Privacy Policy

1. Scope

All data subjects whose personal data is collected, in line with the requirements of the GDPR.

2. Responsibilities

2.1 The GDPR Owner is responsible for ensuring that this notice is made available to data subjects prior to Human Capital collecting/processing their personal data.

2.2 All Employees/Staff of Human Capital who interact with data subjects are responsible for ensuring that this notice is drawn to the data subject’s attention and their consent to the processing of their data is secured.

3. Privacy notice

3.1 Who are we?

We are a global recruitment firm Identifying and recruiting business-critical talent for organisations involved in the energy, agriculture and metal supply chains.

Our GDPR Owner and data protection representatives can be contacted directly here:

Anna Swahn
aswahn@humancapital.global

The personal data we would like to collect on you is:

Personal data type: Source

Name: Publicly available profiles: directly given

Address: Publicly available profiles, directly given

Contact details: Publicly available profiles, directly given

Qualifications: Publicly available profiles, directly given

Career history: Publicly available profiles, directly given

References: Publicly available profiles, directly given

The personal data we collect will be used for the following purposes:

  • Placement and recruiting
  • Affinity assessment for suitable placements

Our legal basis for processing for the personal data:

  • Contractual obligations
  • Processing on basis of data being manifestly made publicly available
  • Consent based processing

Any legitimate interests pursued by us, or third parties we use, are as follows:

  • Government mandated release of information
  • Interests perused by public authorities

Human Capital does not process any special categories of data specified under the GDPR which includes religion, health and trade union membership amongst others specified.

3.2 Consent

By consenting to this privacy notice you are giving us permission to process your personal data specifically for the purposes identified.
Consent is required for Human Capital to process both types of personal data, but it must be explicitly given. Where we are asking you for sensitive personal data we will always tell you why and how the information will be used.

You may withdraw consent at any time by contacting the organisation GDPR owner and submitting a subject access rights request form.

3.3 Disclosure

Human Capital will not pass on your personal data to third parties without obtaining your consent or doing so under legitimate interests under legislation.

3.4 Retention period

Human Capital will process personal data for an indefinite period as needed to conduct placements. Where it is clear that personal data is no longer needed as there is no longer potential to place that data will be deleted under the retention of data policy.

3.5 Your rights as a data subject

  • At any point while we are in possession of or processing your personal data, you, the data subject, have the following rights:
  • Right of access – you have the right to request a copy of the information that we hold about you.
  • Right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete.
  • Right to be forgotten – in certain circumstances you can ask for the data we hold about you to be erased from our records.
  • Right to restriction of processing – where certain conditions apply to have a right to restrict the processing.
  • Right of portability – you have the right to have the data we hold about you transferred to another organisation.
  • Right to object – you have the right to object to certain types of processing such as direct marketing.
  • Right to object to automated processing, including profiling – you also have the right to be subject to the legal effects of automated processing or profiling.
  • Right to judicial review: in the event that Human Capital refuses your request under rights of access, we will provide you with a reason as to why. You have the right to complain as outlined in clause 3.6 below.

All of the above requests will be forwarded on should there be a third party involved (as stated in 3.4 above) in the processing of your personal data.

3.6 Complaints

In the event that you wish to make a complaint about how your personal data is being processed by Human Capital (or third parties as described in 3.4 above), or how your complaint has been handled, you have the right to lodge a complaint directly with the supervisory authority and Human Capital’s data protection representatives GDPR Owner.

Data subject access requests are to be sent to the GDPR owner.

The details for each of these contacts are:

Supervisory authority contact details

Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

+44 303 123 1113

GDPR Owner contact details

Anna Swahn
aswahn@humancapital.global

Document Owner and Approval

The GDPR Owner is the owner of this document and is responsible for ensuring that this policy document is reviewed in line with the review requirements stated above.

A current version of this document is available to all members of staff in the company documentation

This policy was approved by the Board of Directors and is issued on a version controlled basis under the signature of the Chief Executive Officer (CEO).

Change History Record

Created: 18th May 2018