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Privacy Policy

Data Protection Policy
1. Introduction
This Data Protection Policy is the overarching policy for data security and protection for Clark James Recruitment Specialists (hereafter referred to as “us”, “we”, or “our”).

2. Purpose
The purpose of the Data Protection Policy is to support the 10 Data Security Standards, the General Data Protection Regulation (2016), the Data Protection Act (2018), the common law duty of confidentiality and all other relevant national legislation. We recognise data protection as a fundamental right and embrace the principles of data protection by design and by default
This policy covers
Our data protection principles and commitment to common law and legislative compliance;
procedures for data protection by design and by default.

3. Scope
This policy includes in its scope all data which we process either in hardcopy or digital copy, this includes special categories of data
This policy applies to all staff, including temporary staff and contractors

4. Principles
We will establish and maintain policies to ensure compliance with the Data Protection Act 2018, Human Rights Act 1998, the common law duty of confidentiality, the General Data Protection Regulation and all other relevant legislation.
We will establish and maintain policies for the controlled and appropriate sharing of service user and staff information with other agencies, taking account all relevant legislation and citizen consent.
Where consent is required for the processing of personal data we will ensure that informed and explicit consent will be obtained and documented in clear, accessible language and in an appropriate format. The individual can withdraw consent at any time through processes which have been explained to them and which are outlined in our Record Keeping Policy: Withdrawal of Consent procedures. We ensure that it is as easy to withdraw as to give consent.
We will undertake annual audits of our compliance with legal requirements.
We acknowledge our accountability in ensuring that personal data shall be:
Processed lawfully, fairly and in a transparent manner;
Collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes;
Adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed (‘data minimisation’);
Accurate and kept up to date;
Kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed (‘storage limitation’);
Processed in a manner that ensures appropriate security of the personal data.
We uphold the personal data rights outlined in the GDPR;
The right to be informed;
The right of access;
The right to rectification;
The right to erasure;
The right to restrict processing;
The right to data portability;
The right to object;
Rights in relation to automated decision making and profiling.
Due to our size, we have determined that we are not required to have a Data Protection Officer (DPO), as we do not process special categories of data on a large scale. Nonetheless, to ensure that every individual’s data rights are respected and that there are the highest levels of data security and protection in our organisation, we have appointed a member of staff to be our Data Security and Protection Lead. The Data Security and Protection Lead will report to the highest management level of the organisation. We will support the Data Security and Protection Lead with the necessary resources to carry out their tasks and ensure that they can maintain expertise.

5. Underpinning policies & procedures

This policy is underpinned by the following:
Data Quality Policy – outlines procedures to ensure the accuracy of records and the correction of errors;
Record Keeping Policy – details transparency procedures, the management of records from creation to disposal (inclusive of retention and disposal procedures), information handling procedures, procedures for subject access requests, right to erasure, right to restrict processing, right to object, and withdrawal of consent to share;
Data Security Policy – outlines procedures for the ensuring the security of data including the reporting of any data security breach;
Network Security Policy – outlines procedures for securing our network;
Business Continuity Plan –outlines the procedures in the event of a security failure or disaster affecting digital systems or mass loss of hardcopy information necessary to the day to day running of our organisation;
Staff Data Security Code of Conduct – provides staff with clear guidance on the disclosure of personal information.

6. Data protection by design & by default.

We shall implement appropriate organisational and technical measures to uphold the principles outlined above. We will integrate necessary safeguards to any data processing to meet regulatory requirements and to protect individual’s data rights. This implementation will consider the nature, scope, purpose and context of any processing and the risks to the rights and freedoms of individuals caused by the processing.

We shall uphold the principles of data protection by design and by default from the     beginning of any data processing and during the planning and implementation of any new  data process.

Prior to starting any new data processing, we will assess whether we should complete a Data Protection Impact Assessment (DPIA) using the ICO’s screening checklist: https://ico.org.uk/for-organisations/guide-to-data-protection/guide-to-the-general-data-protection-regulation-gdpr/accountability-and-governance/data-protection-impact-assessments/

All new systems used for data processing will have data protection built in from the beginning of the system change.

All existing data processing has been recorded on our Record of Processing Activities.

Each process has been risk assessed and is reviewed annually.

We ensure that, by default, personal data is only processed when necessary for specific purposes and that individuals are therefore protected against privacy risks.

In all processing of personal data, we use the least amount of identifiable data necessary to complete the work it is required for and we only keep the information for as long as it  is required for the purposes of processing or any other legal requirement to retain it.

Where possible, we will use pseudonymised data to protect the privacy and confidentiality of our staff and those we support.

Who we are

https://clarkjames.co.uk.

Comments

When visitors leave comments on the site we collect the data shown in the comments form, and also the visitor’s IP address and browser user agent string to help spam detection.

An anonymized string created from your email address (also called a hash) may be provided to the Gravatar service to see if you are using it. The Gravatar service privacy policy is available here: https://automattic.com/privacy/. After approval of your comment, your profile picture is visible to the public in the context of your comment.

Media

If you upload images to the website, you should avoid uploading images with embedded location data (EXIF GPS) included. Visitors to the website can download and extract any location data from images on the website.

Cookies

If you leave a comment on our site you may opt-in to saving your name, email address and website in cookies. These are for your convenience so that you do not have to fill in your details again when you leave another comment. These cookies will last for one year.

If you visit our login page, we will set a temporary cookie to determine if your browser accepts cookies. This cookie contains no personal data and is discarded when you close your browser.

When you log in, we will also set up several cookies to save your login information and your screen display choices. Login cookies last for two days, and screen options cookies last for a year. If you select “Remember Me”, your login will persist for two weeks. If you log out of your account, the login cookies will be removed.

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Embedded content from other websites

Articles on this site may include embedded content (e.g. videos, images, articles, etc.). Embedded content from other websites behaves in the exact same way as if the visitor has visited the other website.

These websites may collect data about you, use cookies, embed additional third-party tracking, and monitor your interaction with that embedded content, including tracking your interaction with the embedded content if you have an account and are logged in to that website.

Who we share your data with

If you request a password reset, your IP address will be included in the reset email.

How long we retain your data

If you leave a comment, the comment and its metadata are retained indefinitely. This is so we can recognize and approve any follow-up comments automatically instead of holding them in a moderation queue.

For users that register on our website (if any), we also store the personal information they provide in their user profile. All users can see, edit, or delete their personal information at any time (except they cannot change their username). Website administrators can also see and edit that information.

What rights you have over your data

If you have an account on this site, or have left comments, you can request to receive an exported file of the personal data we hold about you, including any data you have provided to us. You can also request that we erase any personal data we hold about you. This does not include any data we are obliged to keep for administrative, legal, or security purposes.

Where your data is sent

Visitor comments may be checked through an automated spam detection service.