Privacy Policy: Recruitment Consultants
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 Consultant.
Why do we collect your data?
We collect your data for the performance of the contract between us, either directly or via your employing company, allowing us to provide IT, finance, marketing, and other operational services to you/your company and for you to provide recruitment services to us.
If you are considering providing recruitment services to us, we may collect some information so we can communicate with you about the opportunity.
What data do we collect?
We collect:
Name(s)
Job title(s)
Company names and details
Email address(es)
Telephone number(s)
Mailing/residential address(es)
LinkedIn and other public social media account links
Employment and qualification histories
Due diligence checks
Identification documentation and proofs
Income and work permission statuses
Personal interests, hobbies, skills, and other personal data that may be provided on a CV
Bank details for payments
None of the personal data above will include 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 your role.
How do we collect your data?
You directly provide us with most of the data we collect. However, we may also use public sources of information, such as when conducting due diligence checks.
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.
Your personal data will be retained for six years from the end of our contract with you.
If you are a prospective Consultant i.e. a Consultant with which we have not signed terms of business, your data will be held for two years from our initial contact with you to provide sufficient time for terms of business to be signed.
What do we do with your data?
We use your data purely for the performance of our contract with you, more detail on which is available in the Data Protection Agreement you or your company are provided with when signing your contract.
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.
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. 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?
We process your data for the performance of our contract together.
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.
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.
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.