Privacy Policy
At Fenway Resourcing Ltd. (“Fenway Resourcing”), safeguarding the confidentiality of information and the privacy of our candidates, clients, and other users of our websites and services is a top priority.
This Policy applies to the processing of all personal data collected by Fenway Resourcing concerning your use of our website or any services we may offer to you. Your privacy holds significant importance to us at Fenway Resourcing. To offer insights into how we process your data when you engage with our services, interact with our specialists, or visit our websites, including www.fenwayresourcing.com, we have formulated this Privacy Policy. In compliance with data protection legislation, we employ the term “personal data” to signify information related to an identified or identifiable natural person.
Who We Are and How to Contact Us
Fenway Resourcing operates as a resourcing business, offering work-finding services to both clients and job seekers. In this capacity, Fenway Resourcing functions as a data controller, necessitating the processing of personal data, including sensitive personal data, to facilitate the provision of these services.
You may provide your personal details directly to Fenway Resourcing through means such as conversations, emails, and website interaction, or we may obtain them from alternative sources such as a job board. The processing of your personal data by Fenway Resourcing requires a lawful basis. Specifically, to deliver work-finding services and provide information regarding relevant roles, we commit to using your personal data in strict accordance with the terms outlined in this policy.
Fenway Resourcing Ltd is registered in the UK and is registered with the Information Commissioner’s Office. You can contact us at 61 Dublin Street, Edinburgh, Scotland, EH3 6NL, or by email at Info@fenwayresourcing.com.
Definitions
Throughout this policy the following terms have the following meanings:
Automated Processing: Any form of automated processing of Personal Data consisting of the use of Personal Data to evaluate certain personal aspects relating to an individual, in particular, to analyse or predict aspects concerning that individual’s performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements. Profiling is an example of Automated Processing.
Consent: agreement which must be freely given, specific, informed and be an unambiguous indication of the Data Subject’s wishes by which they, by a statement or by a clear positive action, which signifies agreement to the Processing of Personal Data relating to them.
Data Privacy Impact Assessment (DPIA): Tools and assessments used to identify and reduce risks of a data processing activity. A DPIA can be carried out as part of Privacy by Design and should be conducted for all major system or process change programs involving the Processing of Personal Data.
Data Protection Legislation: To the extent the UK GDPR applies, the law of the United Kingdom or of a part of the United Kingdom which relates to the protection of personal data.
To the extent the EU GDPR applies, the law of the European Union or any member state of the European Union to which the party is subject, which relates to the protection of personal data.
EU GDPR: The General Data Protection Regulation ((EU) 2016/679).
UK GDPR: Has the meaning given to it in section 3(10) (as supplemented by section 205(4)) of the Data Protection Act 2018.
Personnel: All individuals working at all levels and grades, including managers, directors, trustees, board members, employees (whether permanent, fixed-term or temporary), consultants, contractors, trainees, seconded staff, homeworkers, casual workers and agency staff, volunteers, interns, agents, or any other person associated with us, wherever located.
Privacy by Design: Implementing appropriate technical and organisational measures at the very beginning of a project, process, or system in an effective manner to ensure compliance with the GDPR.
Privacy Notices: Separate notices setting out information that may be provided to Data Subjects when we collect information about them. These notices may take the form of general privacy statements applicable to a specific group of individuals or they may be stand-alone, one-time privacy statements covering Processing related to a specific purpose
Controller, processor, pseudonymisation, data subject, personal data, personal data breach, processing and appropriate technical and organisational measures shall have the same meaning as set out in the Data Protection Legislation in force at the time.
Collection of Personal Data
Fenway Resourcing collects and processes your personal data, which may include special categories, for the explicit purpose of delivering work-finding services. This encompasses activities such as communicating job opportunities, evaluating your suitability, updating databases, recommending you for roles, arranging payments, and managing our services and relationships with you and our clients.
In certain situations, we may be obligated to utilise your data to investigate, report, and detect criminal activities and to adhere to applicable laws. Additionally, your information may be used for internal audits to showcase compliance with industry standards.
The legal bases on which we rely to provide these services are:
- Your consent
- Legitimate interest
- Compliance with a legal obligation
- Fulfilment of a contractual obligation with you
For candidates previously registered with or employed by Fenway Resourcing, it is crucial to promptly inform us of any changes in your personal data. Information related to health and/or criminal records is processed only if relevant to your registration and is handled within the constraints of the law. If you provide information about third parties, we assume that you have obtained their permission for Fenway Resourcing to collect, process, and transfer their personal data to the same extent as yours.
By accepting our Terms & Conditions, you permit us to use your personal data to send automated email messages or marketing materials related to our services, including employment information. You retain the option to opt out of receiving such marketing messages at any time.
Personal data that is processed when you communicate with Fenway Resourcing
When you engage with us through email, telephone, online, or in-person interactions, we collect personal data, including your name, mailing address, phone number, email address, contact preferences, CV, and other pertinent information related to your work history. This information is provided by you to deliver our services. We also gather details about Fenway Resourcing events and meetups you participate in. Event logs may be created for diagnosing usability issues on our website, and information related to support or service issues may be captured. To enhance customer service, and in compliance with applicable laws, we may record and review conversations with our consultants and analyse feedback obtained through voluntary candidate and user surveys.
Purposes and Legal Grounds:
We utilise the personal data collected for the following purposes:
- Processing job applications in collaboration with our clients, to whom we are entrusted to fill job vacancies. This involves sharing your details with the relevant client to proceed with the application, and you acknowledge that this may result in further direct correspondence from them.
- With candidates’ permission, Fenway Resourcing may confidentially contact them about other potentially suitable opportunities that may arise in the future.
Legal Grounds for Processing:
- Fenway Resourcing’s interests in providing recruitment services and ensuring quality product support.
- Fulfilling our contractual obligations to you or any clients to whom you have requested us to pass on your details.
- Compliance with other legal obligations to which we may be subject.
In specific circumstances, we may seek your explicit consent to process particular personal data, and we will inform you accordingly.
Legal Bases for Processing Your Data
Fenway Resourcing operates as a data controller for its staff and candidates under Data Protection Laws. We ensure that personal data processing aligns with legal bases:
- Consent
We rely on your consent to process your personal data when you engage in the following activities with us:
- Expressing interest in a potential professional relationship: This can involve submitting a profile or connecting with us through various channels, indicating your openness to exploring potential collaborations or opportunities.
- Participating in activities designed to explore your career goals and aspirations: These activities might include completing assessments, attending social events, or engaging in discussions with our team members.
- During these interactions, you will be presented with clear information about the types of personal data we collect and how we use it. You will always have the right to withdraw your consent at any time by contacting us at info@fenwayresourcing.com
- Legal Obligations
We may be required to process your personal data to comply with legal obligations.
- Legitimate Interest
We may also process your personal data based on our legitimate interests, provided these interests are not overridden by your data protection rights. Our legitimate interests may include:
- Maintaining a pool of qualified candidates for future job openings.
- Verifying the information provided to us.
- Keeping you informed about relevant opportunities.
- Analysing data to improve our processes.
We will always strive to ensure that our legitimate interests are balanced against your data protection rights.
If you have any questions about the legal basis for processing your data, or if you wish to exercise your rights under applicable data protection laws, please contact us using the information provided in the “Contact Us” section below.
Disclosures and Transfers of Personal Data
Fenway Resourcing may disclose personal data under specific circumstances:
- Disclosure to clients is necessary for staffing services, including permanent placements.
- Personal data may be shared with entities handling business functions and services on our behalf.
- Disclosure to government agencies or third parties is made to comply with laws, and legal processes, or protect rights and safety.
Other Disclosures:
Personal data may be disclosed to comply with legal obligations, enforce terms and conditions, or pursue legal remedies. In the event of reorganisation or business disposition, personal data may be transferred to an affiliate or third party, ensuring compliance with this Privacy Policy.
Other service providers
While providing our services, we may share your personal data with other service providers who work on our behalf, including:
Telecommunications providers: We may utilise telecommunications service providers to facilitate communication with you. This could involve sharing your phone number or email address for purposes such as sending appointment reminders, important service updates, or two-factor authentication.
Customer Relationship Management (CRM) providers: We may utilise CRM software to manage customer interactions and communications. This may involve sharing your contact information, demographics, and interaction history with the CRM provider to ensure a smooth and personalised customer experience.
These service providers will only have access to the information necessary to perform their specific service and are obligated by contract to handle your data by this Privacy Policy and applicable data protection laws. We take steps to ensure all service providers we work with maintain appropriate security measures to protect your personal data.
Management and Security of Personal Data
At Fenway Resourcing, we prioritise the responsible management and security of your personal data. Acting as both a data controller and processor under the General Data Protection Regulation (GDPR), we adhere to fundamental data protection principles, ensuring that personal data is:
Processed Lawfully and Transparently:
- We process personal data in a manner that is lawful, fair, and transparent.
Collected for Specified and Legitimate Purposes:
- Personal data is collected for specific and legitimate purposes, with no further processing incompatible with these intentions.
Adequate, Relevant, and Limited:
- We ensure that personal data is adequate, relevant, and limited to what is necessary for the intended purposes.
Accurate and Up-to-Date:
- We take every reasonable step to maintain the accuracy of personal data, promptly rectifying or erasing inaccurate information.
Retention for Necessary Duration:
- Personal data is retained for no longer than necessary for the purposes it was processed.
Processed with Appropriate Security Measures:
- We implement technical and organisational measures to ensure the security of personal data, guarding against unauthorised or unlawful processing, accidental loss, destruction, or damage.
Fenway Resourcing is committed to demonstrating and ensuring compliance with these principles.
How We Collect Your Personal Data
We collect your personal data in a few ways:
1. Directly from you:
When you submit a profile or connect with us through our website or various channels, expressing interest in a potential professional relationship.
When you participate in activities designed to explore your career goals and aspirations, such as completing assessments, attending workshops, or engaging in discussions with our team members.
During any direct communication with us, including phone calls, emails, or meetings.
2. Through publicly available sources:
We may collect limited information about you from publicly available sources, such as your professional social media profiles (e.g., LinkedIn), by the terms of use of those platforms.
Transparency and Consent:
We are committed to being transparent about what data we collect and how we use it. Whenever we collect your personal data, we will provide you with clear information about:
- The specific data we are collecting
- The purpose for which we are collecting the data
- The lawful basis for processing the data
- Your rights about your data
We will always obtain your explicit consent before collecting and using your personal data for any purpose, except in the rare instances where processing is based on a legitimate interest, as outlined in the “Legal Basis for Processing Your Data” section of our Privacy Policy.
By interacting with us through the methods mentioned above, you are consenting to the collection and use of your personal data by this Privacy Policy.
Your Rights under the Data Protection Legislation
Data subjects have the following rights:
Right of Access to Your Data:
- You can confirm whether personal data about you is being processed and, if so, request access to that data.
- You also have the right to obtain a copy of the personal data being processed.
Right to Rectify Data:
- You may request Fenway Resourcing to rectify any inaccurate or incomplete personal data concerning you.
- If your data has been shared with third parties, we will inform them of the rectification request.
Right to “Be Forgotten”:
- You can request the complete deletion of your personal data from our database, including any third parties with access to the data.
- If shared with third parties, we will notify them of the erasure request.
(Note: Legal requirements may prevent immediate deletion based on statutory retention periods.)
Right to Restrict Data Processing:
- You have the right to ask Fenway Resourcing to restrict the processing of your personal data in certain situations.
Right to Data Portability:
- You can receive your personal data in a structured, commonly used, and machine-readable format and transmit it to another controller.
Right to Lodge a Complaint:
- You can object to the processing of your personal data based on public interest or legitimate interest.
- If dissatisfied, you have the right to complain to the supervisory authority. In the UK, it’s the Information Commissioner’s Office.
If you wish to exercise your right to restrict processing or your right to object to processing, or if you have any queries relating to the processing of your personal data by Fenway Resourcing Ltd, please contact our Data Protection Officer at 61 Dublin Street, Edinburgh, Scotland, EH3 6NLor by email at Info@fenwayresourcing.com.
Children
We request that individuals under 16 not provide personal data to Fenway Solutions. If we learn that we have collected personal data from a child under 16, we will take steps to delete the information as soon as possible.
Retention of Personal Data
We will retain your personal data as long as your engagement with Fenway for work-seeing purposes is considered to be active. In addition, see below under “Your Rights” for a description of your right of erasure.
Contacting us, exercising your information rights and Complaints
If you have any questions or comments about this Privacy Policy, wish to exercise your information rights in connection with the personal data you have shared with us or wish to complain, please contact us at Fenway Resourcing Ltd, 61 Dublin Street, Edinburgh, Scotland, EH3 6NL or send your email requests to Info@fenwayresourcing.com
We fully comply with Data Protection legislation and will assist in any investigation or request made by the appropriate authorities.
If you remain dissatisfied, then you have the right to apply directly to your competent supervisory authority.
Changes to this Policy
Fenway Resourcing reserves the right to change this Policy as we may deem necessary from time to time, as we add new products and apps, as we improve our current offerings or as technologies and laws change. You can determine when this Privacy Policy was last revised by referring to the “Last updated” legend at the top of this page. Any changes will become effective upon our posting of the revised Privacy Policy.
We will provide notice to you if these changes are material and, where required by applicable law, we will obtain your consent. This notice will be provided by email or by posting notice of the changes on the Fenway Resourcing websites and apps that link to this Privacy Policy.
