Elements Privacy Policy

General

Elements Talent Consultancy (Elements) is the Data Controller of the personal data you provide to us or that we receive. Elements is a UK registered company, number 06981002, and our registered address is 32 Jamestown Road, Camden, London. NW1 7BY.

At Elements, the privacy and security of your personal data is our priority. We want to be transparent around the personal data we gather, where we find this information, how we use and store this data, and how we share. We will also outline the controls we have in place to keep your information secure and the choices you have around when and how you choose to share your personal data. 

 

Who We Are  

We are a talent acquisition consultancy that helps our partners solve some of the most complex and challenging hiring missions. To do this, we collect personal data from the following types of people to allow us to undertake our business and to source candidates for our partners:

– Prospective and placed candidates for permanent and contract roles

– Prospective and live partner contacts

– Supplier contacts to support our services

– Employees, consultants, temporary workers

 

Legal Basis for Processing

Our legal basis for personal data processing is our legitimate business interests, described in more detail below. However, we will also rely on contract, legal obligation and consent for specific uses of data.

We will rely on contractual provisions if there is a legal document between the parties. We will rely on legal obligation if we are legally required to hold information on you to fulfil our legal obligations.

We will, in some circumstances, rely on consent for particular uses of your data, and you will be asked for your express consent if legally required. Examples of when consent may be the lawful basis for processing include permission to introduce you to a third party.

 

Legitimate Interests

At Elements, we take your privacy seriously and will only use your personal information for administration purposes to provide our talent acquisition services. The information we have collected is used to deliver our services to our partners in our capacity as a talent acquisition consultancy. 

We think it’s reasonable to expect that, if you are looking for employment or have posted your professional CV information on a job board or professional networking site, you recognise that it is fair to collect that public information and otherwise use your personal data to provide our services. We use that data; to approach you as an onsite recruiter, to share that information with prospective employers, to ensure we source candidates equitably and to assess your skills against our live vacancies. During the job offer process, your potential employer may want to confirm your references, qualifications, right to work and criminal record, which we will follow according to the laws and regulations.

Therefore, we think it’s reasonable for us to process your data and contact you to propose relevant roles or available opportunities.

We may also need to use your data for our internal administrative activities.

 

Data Storage and Processing

All of the personal data we hold about you will be processed consistent with EU data protection legislation and, in particular, the GDPR. We take all reasonable steps to ensure that your personal data is processed securely and prevent unauthorised access to and misuse your personal data. 

 

Types of Data We Collect 

To enable us to provide the best possible service to our partners, we need to process certain information for our own internal hiring processes and employment at Elements. 

Dependent on why we are processing your personal data, we may collect, hold and process a range of information about you. This includes:

– Your name, address and contact details, including email address and telephone number;

– Details of your qualifications, skills, experience and employment history

– Information about your entitlement to work

– References 

– Links to technical or corporate online profiles such as Linkedin 

– Other relevant information you may choose to share, primary reasons why you may or may not be interested in roles, alongside your job requirements

– Diversity indicators for the following reasons:

– when required by Talent Partners,

– to ensure transparency & fairness in the hiring process,

– to understand the demographics of the talent available and

– to deduce the diversity of our Partners companies and their peers.

As a global consultancy, per local laws and requirements, we may also collect information about country-specific diversity, security clearance status or details of any criminal convictions.

If you are an Elements Partner, we need to collect and use information about you, or individuals at your organisation, in the course of providing you with our talent acquisition services. This can include finding candidates to fill your roles, providing you with our services or notifying you of content published by Elements that may be relevant to you. 

Elements will also, per data protection laws, store information relating to previous dealings with us, including job applications, email and telephone communications, job interviews and placements.

We collect a limited amount of data from our website’s users, which we use to improve your experience when using our website and help us manage the services we provide. This includes information such as how you use our website, the most popular referrers and website responsiveness. 

 

Where We Find Your Information 

We may obtain candidate information from any number of locations:

– When you register or apply for jobs

– When you correspond with us by phone, email or otherwise

– When you visit our website

– When you register your CV on a job board, and it matches specific criteria

– When you apply for a role via a job board

– When you are referred by a friend or colleague

– Through your online profiles 

When we obtain your information from external sources such as LinkedIn, corporate websites and job boards, we will contact you within a reasonable timeframe to ensure that our services are appropriate or relevant to you.

There are two main ways in which we collect partner data:

– Directly from you

– Third parties such as candidates, employee recommendations, online search engines, online job boards, industry forums, LinkedIn and networking.

We collect employee data in the public domain to help partners gauge diversity within their own companies and how they relate to their peers. We use code to deduce diversity initially created by the University of Chicago to create fairness in social processes. We are working to improve the code and corroborate this data with publicly available diversity datasets.

 

Data Retention 

The length of time we will hold or store your personal information will depend on the services we perform for you and how long you require them. We conduct regular data-cleansing and updating exercises with our candidates to ensure that (i) the data that we hold is accurate, (ii) we are not holding information for too long and (iii) the data remains relevant for the purposes for which it was collected.

We will consider there to be meaningful contact with you if you submit your updated CV onto our website, apply for jobs or receive an updated CV from a job board. We will also consider it meaningful contact if you communicate with us about potential roles, either by verbal or written communication or engage with any of our marketing communications.

Under new data protection regulations (GDPR), we must keep the data we hold accurate and, where necessary, up to date. As such, we will make an effort to regularly communicate with you to ensure your information is up to date and accurate. We endeavour to permanently erase your personal data on the expiration of the retention period or where we receive a valid request from you to do so. For a list of all data categories and retention periods, please contact privacy@weareelements.io

 

Data Sharing

As required under GDPR, we will only share your information with the particular partner who approached or, to the extent appropriate, with prospective employers.

Unless you specify otherwise, we may also share your information with any of our group companies and associated third parties, such as our service providers, where we feel this will help us to provide you with the best possible service. We have the appropriate processing agreement in place.

Embedded Partners

We will obtain and control your information with our partners to operate or act as an internal onsite talent acquisition function.

Trusted Third Parties

We will share your personal information and, where necessary, your sensitive personal data with trusted third parties where we have retained them to provide services that you or our partners have requested, such as:

– employment reference checking

– qualification checking

– criminal reference checking

– verification of details you have provided from third party sources

– psychometric evaluations or skills tests

We will also share your personal information with third parties who perform functions on our behalf and provide services:

– professional advisors

– data analytics providers

– IT consultants carrying out testing and development work on our business technology systems

– research and mailing houses

– function co-ordinators

We require minimum standards of confidentiality and data protection from such third parties. To the extent that any personal information is provided to third parties outside the EEA or who will access the information from outside the EEA, we will ensure that approved safeguards are in place, such as the approved Model Clauses or the EU/US Privacy Shield.

 

Your Rights with Regards to Your Information

You have certain rights concerning the personal information we hold about you. Details of these rights and how to exercise them are set out below. We will require evidence of your identity before we can act on your request.

You have the right at any time to ask us for a copy of the personal information about you that we hold. We would need you to provide your professional social media profile(s) profile to trace you uniquely. Where we have a good reason, and if the GDPR permits, we can refuse your request for a copy of your personal information or some aspects of the request. If we deny your request or any element of it, we will provide you with our reasons for doing so.

Right to Object
You have a legal right to object at any time to:

– use of your personal information for direct marketing purposes; and

– processing of your personal data, which is based on our legitimate interests, unless there is a compelling legitimate ground for our continued processing.

Right of Correction or Completion
If personal information we hold about you is not accurate, out of date or incomplete, you have a right to have the data rectified, updated or completed. You can let us know by contacting us at privacy@weareelements.com.

Right of Erasure
In certain circumstances, you have the right to request that personal information we hold about you is erased, and there are no other legal grounds on which we may process the information.

Right to Object to or Restrict Processing
In certain circumstances, you have the right to object to our processing of your personal information by contacting us at privacy@weareelements.com. For example, if we are processing your information based on our legitimate interests, and there are no compelling legitimate grounds for our processing that override your rights and interests. You also have the right to object to the use of your personal information for direct marketing purposes.

You may also have the right to restrict our use of your personal information. Such as in circumstances where you have challenged the accuracy of the information and during the period where we are verifying its accuracy.

Right of Data Portability
In certain instances, you have a right to receive any personal information that we hold about you in a structured, commonly used and machine-readable format. You can ask us to transmit that information to you or directly to a third-party organisation.
The above right exists only in respect of personal information that:

– you have provided to us previously; and

– is processed by us using automated means.

Please note we cannot guarantee technical compatibility with a third party organisation’s systems. In certain circumstances, we may be unable to comply with requests related to others’ personal information without their consent.

You can exercise any of the above rights by contacting us using any of the methods identified in this Privacy Notice. Please be aware that most of the above rights are subject to limitations and exceptions. We will provide reasons if we are unable to comply with any request to exercise your rights.

 

Data Subject Access Requests

You may ask us to confirm what information we hold about you and request us to modify, update or delete such information if you wish to access your data at any time. In that case, there will be no administration charge, and the request will be fulfilled as set out in the relevant data protection legislation appropriate to the jurisdiction. To make such a request, please email privacy@weareelements.com.

 

Marketing Consent

From time to time, we would like to send you details of reports, promotions, offers, networking and client events, and general information about the industry sectors we think might interest you. We will only contact you for marketing purposes if you have consented though should you receive any material in error, please email privacy@weareelements.com.

 

Changes to our Privacy Notice

Any changes we make to our privacy notice in the future will be posted on this page and, where appropriate, notified to you by email. Please check back frequently to see any updates or changes to our privacy notice.

 

Regulatory and Law Enforcement Agencies

If we receive a request from a regulatory body or law enforcement agency and, if permitted under GDPR or other applicable laws, we may disclose specific personal information to such bodies or agencies.

 

Concerns

If you are concerned about how we are collecting or using your personal data, you should raise your concern with us in the first instance. If you are unhappy with how we have used your data, you can also inform the Information Commissioner’s Office. The ICO’s address is Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF. Helpline number: 0303 123 1113 https://ico.org.uk/make-a-complaint.

 

Contact

Please address any questions, comments and requests regarding our data processing practices to privacy@weareelements.com.