1. Scope

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

  1. Responsibilities


  1. The Data Protection Officer / GDPR Representative is responsible for ensuring that this notice is made available to data subjects prior to Keystone Employment Group collecting/processing their personal data.

  2. All Employees/Staff of Keystone Employment Group 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.


  1. Privacy Notice


  1. About Us

DirectTemping.com and all brand derivatives are operated by Keystone Employment Group No.1 Limited. Keystone Employment Group is registered with the Information Commissioners Office, Registration No: Z5721807

Our Data Protection Officer / GDPR Representative and data protection representatives can be contacted directly here: dpo@keystonetalentbank.com


3.1.2 The types of personal data we collect and use


The personal data we collect from/process on candidates/workers is summarized below:



Type of information held

How this information is used

Name

To enable managers and administrators of the service to identify you and ensure work and payment details are accurate and properly relate to you

Address

To ensure compliance with legislation, regulations and organisational policy around the employment of workers and to enable managers and administrators

Age

To establish compliance with employment law and rates of pay and ensure appropriate handling of work assignments and duties

Date of Birth

To establish compliance with employment law and rates of pay and ensure appropriate handling of work assignments and duties

Availability to work

To enable managers and administrators to establish your availability to undertake work assignments

Eligibility to work in the UK

To establish your legal right to work in the UK and compliance with the requirements of legislation and the work to be undertaken

Your employment status

To establish your current status as an employee, contractor or worker in order to ensure compliance with legislation and suitability to the work proposed to be undertaken

Passport, visa and other proof of identity documentation

To provide evidence of compliance with right to work, right to remain and status of working within the UK and in accordance with the organisation offering the work assignment and to support evidence of identity. Electronic versions of such documentation

Nationality

To support right to work and eligibility evidence and to capture diversity and equality measures and policies of the hiring organisation

Ethnic origin

To capture diversity and equality measures and policies of the hiring organisation

Gender

To capture diversity and equality measures and policies of the hiring organisation

Sexual orientation

To capture diversity and equality measures and policies of the hiring organisation

Registered disability status

To capture diversity and equality measures and policies of the hiring organisation and ensure managers and administrators can make reasonable adjustments and offer appropriate roles

Previous and current employment information

To provide managers and administrators with relevant information relating to prior work experiences, pay rates and other relevant information and to provide you with a record of work experience

Contact telephone number(s)

To enable managers and administrators to contact you in relation to work related matters and to provide information relating to your account and service

Contact email address

To enable managers and administrators to contact you in relation to work related matters and to provide information relating to your account and service

Student Reference Number

To enable organisations, including hiring managers and administrators to verify your student status and study information and to support proof of identity and eligibility for certain functions and services

Staff ID or Employer Number

To enable organisations, including hiring managers and administrators to verify your staff or employee status and to support proof of identity and eligibility for certain functions and services

National Insurance Number

To enable the payment for work and facilitate National Insurance contributions and deductions and to ensure compliance with current legislation and accounting requirements and to support proof of identity and eligibility

Tax Code and Taxation information

To ensure correct application of tax codes and to ensure compliance with legislation and accounting regulations

Employment start date

To ensure an accurate record is kept of all work you undertake and ensure compliance with necessary record keeping requirements

Work assignment start and end dates

To ensure an accurate record is kept of all work assignments undertaken over the system and provide an audit trail of those work assignments and to ensure compliance with all necessary record keeping requirements

Number of hours worked and on which days and at which times

To ensure an accurate record is kept of all work assignments undertaken and to ensure compliance with working hours rules and regulations and organisational policy and to comply with all relevant record keeping requirements

Notes and messages between you and your manager/supervisor and service administrators

To provide you and your hiring manager and relevant administration staff with a record of certain correspondence relating to work assignments and work related activity to provide up to date messaging and notifications and provide a record of all such messaging and notes

Student loan information

To ascertain the status of any student loan(s) in order to provide institutions and administrators with accurate information and to ensure compliance in relation to taxation and earnings information and to ensure compliance with relevant legislation and regulations

Details of when your studies start and finish and what type of studies you are undertaking and the duration of those studies

To provide the institution and service administrators with accurate information relating to your studies and the corresponding rules around how you may work, in what roles and for how many hours and to ensure compliance with relevant regulation and legislation

Next of kin

To enable the institution to contact named next of kin in the event of exceptional instances such as emergencies, incapacitation etc

Emergency contact information

To enable the institution to contact named emergency contacts in the event of exceptional instances such as emergencies, incapacitation etc

Your skills and qualifications

To facilitate the offering of relevant work opportunities and to provide managers and administrators with information on your skills and qualifications for reporting and analysis

Your areas of interest in work and working preferences

To facilitate the offering of relevant work opportunities and to provide managers and administrators with information on your skills and qualifications for reporting and analysis

References from prior and current managers and employers

To provide managers and administrators with meaningful references relating to prior work in order to assess suitability to work offers and enabling managers and administrators to follow up and contact the named referees where appropriate

Rates of pay, holiday pay, national insurance contributions, pension payments, bonus and ancillary payments and any deductions from pay

To provide an accurate record of pay, holiday pay, national insurance contributions, pension payments, bonus and ancillary payments and any deductions from pay to yourself, relevant managers and administrators and relevant tax authorities and to provide a record that complies with all relevant taxation and pay requirements and regulations

Personal statements in support of being considered for a work or voluntary assignment

To enable you to provide potential hiring managers and administration staff with a personal statement that supports your interests, abilities or other points of note that may help with decision making and to provide information for reporting and analysis

Education history, locations and grades

To provide your online profile with an up to date list of relevant qualifications and education history, including locations, dates, grades and other relevant information to provide managers and administration staff with information that can assist the offering of appropriate work and to enable reporting and analysis

Curriculum Vitae

To enable you to store a Curriculum Vitae as a part of your profile to make it available to managers and administrators as part of finding and offering you work that matches your skills, interests and capability and to provide insight on previous roles

Supporting documents that you upload in support of being considered for a work or voluntary assignment

To enable you to store any other documents, of your choice that may support your application or consideration for a role and to provide managers and administrators with information that will assist and inform the selection process

Details of previous work assignments including duration, timesheet information and rates of pay

To enable you, managers and administrators to access information relation to previous work experience, duration, pay rates and other information relevant to prior work roles to establish suitability to a role and to collate information for reporting purposes on activity, trends and spend

Photographic images of you

To enable managers and staff to associate your profile with you as an individual for identification and interaction purposes

Changes made to your profile, account and settings

To ensure a full audit trail of access to and changes to your online profile and account are maintained for safety, compliance and reporting purposes and to provide accountability for all such changes




3.1.3 Using your personal data: the legal basis and purposes


Keystone will process your data in accordance with GDPR and Data Protection law for the purposes as stated in 3.1.2 and on the following legal basis:


As necessary to perform our contract with you and with your employers:


As necessary for our own legitimate interests:


As necessary to comply with our legal obligations:


Based on your consent:


In all cases of consent based processing, that consent can be withdrawn via the Data Subject Access Request process at any time.



The only special categories of personal data captured or processed relate to racial and ethnic origin which some employers use to measure their equal opportunities performance, however all data subjects can opt whether or not to answer those questions when registering and creating their profile. Even where this information is given, the data subject retains the right to remove, delete or alter that information, in accordance with the Data Subject Access request process.





  1. 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 Keystone Employment Group 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.


Keystone maintains a Data Subject Access Request process (including you withdrawing consent and accessing any information, asking for personal data to be deleted, accessed or for processing to cease) which you can access at any time by contacting us as follows:



You may withdraw consent, cease processing, request to port personal data at any time by making a Data Subject Access Request. NB: you will be asked to provide proof of identity.


  1. Disclosure

Keystone Employment Group will not pass on your personal data to third parties without first obtaining your consent, other than those instances listed below. The following third parties will receive your personal data for the following purpose(s) as part of the processing activities:



  1. Retention Period

Keystone Employment Group will process personal data for as long as an active account in the Talent Bank system is maintained. When an account is closed we will retain the data for a maximum of 1 year, unless you request or give consent for it to be available to us or other legitimate parties for a longer period. You can request for your data to be deleted or ported sooner than the maximum 1 year if you wish. You may cancel and/or request for your account to be deleted at any time, but we may continue to process your data until the final payment cycle is complete to ensure compliance with legal obligations and to ensure workers are properly paid for any work they undertake.


Keystone Employment Group will store the personal data for a minimum of 7 years in the case of data required to meet our legal obligations with taxation, financial record keeping and right to work laws.


  1. 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:

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


  1. Complaints

In the event that you wish to make a complaint about how your personal data is being processed by Keystone Employment Group you can contact Keystone’s nominated Data Protection Officer at dpo@keystone-group.net


You also have the right to complain to the Information Commissioner’s Office. It has enforcement powers and can investigate compliance with data protection law: ico.org.uk



  1. Further information


Personal data

Under the EU’s General Data Protection Regulation (GDPR) personal data is defined as:

“any information relating to an identified or identifiable natural person ('data subject'); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person”.


How we use your information

This privacy notice tells you how we, Keystone Employment Group will collect and use your personal data and is detailed in section 3.1.2


We make an important distinction between capturing and analysing general web traffic and your personal data we store and process as a registered user. The first category collects data about users’ browsing actions and patterns, helping us to improve: our website, its content, features and general infrastructure performance. This type of data is collected by cookies and analysed with analytics software - no personal data is captured, this is aggregated data and does not identify any individual. The second category – registered users - does involve storing and processing of personal data for the purpose of related activities and services as detailed in 3.1.2


How we use Cookies


We use Session Cookies to provide security and carry information across pages of the Website and avoid you having to re-enter information; they are temporary and remain in the cookie file of your browser until you leave the Website.

We use Persistent Cookies to help when you return to the Website so we can tailor content and the presentation of the Website to match your preferences; they also assist in compiling anonymous, aggregated statistics that allow us to understand how users use the Website and so help us improve the structure of the Website. Persistent Cookies remain in the cookie file of your browser for much longer (though how long will depend on the lifetime of each specific cookie).


You have the ability to accept or decline cookies by modifying the settings in your browser. However, you may not be able to use all the interactive features of the Website if cookies are disabled.


Collecting personal data

All personal data you enter are captured via securely encrypted pages. Browsers display these security credentials using a padlock symbol; the exact format varies from browser to browser.

If you do not see a padlock symbol or the certificate details do not verify Keystone Employment Group as the owner of the site – then do not enter any details and contact our Customer Services team on 0844 225 1010 or our nominated DPO at dpo@keystonetalentbank.com


Sensitive details like passwords and bank details are stored in an encrypted form and all Personal Data is stored within the EEA at a secure data centre which is certified to ISO27001 - the only auditable international standard for information security management systems. Daily, encrypted backups of all data are performed and stored off-site.


Why does Keystone Employment Group need to collect and store personal data?

In order for us to provide you with a service we need to collect personal data for to enable prospective employers and other legitimate parties to offer you opportunities and information relating to work assignments. Please refer to Section 3.1.2 for a complete summary of the information we capture and what we do with it. In any event, we are committed to ensuring that the information we collect and use is appropriate for this purpose, and does not constitute an invasion of your privacy.


In terms of being contacted for marketing purposes Keystone Employment Group would contact you for additional consent.




Will Keystone Employment Group share my personal data with anyone else?

We may pass your personal data on to third-party service providers contracted to Keystone or your direct employer/and/or institution in the course of dealing with you. Any third parties that we may share your data with are obliged to keep your details securely, and to use them only to fulfil the service they provide you on our behalf. When they no longer need your data to fulfil this service, they will dispose of the details in line with Keystone’s procedures and data protection policy. If we wish to pass your personal data onto another third party, not directly involved in the provision of services to your or our clients, we will only do so once we have obtained your consent, unless we are legally required to do otherwise.


How will Keystone use the personal data it collects about me?

Keystone will process (collect, store and use) the information you provide in a manner compatible with the EU’s General Data Protection Regulation (GDPR). We will endeavour to keep your information accurate and up to date, and not keep it for longer than is necessary. Keystone is required to retain information in accordance with the law, such as information needed for income tax and audit purposes. How long certain kinds of personal data should be kept may also be governed by specific business-sector requirements and agreed practices. Personal data may be held in addition to these periods depending on individual business needs.


Under what circumstances will Keystone contact me?

Our aim is not to be intrusive, and we undertake not to ask irrelevant or unnecessary questions. Moreover, the information you provide will be subject to rigorous measures and procedures to minimise the risk of unauthorised access or disclosure.


Can I find out the personal data that the organisation holds about me?

Keystone at your request, can confirm what information we hold about you and how it is processed. If Keystone does hold personal data about you, you can request the following information:




Acceptable Use Policy


In using the web service clients agree to use it for the sole purpose of finding suitable Workers, offering them work related opportunities on behalf of their organisation and engaging with them through the system. Furthermore, users agree not to:


Users acknowledge that Keystone Employment Group own the copyright and all other intellectual property rights associated with the content, save where otherwise stated.


For further information or to request a Data Subject Access Request please contact:

dpo@keystone-group.net