This Privacy Notice tells you what to expect in relation to personal information about you which is collected, handled and processed by Thor Companies Ltd and its subsidiary companies, Thor Life Sciences Ltd and Thor Companies Inc.
Thor Companies Ltd of Westminster Tower, 3 Albert Embankment, London SE1 7SP is the Data Controller.
We acknowledge and agree that any personal data of yours that we handle will be processed in accordance with all applicable data protection laws, which with effect from 25 May 2018, is the General Data Protection Regulations (“GDPR”).
THE INFORMATION WE MAY COLLECT
The information about you we may collect, hold and process is set out below:
(A) Information collected and processed for finding you a suitable role is as follows:
- Postal address
- Email address
- Telephone number
- CV & Work history
- References where applicable
- Job preferences including role, geographical areas and salary
- Any other work-related information you provide, for example, education or training certificates
- A log of our communications with you by email and telephone
(B) Information in respect to individuals that have worked for us previously or may work for us (either directly for Thor Companies Ltd or as a Contractor/Consultant in one of our Clients) is as follows:
- In some cases, permits and visas
- Date of Birth
- National insurance number
- Full details of job offer and placements
- Financial information (including but not limited to payroll details and terms, HMRC data, pension scheme details, court orders and statutory payments)
- A log of our communications with you by email and telephone
This information will have been provided, or will be provided, by you or a third party who we work with, such as a Job Board Company or another employment business or agency. In the case of references, these will be from your previous employer and will be limited to your capabilities without information classed as “Special Category” under the GDPR Regulations.
SPECIAL CATEGORY DATA
Thor Companies Ltd will not process any Special Category Data; this includes but it not limited to; race, ethnic origin, politics, religion, trade union membership, genetics, biometrics (where used for ID purposes), health, sex life or sexual orientation. We advise that any information you provide us that falls within this category is removed from all written communication, including your CV, cover letters and email communication.
HOW WE USE THE INFORMATION
The above information is used to provide our services to you in our capacity as an employment business / agency to find you suitable work whether on a temporary or permanent basis based on your requirements as set out below.
The information under A above may be used as follows:
- To match your skill sets with job vacancies to assist in finding you the positions that most suit you
- To put forward your details to our clients and prospective employers for you to be considered for vacancies
- To place you with our clients and prospective employers
- To keep you informed of available opportunities as they arise
- To keep you informed of the services offered by Thor Companies Ltd
The information under B above may be used as follows:
- To establish that you have the right to work
- To put in place contractual arrangements and documentation once a role has been secured
- To pay you if placed
Thor Companies Ltd does not send mass marketing, however we may on occasion send you information on roles we have available, events we are attending or hosting or other information relevant to our recruitment business. If you do not wish to receive this information you must notify us in writing as described in the “Your Rights” section.
HOW WE HOLD YOUR DATA
All the personal data we have is stored on our secured database in the UK; our database provider act as a Data Processor in this capacity. For more information about our database provider, please email email@example.com
DISCLOSURE OF YOUR INFORMATION
Your CV and related information will be shared or sent to prospective employers and our clients with your permission. Once you have secured a placement, additional information will be provided to them to enable the placement to proceed. Such employers and clients will usually be located inside the European Economic Area (EEA) but may be outside of the EEA.
Personal data shall not be transferred to a country or territory outside the EEA unless that country or territory ensures an adequate level of protection or the appropriate safeguards are in place for your rights and freedoms. In case of transfer of personal information from EU/EEA to third party outside the EEA, we will be entering into EU Standard Contractual Clauses with that third party. Further details of EU Standard Contractual Clauses can be found here
Other trusted third parties that we may share your data with are as follows: HM Revenue and Customs, Pension scheme providers, legal advisors and other companies for the purpose of undertaking pre-engagement checks for the role or for paying you.
OUR LEGAL BASIS FOR PROCESSING YOUR INFORMATION
Thor Companies Ltd processes all low risk information in sections A and B above under the Legitimate Interest basis supplied by Article 6(1)(f) of the GDPR.
“processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child.”
We have performed a Legitimate Interest Assessment, details of which will be supplied if requested, and have found this to be a lawful and reasonable basis for the processing of personal data. Using your personal information helps us to operate and improve our employment business, ensures we are working with the most up to date market information and allows us to provide a quality service to both our candidates and clients.
Moderate Risk Information and documentation to establish your right to work is processed by us as we are legally obliged to do so. For the purposes of paying you, where relevant, we are legally obliged to provide information to HMRC.
Once a position has been found for you, we will process your personal data, including financial information, for the purpose of you entering into a contract to fulfil your role and to enable us to pay you, depending on the specific contractual arrangements and circumstances.
RIGHT TO BE INFORMED
Thor Companies Ltd will make a sustained effort to inform you of the data we hold on your behalf; our methods will include verbal notification when we speak with you on the telephone and written notification which will include explicit email correspondence and this Privacy Statement which we will publish on our website and social media.
RIGHT TO OBJECT TO DIRECT MARKETING
You have the right to object to, and therefore be removed from, direct marketing from Thor Companies Ltd. Direct marketing could include the following; notifications about roles we are working on, notifications on events we are attending or hosting, relevant industry news. We do not send mass marketing and will endeavour to only send information you have stated is relevant and interesting to you.
To update your marketing preferences please email us on firstname.lastname@example.org
RIGHT TO OBJECT TO PROCESSING OF INFORMATION ON LEGITIMATE INTEREST GROUNDS
You have the right to object to our processing of your data under Legitimate Interest; please raise this objection with us in writing. Thor Companies Ltd has the right to refuse an objection on the following basis; where the information is held for contractual reasons, where the information is held pending legal action, or where the information held does not cause substantial damage or distress to the data subject.
If you chose to raise an objection in writing, we will consider the balance of interests and will report back to you on our decision within 30 working days. If you are not satisfied by our response you have the right to complain to our governing authority, the ICO.
RIGHT OF ACCESS
You have the right at any time to ask for a copy of the information about you that we hold. Thor Companies Ltd will provide a report detailing this information within 1 month of the request, as per GDPR regulations.
If you would like to make a request for information, please email email@example.com
RIGHT TO RECITIFICATION
If any of the data we hold on you is incorrect, please inform your Thor contact, or firstname.lastname@example.org and we will rectify this immediately. Thor Companies Ltd will do everything within its power, and with proportionate effort, to ensure that data is accurate and up to date.
RIGHT TO ERASURE
Under GDPR individuals have the right to request their personal details are erased; this can be done verbally or in writing. Thor Companies Ltd will respond to each request within 1 month of receiving it with the process we will take to ensure this right is upheld.
For more information, please email email@example.com
RETENTION OF YOUR DATA
Your data will be retained for no longer than is necessary and in accordance with our Data Retention Policy. Our criteria for retention varies dependant on the information we hold and the relationship we have with you and rests upon the following; how long we have had an on-going relationship with you, the average length of time spent in 1 role within your industry/role, if we have any legal obligations requiring your data, if retention is required to establish our legal position (e.g. statute of limitations, litigation etc)
If you have a concern about the way we are collecting or using your personal data, you should raise your concern with us in the first instance at firstname.lastname@example.org
As Thor Companies Ltd is Headquartered in the UK we hold ourselves accountable to the Information Commissioners Office who can be contacted at https://ico.org.uk/concerns
We ensure we are also compliant to the Swedish and Danish counterparts;
Sweden: Datainspektionen – Swedish Data Protection Authority https://www.datainspektionen.se/
Denmark: Datailsynet – Danish Data Protection Authority http://www.datatilsynet.dk/fejl/
Please address any questions, comments and requests regarding our data processing practices to Alexandra Aldhous, our Compliance and Assurance Associate, at email@example.com or firstname.lastname@example.org
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LINKS TO OTHER WEBSITES
Our website may contain links to other websites of interest. However, once you have used these links to leave our site, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this privacy statement. You should exercise caution and look at the privacy statement applicable to the website in question.
CHANGES TO THE PRIVACY NOTICE
This Privacy Notice may be changed by us at any time. We will notify you of changes: e.g. by posting the change on our website and social media, sending you a message through a secure channel, or any other reasonable means.