Legal Info

Privacy Policy

Company Name	Zebra People (‘the Company’)
Company Contact details	Zebra People Ltd, 6 Hoxton Square, London N1 6NU
Privacy Notice	Privacy Notice (when personal data is obtained from the data subject)
Topic	Data protection
Date	February 2023
Version	3

Collection and use of personal data
1. Purpose of processing and legal basis
2. Legitimate interest
3. Statutory/contractual requirement
4. Recipient(s) of data
Information to be provided when data is not collected directly from the data subject
1. Categories of data
2. Sources of data
Overseas transfers
Data retention
Your rights
Links to external sites
Mailchimp newsletters
Sale of the business
Data security
Changes to this privacy statement
Complaints or queries

1. Collection and use of personal data

a. Purpose of processing and legal basis

The Company will collect your personal data (which may include special categories of personal data) and will process your personal data for the purposes of providing you with work-finding services. This includes for example, contacting you about job opportunities, assessing your suitability for those opportunities, updating our databases, putting you forward for job opportunities, arranging payments to you and developing and managing our services and relationship with you and our clients.

On some occasions we may be required to use your data for the purpose of investigating, reporting and detecting crime and also to comply with laws that apply to us. We may also use your information during the course of internal audits to demonstrate our compliance with certain industry standards.

We must have a legal basis to process your personal data. The legal bases we rely upon to offer our work-finding services to you are:

Your consent
Where we have a legitimate interest
To comply with a legal obligation that we have
To fulfil a contractual obligation that we have with you

b. Legitimate interest

This is where the Company has a legitimate reason to process your data provided it is reasonable and does not go against what you would reasonably expect from us. Where the Company has relied on a legitimate interest to process your personal data our legitimate interests is/are as follows:

Managing our database and keeping work-seeker records up to date
Providing work-finding services to you and our clients
Contacting you to seek your consent where we need it

c. Statutory/contractual requirement

The Company has certain legal and contractual requirements to collect personal data (e.g. to comply with the Conduct of Employment Agencies and Employment Businesses Regulations 2003, immigration and tax legislation, and in some circumstances safeguarding requirements). Our clients may require this personal data, and we may need your data to enter into a contract with you. If you do not give us the personal data we need to collect In order to comply with our statutory and legal requirements, we may not be able to continue to provide work-finding services to you.

d. Recipient(s) of data

The Company will process your personal data and/or sensitive personal data with the following recipients:

Clients (who we may introduce or supply you to)
Your former employers who we may seek references from
Payroll service providers who manage payroll on our behalf or other payment intermediaries who we may introduce you to
Auditors who are assessing the compliance and processes of the business to ensure its adherence to all relevant legislation and good practice guidance.

2. Information to be provided when data is not collected directly from the data subject

a. Categories of data: The Company has collected the following personal data on you:

Personal data:

Name, address, mobile number, email
National insurance number
Nationality, Passport, DoB (through right to work check)

Special categories of personal data:

[Health information including whether you have a disability]
[Criminal conviction(s)]

b. Sources of data: The Company sourced your personal data/special categories of personal data:

LinkedIn
Cookies Click Here
CVs/Portfolios
Vetting

This information came from a publicly accessible source.

3. Overseas Transfers

The Company may transfer the information you provide to us to countries outside the UK and/or the European Economic Area (‘EEA’) for the purposes of providing you with work-finding services. We will take steps to ensure adequate protections are in place to ensure the security of your information. The EEA comprises the EU member states plus Norway, Iceland and Liechtenstein.

4. Data retention

The Company will retain your personal data only for as long as is necessary for the purpose we collect it. Different laws may also require us to keep different data for different periods of time. For example, the Conduct of Employment Agencies and Employment Businesses Regulations 2003, require us to keep work-seeker records for at least one year from (a) the date of their creation or (b) after the date on which we last provide you with work-finding services. We are required to keep your records relating to the right to work in the UK 2 years after employment or the engagement has ended alterable and working time records including your 48 hour opt out notice annual leave/holiday records 2 years from the time they were created.

Additionally, we must also keep your payroll records, holiday pay, sick pay and pensions auto-enrolment records for as long as is legally required by HMRC and associated national minimum wage, social security and tax legislation. This is currently 3 to 6 years.

5. Your rights

Please be aware that you have the following data protection rights:

The right to be informed about the personal data the Company processes on you
The right of access to the personal data the Company processes on you
The right to rectification of your personal data
The right to erasure of your personal data in certain circumstances
The right to restrict processing of your personal data
The right to data portability in certain circumstances
The right to object to the processing of your personal data that was based on a public or legitimate interest
The right not to be subjected to automated decision making and profiling
The right to withdraw consent at any time

Where you have consented to the Company processing your personal data and sensitive personal data, you have the right to withdraw that consent at any time by contacting Carly Price, Zebra People’s data protection officer. Please note that if you withdraw your consent to further processing that does not affect any processing done prior to the withdrawal of that consent, or which is done according to another legal basis.

There may be circumstances where the Company will still need to process your data for legal or official reasons. Where this is the case, we will tell you and we will restrict the data to only what is necessary for those specific reasons.

If you believe that any of your data that the Company processes is incorrect or incomplete, please contact us using the details above and we will take reasonable steps to check its accuracy and correct it where necessary.

You can also contact us using the above details if you want us to restrict the type or amount of data we process for you, access your personal data or exercise any of the other rights listed above.

6. Links to external websites

The Company’s website may contain links to other external websites. Please be aware that the Company is not responsible for the privacy practices of such other sites. When you leave our site we encourage you to read the privacy statements of each and every website that collects personally identifiable information. This privacy statement applies solely to information collected by the Company’s website.

7. Mailchimp newsletters

We use the Mailchimp platform to send news and updates to you if you have requested to receive these. This involves us sharing your email address with the platform provider, Intuit, as a data processor.

Intuit also collects some personal data via the Mailchimp platform as a data controller in their own right. For example, technical information about your device. For more information, you can read Mailchimp’s cookie statement and the Intuit privacy statement.

The legal basis for processing this data is that it’s necessary:

you have opted-in to receive ‘Industry news and insights’

We will not:

sell or rent your data to third parties
share your data with third parties for marketing purposes
We will share your data if we are required to do so by law – for example, by court order, or to prevent fraud or other crime.

8. Sale of business

If the Company’s business is sold or integrated with another business your details may be disclosed to our advisers and any prospective purchasers and their advisers and will be passed on to the new owners of the business. Where the sale of the business results in the transfer of your details to a different data controller we will notify you of this.

9. Data Security

The Company takes every precaution to protect users’ information. The Company is regulated with the ICO www.ico.org.uk and is compliant with Cyber Essentials protocols.

Only employees who need the information to perform a specific job (for example, consultants, our accounts clerk or a marketing assistant) are granted access to your information.

The Company uses all reasonable efforts to safeguard your personal information. However, you should be aware that the use of email/ the Internet is not entirely secure and for this reason the Company cannot guarantee the security or integrity of any personal information which is transferred from you or to you via email/the Internet.

If you share a device with others, we recommend that you do not select the “remember my details” function when that option is offered.

If you have any questions about the security on our website, you can email hq@zebrapeople.com

10. Changes to this privacy statement

We will update this privacy statement from time to time. We will post any changes on the statement with revision dates. If we make any material changes, we will notify you.

11. Complaints or queries

If you wish to complain about this privacy notice or any of the procedures set out in it please contact: Carly Price, Zebra Peoples Data Protection Officer at compliance@zebrapeople.com

You also have the right to raise concerns with the Information Commissioner’s Office on T: 0303 123 1113 or, or any other relevant authority should your personal data be processed outside of the UK and you believe that your data protection rights have not been adhered to.