Company Name: Michael Warwick Nicholls Ltd (‘the Company’)
Company Contact Details: Sharon McDonagh (Data Protection Lead) - sharon@mwn.co.uk
Date Updated: 5th July 2023
This Privacy Policy applies to the personal data of our Website Users, Candidates, Clients and Suppliers.
Michael Warwick Nicholls Ltd is a recruitment business which provides work-finding services to its clients and work-seekers. The Company must process personal data so that it can provide these services – in doing so, the Company acts as a data controller.
The Company must have a legal basis for processing your personal data. We will only use your personal data in accordance with the terms of the following statement.
1) CATEGORIES OF PERSONAL DATA i. Candidates: In order to provide you with work finding services, we need to collect and process certain information about you. The information that we collect may include (but is not limited to) your name, address, email address, telephone number(s), curriculum vitae, employment details, salary information, notice period, qualifications, right to work in the UK, photograph, compliance documents, links to your professional profiles, employment preferences.
ii. Clients: If you are a client of Michael Warwick Nicholls Ltd, we need to collect and process information about you or individuals at your organisation in order to supply candidates to you and to ensure that the contractual arrangements between us can be implemented. The information we collect may include (but is not limited to) your name, job title, email address, telephone number(s), links to your professional profiles, work address details.
iii. Suppliers: If you supply services to Michael Warwick Nicholls Ltd, we will need to retain and process your contact details and contact details of relevant individuals at your organisation to ensure that the contractual arrangements between us can be properly implemented. This information may include (but is not limited to) your name, job title, email address, work address, telephone number(s), company bank details (so that we can pay for services provided).
Sensitive Personal Data: Different rules apply to sensitive or special category personal data where the data concerns race, ethnic origin, politics, religion, trade union membership, genetics, health (physical or mental), sex life or sexual orientation. We do not intentionally or knowingly collect this type of information as we do not need it for recruitment purposes. Please do not submit this type of data - any sensitive/special category data supplied, will be deleted.
2) SOURCES OF DATA i. Information we obtain directly from you: This is personal data that you give us by using the ‘Contact us page’ or by responding to a job advert on our website – www.mwn.co.uk (our site), or by corresponding with us by phone, e-mail or otherwise, including information you provide when you register to enter our database.
ii. Information we obtain from other sources: This is personal data that we obtain about you via other sources such as job boards, LinkedIn, CV libraries, referrals and any other relevant social media sites. We will inform you within 30 days of obtaining your details, by sending you this privacy notice stating the source the personal data originates from.
iii. Our website - You can send us your personal information via the ‘Contact Us’ page on our website or by applying to a job that is advertised.
- Cookies: www.mwn.co.uk (Our site) does not use cookies
- Our website contains links to Third Party sites. We recommend reading the privacy statements upon visiting these websites as we are not responsible for the information that is submitted/collected by these third parties.
3) PURPOSE OF PROCESSING AND LEGAL BASIS i. CANDIDATES: The Company will collect your personal data and will process your personal data for the purposes of providing you with work-finding services. This includes for example, contacting you about job opportunities, assessing your suitability for those opportunities, updating our database, putting you forward for job opportunities, and developing and managing our services and relationship with you.
In some cases, we may be required to use your data for the purpose of complying with laws that apply to us. We may also use your information during the course of internal audits to demonstrate our compliance with certain industry standards.
The legal bases we rely upon to process your personal data are:
a. Where we have a legitimate interest
b. To comply with a legal/statutory obligation that we have
c. Your consent
For the purposes of retaining and processing your personal data our legal bases are: Legitimate interest and statutory/legal obligation. a. Legitimate Interest: - We act as a recruitment agency as defined under the Employment Agencies Act 1973. We introduce candidates to clients for permanent employment - to be engaged directly by the client. The exchange of personal data of our candidates is an essential part of this process.
- To deliver our recruitment services we need to contact candidates on a regular basis via email, phone (calls and texts), job alerts and other relevant notifications
- As a leading Management Consultancy recruitment company, new vacancies are registered regularly. We require a database of candidate personal information so that we can contact candidate’s regarding potential job opportunities when they arise.
b. Statutory/Legal obligation: As a Recruitment agency, we are required to collect certain personal data to meet statutory obligations, such as the Conduct of Employment Agencies and Employment Businesses Regulations 2003 – for example, we have to check identity, right to work, suitability for the role, qualifications and experience before submitting your application to our clients.
For the purposes of sending you marketing information via email or SMS our legal basis is: Consent c. Consent - We will request your consent by email, should we need to rely on this legal basis.
- You have the right to withdraw your consent for marketing purposes at any time and can do so by contacting Sharon McDonagh, sharon@mwn.co.uk
- Where we have relied on consent to send you marketing material, we will retain this consent for a period of 1 year.
- Upon expiry of that period the Company will seek further consent from you. Where consent is not granted the Company will cease to send you marketing material.
ii. CLIENTS: The Company will collect and process information about you or individuals at your organisation in order to provide work-finding services. This includes for example, contacting you about job specifications, providing relevant candidates for vacancies, briefings, interview arrangements and to develop and manage our services and relationship with you.
In some cases, we may be required to use your data for the purpose of complying with laws that apply to us. We may also use your information during the course of internal audits to demonstrate our compliance with certain industry standards.
The legal bases we rely upon to process your personal data are:
a. Where we have a legitimate interest
b. To comply with a legal/statutory obligation that we have
c. Contractual obligations
a. Legitimate Interest: We need client contact information so that we can provide relevant candidates when new vacancies arise, to liaise regarding candidate feedback and interview arrangements, and for vacancy briefings.
b. Statutory/Legal obligation:
As a Recruitment agency, we are required to collect certain data to meet statutory obligations, such as the Conduct of Employment Agencies and Employment Businesses Regulations 2003. We cannot supply a work-seeker to a client unless we have obtained sufficient information from the client to select a suitable work-seeker for the position which the client is looking to fill – for example, the identity of the client and nature of the client’s business, the position the client is looking to fill including the type of work, location, hours, the experience, training and qualifications which the client considers necessary for a work-seeker to possess in order to work in the position.
c. Contractual obligation: If you are a client of Michael Warwick Nicholls Ltd, we need to collect and process information about you or individuals at your organisation in order to ensure that the contractual arrangements between us can be implemented.
iii. SUPPLIERS: For the purposes of retaining supplier information our legal bases are:
a. Legitimate Interest
b. Contractual obligation
a. Legitimate Interest: We need to collect and process information about you or individuals at your organisation to discuss the services that you provide to us.
b. Contractual obligation: If you are a supplier of Michael Warwick Nicholls Ltd, we need to collect and process information about you or individuals at your organisation in order to ensure that the contractual arrangements between us can be implemented.
4) RECIPIENT/S OF DATA i. CANDIDATES: The Company will process your personal data with the following recipients:
- Clients to facilitate your search for work
(Michael Warwick Nicholls Ltd will not forward your details to any Client without your permission).
- The REC (The Recruitment & Employment Confederation) in the event of any internal audits and investigations carried out on the Company to ensure that we are complying with all relevant laws and obligations
- MWN Associates Ltd – our Associate business, should you wish to discuss contract vacancies
- Our CRM providers (Chameleoni) only in the event of a technical issue or for database backup purposes
- Interhost LLP - our IT system providers
ii. CLIENTS: The Company will process your personal data with the following recipients:
- Candidates will receive job specifications and company information
(Michael Warwick Nicholls Ltd will only forward material that has been authorised by the client) - Candidates will receive interviewer’s name and job title along with interview scheduler name and contact information via interview confirmations.
- The REC in the event of any internal audits and investigations carried out on the Company to ensure that we are complying with all relevant laws and obligations
- Our CRM providers (Chameleoni) only in the event of a technical issue or for database backup purposes
- Interhost LLP - our IT system providers
iii. SUPPLIERS: The Company will process your personal data with the following recipients:
- Relevant MWN staff.
- The REC in the event of any internal audits and investigations carried out on the Company to ensure that we are complying with all relevant laws and obligations
- Our CRM providers (Chameleoni) only in the event of a technical issue or for database backup purposes
- Interhost LLP - our IT system providers
5) DATA STORAGE/SECURITY i. Data Storage Any information collected and processed by Michael Warwick Nicholls Ltd is stored in the following locations:
- On our secure CRM (Chameleoni)
- On our Talentpool portal, which showcases an anonymised, pertinent snapshot ofyour skills and experience – this snapshot contains
no identifiable information and is accessed by clients who possess a unique username and password. You canwithdraw your
information from the talentpool portal at any point by emailing sharon@mwn.co.uk.
- In our emails on Microsoft 365 (which can be accessed via our laptops and mobile phones only)
- In files on Microsoft 365 (which can be accessed via our laptops only)
ii. Data Security Our emails and files are housed on a secure server via Microsoft Office 365 who work to ISO 27001, 27018 and 27017 standard for information security. The server can only be accessed by Michael Warwick Nicholls staff, who each have a unique username and password.
- All laptops are password protected and an additional username and password is required to enter our emails and files.
- All mobile phones are password protected. An additional username and password is required to access emails on our phones.
- We've enhanced our cybersecurity by implementing Multi-Factor Authentication (MFA),leveraging the Microsoft Authenticator app.
This additional layer of security, requiring users to verify their identity through multiple factors, significantly strengthens protection against unauthorized access.
Our CRM (Chameleoni) is hosted by a Tier 1 ISO who provides industry-leading security and has a long list of internationally recognised certifications and accreditation’s including: ISO 27001 for information security, ISO 9001 for quality management systems, ISO 27017 for cloud security, ISO 27018 for cloud privacy, SOC 1, SOC 2 and SOC 3, PCI Level 1, The Crown Commercial Service (CCS) and multiple Microsoft accreditation’s. Security and performance tests are carried out at regular intervals to ensure the smooth running of the service.
Our talent pool is hosted by a Tier 1 ISO who providesindustry-leading security and has a long list of internationally recognisedcertifications and accreditation’s including: ISO 27001 for informationsecurity, ISO 9001 for quality management systems, ISO 27017 for cloudsecurity, ISO 27018 for cloud privacy, SOC 1, SOC 2 and SOC 3, PCI Level 1, TheCrown Commercial Service (CCS) and multiple Microsoft accreditation’s. Security and performance tests are carried out at regular intervals to ensurethe smooth running of the service.
6) DATA RETENTION Michael Warwick Nicholls Ltd will retain your personal data only for as long as is necessary. We regularly review the length of time that personal data is kept, considering the purpose(s) for which the data is being retained. Any data that is no longer required is destroyed securely. If we need to keep personal data to comply with legal or statutory requirements, we will minimise the data that is retained.
If you state that you no longer wish to be contacted by Michael Warwick Nicholls Ltd, we will cease all contact and delete your details from our database.
Unsuccessful applicants – please note that if you submit your details for consideration via a job board, our website, directly to us or via any other channels and we deem your application unsuccessful, we will not retain your information.
7) YOUR RIGHTS Please be aware that you have the following data protection rights:
- The right to be informed about the personal data the Company processes on you;
- The right of access to the personal data the Company processes on you;
- The right to rectification of your personal data;
- The right to erasure of your personal data in certain circumstances;
- The right to restrict processing of your personal data;
- The right to data portability in certain circumstances;
- The right to object to the processing of your personal data that was based on a public or legitimate interest;
- The right not to be subjected to automated decision making and profiling; and
- The right to withdraw consent at any time.
Where you have consented to the Company processing your personal data you have the right to withdraw that consent at any time by contacting Sharon McDonagh, sharon@mwn.co.uk.
There may be circumstances where the Company will still need to process your data for legal or official reasons. We will inform you if this is the case. Where this is the case, we will restrict the data to only what is necessary for the purpose of meeting those specific reasons.
If you believe that any of your data that the Company processes is incorrect or incomplete, please contact Sharon McDonagh, sharon@mwn.co.uk, and we will take reasonable steps to check its accuracy and correct it where necessary.
8) COMPLAINTS OR QUERIES If you wish to complain about this privacy notice or any of the procedures set out in it please contact: Sharon McDonagh, sharon@mwn.co.uk
You also have the right to raise concerns with Information Commissioner’s Office on 0303 123 1113 or at https://ico.org.uk/concerns/, or any other relevant supervisory authority should your personal data be processed outside of the UK, if you believe that your data protection rights have not been adhered to.
9) UPDATES TO THIS POLICY We regularly review our privacy policy and update the version on our website, to check that you have the most recent version – please periodically visit: http://www.mwn.co.uk/privacy-policy
This policy was last updated on 5th July 2023
