This Privacy Notice tells you what to expect about 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 68-70 S Lambeth Rd, Vauxhall London, SW8 1RL is the Data Controller.
We acknowledge and agree that any personal data of yours that we handle will be processed by 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:
(B) Information with 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:
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 is 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:
The information under B above may be used as follows:
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 acts as a Data Processor in this capacity. For more information about our database provider, please email gdpr@thor-companies.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 a 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 to undertake pre-engagement checks for the role or for paying you.
No mobile information will be shared with third parties/affiliates for marketing/promotional purposes. All the above categories exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties.
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 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 are processed by us as we are legally obliged to do so. To pay you, where relevant, we are legally obliged to provide information to HMRC.
Once a position has been found for you, we will process your data, including financial information, for you entering into a contract to fulfil your role and to enable us to pay you, depending on the specific contractual arrangements and circumstances.
Thor Companies Ltd do not process High-Risk Special Category Data at this time however, should this ever change we will update our Privacy Policy and communicate this change to all affected Data Subjects.
YOUR RIGHTS
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, and 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 gdpr@thor-companies.com
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 object 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 with 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.
If you would like to request information, please email gdpr@thor-companies.com
RIGHT TO RECTIFICATION
If any of the data we hold on you is incorrect, please inform your Thor contact or gdpr@thor-companies.com 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 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 gdpr@thor-companies.com
RETENTION OF YOUR DATA
Your data will be retained for no longer than necessary and in accordance with our Data Retention Policy. Our criteria for retention varies depending on the information we hold and the relationship we have with you and rests upon the following; how long we have had an ongoing 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)
CONCERNS
If you have a concern about the way we are collecting or using your personal data, you should raise your concern with us in first instance at gdpr@thor-companies.com
As Thor Companies Ltd is Headquartered in the UK we hold ourselves accountable to the Information Commissioners Office which can be contacted at https://ico.org.uk/concerns
We ensure we are also compliant with 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/
CONTACT
Please address any questions, comments and requests regarding our data processing practices to our Compliance team at gdpr@thor-companies.com.
HOW WE USE COOKIES
A cookie is a small file which asks permission to be placed on your computer's hard drive. Once you agree, the file is added, and the cookie helps analyse web traffic or lets you know when you visit a particular site. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences.
We use traffic log cookies to identify which pages are being used. This helps us analyse data about web page traffic and improve our website to tailor it to customer needs. We only use this information for statistical analysis purposes and then the data is removed from the system.
Overall, cookies help us provide you with a better website, by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us. For more information please read our cookie policy
You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of the website.
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.