WHAT IS THE PURPOSE OF THIS NOTICE?

Citrus Connect Ltd is committed to protecting your personal data. This privacy notice aims to give you information on how Citrus Connect Limited collects and processes your personal data. It explains your privacy rights and how the law protects you including how we comply with current legislation which relates to the use of personal data.

This policy notice applies to you when we collect or process your personal data for example when you use our website (www.citrus-connect.co.uk), get in touch with us for any reason (including by phone or email), when you apply to work for us, when we get in touch with you in relation to a job role we are seeking a candidate for, or if you wish to apply for a job role we are seeking a candidate for, on behalf of one of our clients.

It is important that you read this privacy notice together with any other privacy policy or notice we may provide on specific occasions where we are collecting or processing personal data about you so that you are fully ware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.

CONTROLLER

Citrus Connect Ltd is the “controller” and responsible for your personal data (referred to in this notice as “Citrus Connect Ltd”, “we” or “our.”)

We have appointed a data protection officer (DPO) to oversee compliance with this privacy notice. If you have any questions about this privacy notice or how we handle your personal information, please contact the DPO using the details below.

CONTACT DETAILS

If you have any questions about this privacy notice, please contact our DPO in the following ways: Company: Citrus Connect Ltd

Email address: leenap@citrus-connect.co.uk

Postal address: No 1 Aire Street, Leeds, England, LS1 4PR

You have the right to make a complaint at any time to the Information Commissioner’s Office (“ICO”), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

YOUR DUTY TO INFORM US OF CHANGES

We keep our privacy policy under regular review. This version was last updated in October 2021.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

THIRD-PARTY LINKS

Our website may include links to third-party websites (including our social media pages), plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

THE KIND OF INFORMATION WE HOLD ABOUT YOU

Personal data, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store, and transfer the following categories of personal data about you:

• Identity Data including your full name and title.

• Contact Data including your home address, email address and telephone number.

• CV and Application Data including your employment history, contact details and any other data you may supply to us in your curriculum vitae (“CV”), any covering letter, or application form including (if applicable) your date of birth, gender and qualifications.
• Interview Data any additional personal data you provide during a job interview.

• Technical Data including your internet protocol (“IP”) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access our website.
• Communications Data including your preferences in receiving updates or marketing from us.

SPECIAL CATEGORIES OF PERSONAL DATA

We may collect special categories of personal data about you, this includes:

• Information about your race or ethnicity, religious or philosophical beliefs, sexual orientation, political opinions and trade union membership; and
• Information about your health, including any medical condition, health and sickness records.

INFORMATION ABOUT CRIMINAL CONVICTIONS

We process information about criminal convictions only where we have obtained your prior consent to do so, and strictly for the purpose of managing your application and suitability for a particular job role.

HOW IS YOUR PERSONAL INFORMATION COLLECTED?

We may collect personal information about you from the following sources:

• Direct interactions with you. You may provide us with your Identity and Contact Data by corresponding with us by post, phone, email or in person. This includes personal data you provide when you contact us with an enquiry.
• Interactions with you following an enquiry or application. You may provide us with your Identity and Contact Data, and CV and Application Data if you contact us in relation to a job role, or submit your CV to us (including via the CV Drop Off function on our website).
• Reed, CV Library, Total Jobs (and other job boards we may use from time to time). We may also collect your Identity, Contact, and CV and Application Data from other recruitment agency job boards, including when we get in touch with you in relation to a potential role you might be interested in.
• Personal referrals. From referrers who provide us with your Identity and Contact data.

• Referees. From whom we may collect your Identity Data and information about your employment history, suitability for a role and job performance.
• Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies.
• Third parties or publicly available sources. We may receive personal data about you from available sources such as information online and any social media profiles you may have including LinkedIn.

HOW WE WILL USE INFORMATION ABOUT YOU

We will only use the personal information we collect about you when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• Where we need to perform a contract we are about to enter into or have entered into with you.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal obligation.

• Where we have your consent.

PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA

We have set out below, in a table format, a description of all the ways we may use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/Activity	Type of data	Lawful basis for processing including basis of legitimate interest
To respond to an enquiry you raise with us.	IdentityContact	Necessary for our legitimate interests in responding to your enquiry.
Where you are a candidate seeking a role with one or more of our clients:   to assess your skills, qualifications and suitability for a job role and whether to shortlist you for the role;to carry out background and reference checks, where applicable;communicating with you throughout the application, interview and recruitment process (as applicable).	IdentityContactCV and ApplicationInterview	Necessary for our legitimate interests in carrying out our recruitment services including considering and progressing your application for a role.
Where we get in touch with you in relation to potential job roles using contact details you have supplied on a job board.	IdentityContactCV and Application	Necessary for our legitimate interests in offering our recruitment services and contacting you in relation to your job search.
To keep records relating to the recruitment processes for roles with our clients.	IdentityContactCV and Application	Necessary for our legitimate interests in carrying out and improving our recruitment

	(d) Interview Data	services,    and    in    keeping internal and audit records.
To manage our relationship with you which will include: Notifying you about changes to our terms or privacy policy; (b) sending marketing and communications to you.	IdentityContactCommunications	Performance of a contract with youNecessary to comply with a legal obligationNecessary for our legitimate interests (to keep our records updated).
Where you are applying for a role with Citrus Connect Ltd: Assessing your application and considering your suitability for the role, communicating with you in relation to the recruitment process, and taking up any necessary references and interviewing you.	IdentityContactCV and ApplicationInterview	Necessary for our legitimate interests in assessing candidates for roles within our business.
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data).	IdentityContactTechnical	Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise).Necessary to comply with a legal obligation.

DISCLOSURES OF YOUR PERSONAL DATA

We may share your personal data with the parties set out below for the purposes set out in the table above.

• Our Client(s) – where you are a candidate seeking to apply for a role with one of our clients, if you are successfully shortlisted for a role we will transfer certain of your personal data to our client in order to progress your application, and so that our client can assess your suitability for the role and whether it wishes to invite you to interview. If your application is

successful we may share your personal data with our client to provide further assistance with your recruitment.

• Third parties – such as website hosts, organisations who help us run our business, credit reference agencies, and law enforcement and fraud prevention agencies, or third parties whom we may choose to sell or transfer parts of our busines or assets to.

If you fail to provide personal information

If you fail to provide information when requested, we may not be able to progress your job application. For example if you fail to provide evidence of qualifications or work history requested, or if we require a credit check or references for this role and you fail to provide us with relevant details, we will not be able to take your application further.

HOW WE USE PARTICULARLY SENSITIVE PERSONAL INFORMATION

We will use your particularly sensitive personal information in the following ways:

• We will use information about your disability status to consider whether we need to provide appropriate adjustments during the recruitment process, for example whether adjustments need to be made during a test or interview.
• We will use information about your race or national or ethnic origin, religious, philosophical or moral beliefs, or your sexual life or sexual orientation, to ensure meaningful equal opportunity monitoring and reporting.

AUTOMATED DECISION-MAKING

You will not be subject to decisions that will have a significant impact on you based solely on automated decision making.

DATA SHARING

Why might you share my personal information with third parties?

We share your personal information with prospective employers for the purposes of processing your application. All prospective employers, third-party service providers and any other entities in the group are required to take appropriate security measures to protect your personal information in line with our policies. We do not allow our third party service providers to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions.

INTERNATIONAL TRANSFERS

We do not typically transfer your personal data outside of the UK, however as some of our external third party providers are based outside of the UK, their processing of your personal data may involve a transfer of data outside the UK.

Whenever we transfer your personal data outside of the UK, we ensure a similar degree of protection is afforded to it by ensuring that appropriate safeguards are implemented, for example,

by only transferring your personal data to countries that have been deemed to provide an adequate level of protection for personal data.

Please contact us if you would like further information in relation to transfers of personal data out of the UK.

DATA SECURITY

We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need-to-know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.

DATA RETENTION

How long will you use my information for?

Where you are a candidate for a job role, we will retain your personal data for a period of 168 months after we have communicated to you the decision about whether you will be appointed to a role. We retain your personal information for that period so that we can show, in the event of a legal claim, that we have not discriminated against candidates on prohibited grounds and that we have conducted the recruitment process in a fair and transparent way. After this period, we will securely destroy your personal data.

We will otherwise only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements.

We may wish to retain your personal data on file, on the basis that a further job opportunity may arise in future and we may wish to consider you for that. We do this because of the nature of our business. As a recruitment consultancy our relationship with you is one where we are aiming to seek employment on your behalf, therefore we may need to retain your personal data for the purposes of offering you the opportunity to apply for job opportunities arising in future, which match your criteria.

YOUR LEGAL RIGHTS

Your rights in connection with personal information

Under certain circumstances you have rights under data protection laws in relation to your personal data, as listed below. Please contact our DPO if you would like to exercise any of them. You have the right to:

• Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
• Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
• Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
• Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal data for direct marketing purposes.
• Request the restriction of processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
• Request the transfer of your personal data to another party. We will provide to you, or your chosen third party, your personal data in a structured, commonly used, machine-readable format. This only applies to automated information which you provided consent for us to use or necessary to perform a contract with you.

RIGHT TO WITHDRAW CONSENT

Where we are relying on consent to process your personal data, you can withdraw that consent at any time. This will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain services to you. We will advise you if this is the case, at the time you withdraw your consent.

EXERCISING YOUR RIGHTS

If you wish to exercise any of the rights set out above, please contact our DPO using the contact details at the start of this notice.

You will not have to pay a fee to access your personal data (or to exercise any of the other rigts). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask your for further information in relation to your request to speed up our response.

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.