Privacy Policy

Introduction

Mentmore Recruitment Limited (“Mentmore”, “we”, “us” or “our”) is committed to protecting your privacy and handling your personal data fairly, lawfully, and transparently.

This privacy notice explains how we collect, use, store, share and protect personal data about candidates for permanent, temporary or contractor roles; contractors and individuals we place or engage; referees, emergency contacts and other individuals whose details are provided to us; client contacts, supplier contacts and other business contacts; and visitors to our website at www.mentmore.com.

For the purposes of UK data protection law, including the UK General Data Protection Regulation (“UK GDPR”) and the Data Protection Act 2018, Mentmore is usually the data controller of the personal data described in this notice. This means we decide why and how your personal data is processed.

Mentmore Recruitment Limited
2nd Floor, 86-90 Paul Street
London
EC2A 4NE
Telephone: 0203 817 3250
Website: www.mentmore.com
Company number: 09935362
ICO registration number:

We have appointed a data protection manager responsible for data protection matters within the business.

Data Protection Manager:

Simon Butler
Email: Simon.butler@mentmore.com
Telephone: 0203 817 3250

Please contact the Data Protection Manager if you have any questions about this privacy notice or how we handle your personal data 

Personal data we may collect 

We may collect and use the following types of personal data:

• name;
• address;
• email address;
• telephone number;
• date of birth, where required;
• gender, where relevant and lawful;
• CV, work history and employment history;
• education, qualifications, skills and professional memberships;
• job preferences, salary expectations, benefits expectations, location preferences and availability;
• current and previous salary or rate information, where relevant;
• interview notes, assessment results and feedback;
• right-to-work information and documents;
• nationality, immigration status and visa information, where required for right-to-work checks;
• references and referee details;
• copies of communications between you and us;
• information from job boards, LinkedIn and other professional networking sites;
• information from publicly available sources;
• client feedback and information about roles we have discussed with you;
• payroll, tax, timesheet, invoicing and payment information, where relevant to contractor roles;
• compliance information required by law or by our clients;
• marketing preferences and communication preferences;
• records of your consent, objections or opt-outs.
• emergency contact details,
• bank details
• umbrella company details
• background check results
• criminal record information, psychometric testing results, technical test results
• passport copies, proof of address, references.

Special category data

“Special category data” is more sensitive personal data, such as information about health, disability, race or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data used for identification, sex life or sexual orientation.

We do not routinely ask candidates to provide special category data unless it is necessary and lawful to do so.

However, we may process special category data where:

• you voluntarily include it in your CV or communications with us;
• you tell us about a health condition, disability or reasonable adjustment requirement;
• we need to process diversity or equal opportunities information;
• it is necessary for employment, social security or social protection purposes;
• it is necessary to establish, exercise or defend legal claims;
• we are otherwise permitted or required to do so by law.

Criminal offence data

We will only process criminal offence data where it is lawful for us to do so. This may include where a client, role, law or regulatory requirement requires criminal record checks or other background screening.

Client, supplier and business contacts

If you are a client contact, supplier contact, referee or other business contact, we may collect:

• name;
• job title;
• employer or organisation;
• work address;
• work email address;
• work telephone number;
• communications with us;
• contract, billing and payment-related information;
• records of meetings, instructions, services and business arrangements.

Website visitors

When you use our website, we may collect:

• IP address;
• browser type and version;
• device information;
• operating system;
• pages viewed;
• dates and times of visits;
• referral source;
• cookie and tracking information;
• information submitted through website forms.
• website analytics tools, cookies, CRM tracking, marketing pixels, embedded content, job alert tools and form providers used
•  

How we collect personal data

• We may collect personal data from:
• you directly, including when you send us your CV, apply for a role, complete a form, speak to us, email us or otherwise communicate with us;
• job boards and recruitment platforms;
• LinkedIn and other professional networking sites;
• publicly available sources;
• referrals from candidates, clients, contacts or other third parties;
• our clients and prospective employers;
• referees;
• background check providers, where relevant;
• umbrella companies, payroll providers or contractor management providers, where relevant;
• suppliers and service providers;
• our website and cookies.
• Where you provide us with personal data about another person, such as a referee or emergency contact, you should ensure that they are aware that you have given us their details and that they understand how we may use their personal data.

Why we use personal data

• We use candidate and contractor personal data to:
• assess your suitability for roles;
• contact you about suitable vacancies;
• discuss your experience, skills, preferences and availability;
• match you with permanent, temporary or contractor opportunities;
• introduce you to clients and prospective employers;
• arrange interviews and assessments;
• obtain feedback from clients;
• negotiate offers, rates, salaries and other terms;
• manage placements and assignments;
• keep records of our recruitment activity;
• maintain our candidate database;
• provide relevant job recommendations and recruitment-related communications.

Contractor and placement administration

• Where relevant, we use personal data to:
• onboard contractors;
• carry out right-to-work and compliance checks;
• manage timesheets;
• process payments, invoices, payroll and tax-related information;
• liaise with umbrella companies, payroll providers, clients and other relevant parties;
• administer contracts and assignments;
• comply with legal, tax, accounting and reporting obligations.
• 3 Client, supplier and business relationship management
• We use client, supplier and business contact data to manage our relationship with clients, suppliers and business partners; provide recruitment services; receive services from suppliers; negotiate, enter into and perform contracts; manage billing, payment and accounting; maintain business records; and respond to enquiries and communications.

Website and communications

We use website and communications data to operate and improve our website; respond to enquiries submitted through the website; understand how visitors use our website; maintain website security; manage cookies and similar technologies; send relevant updates, where lawful; and improve our services and user experience.

Legal, compliance and business protection

We may use personal data to comply with legal and regulatory obligations; verify identity and right to work; prevent fraud and misuse of our services; establish, exercise or defend legal claims; respond to data protection requests; investigate complaints; maintain appropriate business records; and protect our business, systems, staff, candidates, clients and suppliers.

Lawful bases for using personal data

We only use personal data where we have a lawful basis under UK data protection law. The lawful bases we may rely on include consent, contract, legal obligation, legitimate interests, vital interests and public task, where applicable.

Legitimate interests

Where we rely on legitimate interests, our interests may include providing recruitment services to candidates and clients; helping candidates find suitable roles; helping clients identify suitable candidates; maintaining an up-to-date candidate database; managing our business relationships; operating as a commercial recruitment business; improving our services and website; keeping appropriate business records; protecting our legal rights and business interests; and ensuring our systems and services are secure.

Before relying on legitimate interests, we consider whether the processing is necessary and whether your interests, rights and freedoms override our interests. You have the right to object to processing based on legitimate interests. Please see section 15 below.

Consent

Where we rely on your consent, you have the right to withdraw that consent at any time. You can do this by contacting the Data Protection Manager or the consultant you have been dealing with.

Withdrawing consent will not affect the lawfulness of processing carried out before you withdrew your consent. In some circumstances, we may continue to process your personal data where we have another lawful basis for doing so.

Special category and criminal offence data

Where we process special category data, we will only do so where we have both a lawful basis under Article 6 of the UK GDPR and a special category condition under Article 9 of the UK GDPR.

Depending on the circumstances, we may rely on one or more of the following conditions: employment, social security and social protection law; substantial public interest, where applicable; explicit consent; legal claims; or processing of data made manifestly public by you.

Where we process criminal offence data, we will only do so where permitted by UK data protection law and where we have an appropriate condition under the Data Protection Act 2018.

Who we share personal data with

• We may share personal data with the following categories of recipients where lawful and appropriate:
• clients and prospective employers;
• hiring managers and interviewers;
• payroll providers;
• umbrella companies;
• background check providers;
• right-to-work verification providers;
• referees;
• job boards and recruitment platforms;
• customer relationship management and applicant tracking system providers;
• IT, hosting, email and cloud service providers;
• website, analytics and cookie providers;
• accountants, auditors, insurers, banks and professional advisers;
• legal advisers;
• government bodies, regulators, tax authorities and law enforcement agencies;
• other third parties where required by law or where necessary to protect our legal rights.
• payroll provider, website host, analytics provider, email provider, cloud storage provider, job board integrations

We require service providers acting as our processors to protect personal data and only process it in accordance with our instructions. Some third parties may act as independent controllers of personal data, in which case they are responsible for their own compliance with data protection law. We do not sell personal data.

International transfers

We may transfer personal data outside the United Kingdom where necessary for the purposes described in this notice. This may happen, for example, where our service providers, cloud systems, recruitment platforms or other technology providers process data outside the UK.

Where we transfer personal data outside the UK, we will ensure that appropriate safeguards are in place. These may include transferring data to a country covered by UK adequacy regulations; using the UK International Data Transfer Agreement; using the UK Addendum to the EU Standard Contractual Clauses; or relying on another lawful transfer mechanism under UK data protection law.

How long we keep personal data

We only keep personal data for as long as necessary for the purposes for which it was collected, including legal, accounting, reporting and compliance purposes. Our retention periods vary depending on the type of data and the reason we hold it.

When deciding how long to keep personal data, we consider the amount, nature and sensitivity of the data; the purposes for which we use it; whether we can achieve those purposes in another way; legal, regulatory, tax and accounting requirements; the risk of harm from unauthorised use or disclosure; and limitation periods for legal claims.

At the end of the relevant retention period, we will delete, anonymise or securely archive personal data.

Accuracy of your personal data

It is important that the personal data we hold about you is accurate and up to date. Please let us know if your personal data changes during your relationship with us.

Cookies and website technologies

Our website uses cookies and similar technologies. Cookies are small files placed on your device that help websites work, improve user experience and provide information to website operators.

We may use cookies and similar technologies to operate essential website functions; keep the website secure; remember user preferences; understand how visitors use our website; improve website performance; support recruitment enquiries and job applications; and measure the effectiveness of our content or communications.

Some cookies are essential and do not require consent. Where required by law, we will ask for your consent before placing non-essential cookies, such as analytics or marketing cookies.

Security

We have put in place appropriate technical and organisational measures to protect personal data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure or access.

These measures may include access controls; password and authentication controls; secure storage systems; staff confidentiality obligations; staff data protection training; data processor due diligence; secure disposal procedures; incident response procedures; and regular review of security arrangements.

Although no method of transmission over the internet is completely secure, we take reasonable steps to protect personal data and maintain the confidentiality, integrity and availability of our systems.

We have procedures in place to deal with suspected personal data breaches and will notify affected individuals and the Information Commissioner’s Office where legally required.

Your data protection rights

Under UK data protection law, you may have the following rights, depending on the circumstances:

• Right of access — to request a copy of the personal data we hold about you.
• Right to rectification — to ask us to correct inaccurate or incomplete personal data.
• Right to erasure — to ask us to delete your personal data in certain circumstances.
• Right to restriction — to ask us to restrict how we use your personal data in certain circumstances.
• Right to object — to object to processing based on legitimate interests, including profiling based on legitimate interests.
• Right to object to direct marketing — to object to direct marketing at any time.
• Right to data portability — to receive certain personal data in a structured, commonly used and machine-readable format, where this right applies.
• Right to withdraw consent — where we rely on consent, to withdraw that consent at any time.
• Rights relating to automated decision-making — to ask for human involvement or challenge certain decisions made solely by automated means, where this applies.

To exercise your rights, please contact the Data Protection Manager using the contact details in section 1.

We may need to ask you for information to confirm your identity before responding to your request. This helps us protect personal data and ensure it is not disclosed to someone who is not entitled to receive it.

You will not usually have to pay a fee to exercise your rights. However, we may charge a reasonable fee or refuse to comply with a request where the law allows us to do so, for example if a request is manifestly unfounded or excessive.

Automated decision-making, profiling, and AI

We do not make recruitment decisions about candidates based solely on automated decision making. We do not use automated systems to make final decisions about whether candidates are suitable for roles without human involvement.

We may use recruitment systems to help us search, sort, store or manage candidate information, but our consultants are involved in recruitment decisions and candidate recommendations.

Marketing communications

We may send candidates, clients and business contacts relevant communications about roles, recruitment services, market updates or related information where permitted by law.

You can opt out of marketing communications at any time by using the unsubscribe link in our emails, where provided; contacting your Mentmore consultant; or contacting the Data Protection Manager.

We will keep a record of your marketing preferences to ensure that we respect your choices.

Complaints

We take privacy complaints seriously. If you have a concern about how we handle your personal data, please contact our Data Protection Manager first so that we can try to resolve it.

You can contact the Data Protection Manager at:

Simon Butler
Email: Simon.butler@mentmore.com
Telephone: 0203 817 3250

We will acknowledge data protection complaints within the timeframe required by law and will respond without undue delay.

You also have the right to complain to the Information Commissioner’s Office, the UK data protection regulator.

Information Commissioner’s Office
Website: www.ico.org.uk
Telephone: 0303 123 1113

You are free to contact the ICO at any time, although we would appreciate the opportunity to deal with your concern first.

Links to other websites

Our website may contain links to other websites. We are not responsible for the privacy practices, content or security of those websites. You should read the privacy notices of any third-party websites you visit.

Changes to this privacy notice

We may update this privacy notice from time to time. The latest version will be published on our website. Where changes are significant, we may take additional steps to bring them to your attention.

Contact us

If you have any questions about this privacy notice or how we use personal data, please contact:

Simon Butler
Mentmore Recruitment Limited
2nd Floor, 86-90 Paul Street
London
EC2A 4NE
Email: Simon.butler@mentmore.com
Telephone: 0203 817 3250