you informed (where required under data protection law).

9 HOW LONG WE KEEP YOUR INFORMATION

Where Education diverse ltd are responsible for making decisions about how to collect and use your personal data, we will only keep your personal data for as long as necessary to fulfil the purposes we collected it for or as long as required to fulfil our legal obligations.

When we consider how long to keep your personal data, we will consider whether it is still necessary to keep it for the purpose which we collected it or whether the same purpose could be achieved by holding less personal data. We will also consider the volume, nature, and sensitivity of the personal data and the potential harm to you if there was an incident affecting your personal data.

In the event that you are offered employment through Diverse Education, Way may store your Data for a longer time period due to requirements made by HMRC, this may include but not limited to Payroll, Holiday pay, Sick pay, pension and any other auto enrolments services. We may keep your records for up to 6 years after your working relationship ends with the company.

10 YOUR LEGAL RIGHTS

You have specific legal rights in relation to your personal data. These are as follows:

  • Access: You must be told if your personal data is being used and you can ask for a copy of your personal data as well as information about how we are using it to make sure we are abiding by the law.
  • Correction: You can ask us to correct your personal data if it is inaccurate or incomplete. We might need to verify the new information before we make any changes.
  • Deletion: You can ask us to delete or remove your personal data if there is no good reason for us to continue holding it or if you have asked us to stop using it (see below). If we think there is a good reason to keep the information you have asked us to delete (e.g. to comply with regulatory requirements), we will let you know and explain our decision.
  • Restriction: You can ask us to restrict how we use your personal data and temporarily limit the way we use it (e.g. whilst we check that the personal data we hold for you is correct).
  • Objection: You can object to us using your personal data if you want us to stop using it. We always comply with your request if you ask us to stop sending you marketing communications. In other cases, if we think there is a good reason for us to keep using the information, we will let you know and explain our decision.
  • Portability: You can ask us to send you or another organisation an electronic copy of your personal data.
  • Complaints: If you are unhappy with the way we collect and use your personal data, you can complain to the ICO or another relevant supervisory body, but we hope that we can respond to your concerns before it reaches that stage. You should speak to back office management at admin@diverse-education.com in the first instance. If you wish to raise concerns with the ICO directly you can contact them with the following details - Information Commissioner's Office - 0303 123 1113 or at https://ico.org.uk/concerns/ opening hours mon - fri 9am - 5pm (excluding bank holidays)

If you would like to exercise any of your legal rights, please contact: Admin@diverse-education.com