Privacy Policy: Candidates
We are Van Kaizen Limited, a company registered in the Isle of Man #132444C that provides a recruitment platform to independent headhunters. We believe in maximising your privacy and confidentiality, in keeping with good business practice and the law, which for us is the Isle of Man’s data protection legislation and regulation. This policy explains what personal data we use, as well as why and how we use it and what it means for you as a Candidate. For policies relating to other relationships with Van Kaizen, see here. We refer to you as a ‘live candidate’ if we are holding your data for the purposes of placing you with one of our clients who is seeking to recruit. We refer to you as a ‘placed candidate’ if we are holding your data in connection with your recruitment by our client.
Why do we collect your data?
We collect live Candidate data to allow us to match the qualifications of Candidates to the needs of Clients, so we can introduce the right Candidates to the right Clients with the aim of securing an offer of employment. This is the provision of the recruitment services our Clients and Candidates expect of us.
We retain placed Candidate data to enable us to respond to any queries after you have been placed, either from your or from your employer.
We collect anonymised web visitor data to help us see how people use our website, and in turn to use that insight to improve the design and functionality of that website for future visitors.
What data do we collect?
We work with Candidates interested in securing employment with our Clients. We collect the following Candidate data:
Name(s)
Email address(es)
Telephone number(s)
Home address(es)
LinkedIn and other public social media account links
Employment and qualification histories
Income and work permission statuses
Personal interests, hobbies, skills, and other personal data that may be provided on a CV
We won’t ask you for any special category data (as defined in the prevailing Isle of Man data protection legislation and regulations (IOMDPR)) and so if this type of data is included on any CV you provide, we will be relying on the fact that you have voluntarily provided that to us. Examples of special category data that might be on your CV is information about your health or information about any adjustments that are required in order for you to undertake a particular role.
We also collect purely anonymous data on visitors to our website (which may include you as a Candidate) using cookies, which are explained in more detail below.
How do we collect your data?
You directly provide us with most of the data we collect. Personal data is normally submitted to us via email, LinkedIn messenger, an equivalent one-to-one messaging platform, or via a job application form on our website. This usually takes the form of providing a CV document, which we keep on file. Some data may be taken from public sources such as LinkedIn or company websites.
We also collect anonymised data via browser cookies when you visit our website, which are explained in more detail below.
How do we store your data and how long do we keep it for?
Data are stored in searchable digital formats in our cloud hosting environment. We maintain a highly secure digital infrastructure with rigorous security and redundancy standards and policies. To minimise the risk of losing data, they are not held in physical form.
If you are a live candidate, we will keep your data until you tell us that you do not want us to keep it anymore. This is to enable you to have the best opportunity to be placed with one of our clients. You will receive a reminder every two years that you have the right to have your data deleted and this will include information about how to easily exercise that right. If you want your data to be retained, you will also be reminded to update your CV.
If you are a placed candidate, we will retain your data for six years from the date of your placement and this will override the retention period applicable to you when you were a live candidate. If you subsequently become a live candidate, the retention period for live candidates will recommence.
Website visitor data is held in the analytics engine of our website hosting provider.
What do we do with your data?
We use Candidate data to match Candidates to job opportunities.
As a Candidate, we may pass your data to Client organisations in the event we believe you are suitable for a vacancy. If your data is passed to Client organisations, then in these circumstances we will be acting on behalf of our Client and the handling of your personal data will be governed by the Client's own privacy policy.
Note that Client organisations may process your data in some of the following ways, in line with their privacy policies.
Assessing your suitability for a role
Contacting you for interview and examination requests
Background and credit checks
Contacting your referees
These are activities for which we are not responsible. However, we have robust agreements in place with our clients that require them to treat your data with the same degree of security and responsibility that we would.
We may also share your data with third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.
Who can see my data?
We share your personal data within Van Kaizen, with contracted recruitment consultants, with our Clients, and with various software suppliers and service providers with whom Van Kaizen has entered into agreements.
Our recruitment consultants and suppliers will only see your data in the context of our systems and policies. Clients to whom we introduce you may process your data under their own policies and systems.
Where is my data held?
Our top-tier data hosting providers store your data in various secure locations within the EEA. This is where your data rests when it is on Van Kaizen’s systems, regardless of the location of anyone interacting with that data.
We may on occasion need to transfer your personal data out of the EEA, for example if we were to introduce you to an employer based elsewhere. When we do, we will ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
We will transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see:
https://www.inforights.im/organisations/data-protection-law-2018/transfers-to-third-countries/We may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see
https://www.inforights.im/organisations/data-protection-law-2018/transfers-to-third-countries/
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
What is the legal basis on which we collect and process your data?
As a live candidate, we believe we have a legitimate interest to process your data, because they are essential to the delivery of the recruitment services that we offer to you as a Candidate. We do not collect data that we do not need for this purpose and we do not believe that our collection and processing infringes on your rights.
If we are successful in securing employment for you with a Client, we will then retain and process your data on the revised basis that it is required for the performance of our contract with the Client and with reference to the statute of limitations for matters arising from such a contract.
What are your rights to that data?
You are entitled to all the following rights, and we will actively seek to uphold these rights for you:
The right to access: You have the right to ask us for copies of your personal data.
The right to rectification: You have the right to request that we correct or complete any information you believe is inaccurate or incomplete.
The right to erasure: You have the right to request that we erase your personal data, under certain conditions. If you are a live candidate, we will remind you of that right every two years.
The right to restrict processing: You have the right to request that we restrict the processing of your personal data, under certain conditions.
The right to object to processing: You have the right to object to our processing of your personal data, under certain conditions, particularly when we are relying on legitimate interest to process your data (see previous section).
The right to data portability: You have the right to request that we transfer the data that we have collected to another organization, or directly to you, under certain conditions.
If you make a request, we have one month to respond to you. If you would like to exercise any of these rights, please email us. You can find out more about these rights here.
Who do I contact if I have questions or concerns?
If you would like to discuss this policy with us, please contact our Data Protection Officer who is Graeme Brooks, (Director).
+44 7624 487045
You have the right to make a complaint at any time to the Isle of Man Information Commissioner's Office (ICO) (www.inforights.im), the Isle of Man supervisory authority for data protection issues.
We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
Changes to our privacy policy
We keep our privacy policy under regular review and place any updates on this web page. This privacy policy was last reviewed in July 2023.
Privacy policy of other websites
Our privacy policy applies only to our website, so if you click on a link to another website, you should read their privacy policy.
Cookies
Cookies are text files placed on your computer to collect visitor behaviour information. When you visit our websites, we will try to collect information from you automatically through these cookies, unless you have them disabled in your browser. For further information, visit www.allaboutcookies.org.
How do we use cookies?
We use cookies to understand how you use our website. We don’t use them to identify or store any personal information about you as an individual, all the browsing data we use is anonymous.
What types of cookies do we use?
There are a number of different types of cookies used by our website hosting and analytics provider, an up-to-date list of which can be found here.
How to manage cookies
You can set your browser not to accept cookies, and the above website tells you how to remove cookies from your browser. However, in a few cases, some of our website features may not function as a result.