At Michael Page, your privacy matters

Who we are and how do we process your personal data

Michael Page International Recruitment Limited (company number 4130921) ("MPIR" "we", “us”, or “our”) is part of PageGroup, and trades under the brands Michael Page, Page Personnel, Page Executive and Page Outsourcing.

We are committed to protecting the privacy of our candidates, clients and users of our website. MPIR entity acting as Controller of your data will depend on the services we perform for you, as described below.

We want to provide a safe and secure user experience. We will ensure that the information you submit to us, or which we collect, via various channels (including our website, through written correspondence (including e-mail), conversations or meetings with our consultants, or through any of our offices or websites globally), is only used for the purposes set out in this Privacy Policy.

Through this Privacy Policy we aim to inform you about the types of personal data we collect, the purposes for which we use the data and the ways in which the data is handled.  We also aim to satisfy the obligation of transparency under the UK GDPR and any other laws that may be applicable.

Scope

Protecting your personal data is our priority. This privacy policy explains how MPIR processes and protects personal data about:

• candidates who register with us for roles that we are managing for other employers and for roles at Michael Page, or through our website, job boards, social media sites or other sources;
• prospective candidates,
• business contacts at our clients and suppliers; and
• users of our websites;

(collectively "you" or “your").

It also tells you about your privacy rights including your right to object to our processing. If you would like to contact us, please see the “How to contact us” section of this policy.

Personal data we collect

Candidates

When you register with us as a candidate to provide work finding services to you, you provide and we process your personal data, including but not limited to your name, contact details and information from your CV, current benefits and your expectations for future roles. Where permitted by law, we may also collect information relating to your health (for example, disability information for reasonable work adjustment purposes), diversity information, including race, ethnic origin, sexual orientation and religion (for equal opportunity monitoring purposes) as well as details of any unspent criminal convictions where required by a client or by us if you apply for a role with us. 

If you use our website, click on links in emails we send to you, open or forward them, or sign up to receive job alerts or other content from us, we also collect personal data from those interactions. 

We also obtain personal data about you from third parties, including:

• referees - when you are offered a job;
• former employers - to confirm dates of employment;
• educational institutions - to check your academic qualifications;
• the Disclosure and Barring Service or Disclosure Scotland - if we need to obtain details of unspent criminal convictions; 
• credit reference agencies - if we need to check your financial standing;
• publicly available sources such as LinkedIn and social media sites to enhance the information we hold about you, in order to help us find more suitable roles for you; 
• clients to whom we have provided your CV and who have engaged with you as part of a job application or who have given feedback on your CV. 

Prospective Candidates

We collect personal data about you, including your name and contact details and professional biographical details obtained from publicly available sources such as LinkedIn and social media sites, so that we can contact you if we think you may be interested in our work finding services at a future date. We may also obtain your personal data through another candidate or an employer who recommends you as a contact.

Prospective Business Clients

We collect your contact details and data relating to your function or position to establish commercial relationships with your company.

Users of our website or apps

We collect personal data such as your IP address and other data about your device which we need to provide our online content to you. We also collect data about your engagement with our website or apps such as the pages you view. If you contact us, we will also collect information about your enquiry. We use cookies and similar technologies to collect a lot of this information and our cookie policy tells you more about this.

Clients

We collect personal data such as your name, job title and contact details. We also process personal data about what communications we have had with you, including whether you have opened or forwarded any emails, newsletters or other content we have sent to you. We also process feedback that you provide about our candidates.  

If you provide information to us about a candidate (for example, if you confirm a candidate has worked with you or if you provide a reference), then we will obtain your details from the candidate and we will keep a record of the personal data that you provide to us about that candidate. 

We process personal data about you from public domain sources such as LinkedIn and social networking sites or because you were a delegate at one of our events or at an event where the event organiser is permitted to share delegate details with us.

Suppliers

We typically collect your name and contact details as a business contact for your organisation. 

Providing your personal data

In some cases, it will be necessary for you to provide personal data to us for us to work together. If you don’t provide us with the personal data we ask for, we may not be able to provide you with our services.

How we use your personal data

Candidates

We use your personal data to:  

• provide you with work finding services;
• communicate with you;
• enable you to upload your CV and apply for jobs;
• personalise your experience by creating a candidate profile; 
• enable us to monitor equality and diversity;
• provide you with interviewing and salary advice and
• send you direct marketing for the purposes of informing you about job opportunities, industry reports and insights, events, promotions and competitions, and other content in accordance with your marketing choices.

We also run targeted and relevant banner advertising on our website and within your social networks to present you and people like you with jobs and content that we believe will be of interest. We target these ads based on your previous interactions with our website, emails and through your engagements with our consultants. Your interaction with our ads may be used to measure the effectiveness of our ad campaigns and to improve our marketing strategy. This processing is carried out via Cookies and only if you have previously provided consent.

Prospective Candidates and Business Clients

We use your personal data to:

• determine if you may be interested in our services and how we can assist you;
• to contact you and find out if you are interested in our services.

Users of our website or apps

We use your personal data to:

• improve and personalise your experience when you use our website or apps; and
• personalise advertising you receive from us.

Clients

We use your personal data:

• to provide recruitment services to you; 
• to communicate with you;
• to get feedback from you on our services through client satisfaction surveys, in order to improve our services and to develop new services;
• to maintain our business relationship with you;
• to answer your enquiries when you contact us;
• to fulfil contractual obligations to you;
• to establish, exercise or defend legal claims; and
• for direct marketing purposes.

Suppliers

We use your personal data:

• to communicate with you;
• to maintain our business relationship with you;
• to answer your enquiries when you contact us;
• to fulfil contractual obligations to you;
• to establish, exercise or defend legal claims; and 
• for direct marketing purposes.

You can unsubscribe from receiving marketing communications from us, using the unsubscribe methods contained in communications we send to you or by contacting us. We have also established a marketing preference centre where you can view and make decisions about your marketing preferences and opt out of receiving marketing from us at any time.

Legal Grounds for processing your Personal Data

Under the UK GDPR, we rely on the following legal grounds to process your personal data:

(a)  Performing a contract - where, in order to perform our obligations under a contract with you or to take steps at your request to enter into a contract with us, it is necessary for us to process your personal data; 

(b)  Compliance with a legal obligation - where we need to process your personal data to comply with legal or regulatory obligations.

(c)  Our legitimate interests or those of a third party - including:

• providing our services to you;
• responding to your requests and enquiries (the legitimate interest of the Companies in this case is to maintain a constant and updated communication with clients and candidates, which is part of any commercial relationship);
• optimising the performance of our website and user experience;
• informing you about our services (job opportunities, industry reports and insights, events, promotions and competitions (the legitimate interest of Page is to inform clients and candidates about similar services and products);
• ensuring that our operations are conducted in an efficient manner;
• providing satisfaction surveys of our services; and
• contacting prospect business clients in order to establish commercial relationships with business clients (the legitimate interest of Page is to maintain relations of any kind with the company where the contact person works).

We have performed a legitimate interest assessment in order to confirm that our interests are not overridden by your interests or fundamental rights and freedoms, you can ask for this assessment using the contact details below.

(d) Consent In some circumstances, we will ask for your consent to process your personal data in a particular way – particularly to manage your marketing preferences or when we run talent trends surveys. For example, if you register for a job, we will offer you the possibility of registering for similar job alerts.  To the extent that we are processing your personal data based on your consent, you have the right to withdraw your consent at any time.  Please contact us, if you would like to withdraw your consent.

Automated Decision Making

We do not take decisions based solely on automated processing; there is always human intervention before taking a decision.

We perform two types of profiling based on candidate’s personal data:

• JobMatch is a tool available on our website for candidates to upload their CVs so we can recommend jobs that align to our skills. However, this profiling does not restrict nor excludes access to other jobs and positions.
• Intelligent search within our customer database enables us to filter through CVs when we receive many applications for roles that we advertise, and to enter relevant key words such as years of experience or field of practice. It then analyses all the CVs uploaded into it and delivers a smaller pool of candidates by matching the key words in candidates’ CVs and ranking the candidates according to their suitability for the role. As explained above, there is always a recruiter who verifies this process, so there are not automated decisions.

Please note that none of this profiling activities produce legal or similar significant effects to candidates, however if you would like to know more please contact us.

Who we share your personal data with

In certain circumstances we will share your personal data with:

Other companies within our Group

MPIR is part of the PageGroup of companies which operates globally. Our recruitment experts and key members of the business who run functions such as payroll and IT support are based all around the world. We may share with or give access to your personal data to other companies within PageGroup. Find a list of PageGroup entities and the countries where they are located.

For example, where appropriate for your job search or if you are looking for a qualified professional to join your organization or a recruitment partner, we may share your personal data with our recruiters specialised in Technology and Outsourcing recruitment for the UK market who are based either in Turkey or the Philippines (see entity list above). They process your personal data on behalf of the UK entities as it may be applicable (see list above). An appropriate level of data protection is ensured for this transfer on the basis of the company's intragroup agreement and SCCs as described below.

The UK recognises that after Brexit, countries in the EEA provide adequate protection for personal data.

We have in place an intra-group data transfer agreement containing the Standard Contractual Clauses approved by the UK Parliament for the transfer of personal data to ‘third countries’ (“SCCs”). The intra-group agreement also contains the UK’s international transfer agreement addendum to the SCCs. These SCCs act as an additional safeguard to permit cross-border transfers of personal data from within the EEA to third countries outside the UK and EEA, (as data protection laws outside the EEA may not provide an equivalent level of protection to EEA data protection laws).

If you would like a copy of the SCCs, please contact us.

The purposes of sharing your personal data within PageGroup companies are: (i) providing essential services which are centralised in one single entity such as IT, commercial and sales support services, in this case these entities will access and process your personal data as data processors, following the instructions of your data controller, (ii) managing global, regional or senior executive positions, or the development of key accounts, which would require the cooperation of different companies across the group, and (iii) managing positions that can be fulfilled remotely.

The applicable lawful basis to these processing activities is the performance of the contract with clients and candidates or to take steps necessary to enter into a contract, and the legitimate interests of PageGroup in delivering its services using internal resources.

Please bear in mind, that if you register as a candidate in a different country than the one in which you originally joined PageGroup, a unique record will be created for you. A single record avoids duplicities and improve accuracy of the personal data. For these purposes, the PageGroup companies involved will share your personal information as independent data controllers.

Third Parties

If you are a candidate, we share your personal data with clients who have vacancies for jobs which you are interested in.

We also share your personal data and, where necessary, special category data with third party service providers who perform services and functions on our behalf, such as:

• conducting employment reference checks;
• conducting qualification checks;
• carrying out criminal convictions checks (as required);
• verifying details you have provided from third party sources; 
• conducting psychometric evaluations or skills tests;
• hosting personal data for us;
• providing professional advice to us;
• providing data analytics to us;
• carrying out testing and development work on our business technology systems;
• administering surveys or competitions on our behalf; 
• assisting us to communicate with you; and
• providing research and mailing house or other direct marketing services.

We contractually require minimum standards of confidentiality and data protection from our third party service providers. If we need to send personal data outside the EEA, we will ensure that adequate safeguards are in place, such as the Model Clauses.

Other Disclosures

In addition, we may disclose your personal data:

• if we are legally required to do so;
• to law enforcement agencies, regulators or other government officials; and
• to the new business owners and their advisers in the event of a re-organisation, merger, sale, joint venture, assignment, or other transfer or disposition of all or any part of our business.

Keeping your personal data secure

We have implemented and maintain appropriate technical and organisational measures to protect your personal data from accidental or unlawful destruction, loss, alteration, unauthorised disclosure or access. Only authorised personnel and third-party service providers are provided with access to personal data on a need-to-know basis, and these employees and service providers are contractually obliged to treat this information as confidential.

How long we hold your personal data for

We will keep your personal data for as long as we need to in order to fulfil the purpose we collected it for, which may be an ongoing purpose. For example, if you’re a candidate, we will retain your personal data for the duration of our business relationship with you and beyond, as we often support candidates with job placements over many years and potentially throughout their careers.

We keep some personal data for longer than others. To determine the appropriate retention period for personal data, we consider factors such as the purposes for which we process your personal data, including any legal, regulatory, accounting and reporting obligations, the nature and amount of personal data that we hold about you, and the potential risk of harm to you from unauthorised use or disclosure of your personal data.

Where we process your personal data for direct marketing purposes, we will do so until you ask us to stop, and for a short period after this (to allow us to implement your request). We also keep a record of the fact that you have asked us not to send you direct marketing or to process your data indefinitely, so that we can respect your request.

Your rights in relation to personal data we hold about you

You have several rights under UK and EU data protection laws. These rights include the right to ask us for a copy of your personal data, to correct, delete or restrict processing of your personal data; to obtain the personal data you provide to us for a contract or with your consent in a structured, machine readable format, and to ask us to share (port) this data to another controller.

In addition, you can object to the processing of your personal data in some circumstances (in particular, where we don’t have to process your personal data to meet a contractual or other legal requirement, or where we are using the data for direct marketing).

These rights may be limited, for example, if complying with your request would reveal personal data about another person, where they would infringe the rights of a third party (including our rights) or if you ask us to delete information which we are required by law to keep or have compelling legitimate interests for keeping. We will inform you of any relevant exemptions we are relying on when we respond to your request.

How to contact us

Exercising your rights

To exercise your rights, or to withdraw your consent to processing, or to unsubscribe from receiving marketing communications from us, you can:

• complete our GDPR contact form, or
• email us at ukgdpr@pagegroup.co.uk, or
• write to us or our DPO at:

Michael Page International Recruitment Limited
UK GDPR Processing Team
3rd Floor,
The Switch, 1-7 The Grove
Slough
Berkshire
SL1 1QP

Questions and Complaints

If you have any questions about our privacy policy, or about our processing of your personal data, or to make a complaint, you can email us or our DPO at dpo@page.com or write to us at:

Michael Page International Recruitment Limited
UK Data Protection Team
2nd Floor
80 Strand
London
WC2R 0DT

If you have unresolved concerns, and you live or work in the UK or believe that a personal data breach happened in the UK, you have the right to complain to the UK Information Commissioner’s Office who can be contacted at:

Telephone: 0303 123 11113
Website: https://ico.org.uk/concerns/
Post:

Information Commissioner's Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

If you live or work outside the UK, or you have a complaint concerning our activities outside the UK, you may prefer to lodge a complaint with a different supervisory authority. A list of relevant authorities in the EEA can be accessed here.

Changes to our Privacy Policy

We may change this privacy policy at any time. If we do so, we will post updates on this site.