Privacy and Data Protection Policy
Minerva Appointments Ltd are a recruitment business who provides work-finding services to its Clients and Candidates. Minerva Appointments Ltd must process personal data (including sensitive personal data) so that it can provide these services – in doing so, Minerva Appointments Ltd act as a data controller.
You may give your personal details to Minerva Appointments Ltd directly, such as on an application, on a registration form, via our website, or we may collect them from another source such as a job board. Minerva Appointments Ltd must have a legal basis for processing your personal data.
Minerva Appointments Ltd processes personal data in relation to its own staff, Candidates and individual Client contacts and is a data controller for the purposes of the Data Protection Laws. Minerva Appointments Ltd is registered with the ICO and its registration number is Z8787392.
Collection and use of personal data:
Purpose of processing and legal basis:
Minerva Appointments Ltd has collected your personal data (which may include sensitive personal data) and will process your personal data for the purposes of providing you with work-finding services. This includes for example, contacting you about job opportunities, assessing your suitability for those opportunities, updating our databases, putting you forward for job opportunities, arranging payments to you and developing and managing our services and relationship with you and our Clients.
In some cases we may be required to use your data for the purpose of investigating, reporting and detecting crime and also to comply with laws that apply to us. We may also use your information during the course of internal audits to demonstrate our compliance with certain industry standards.
The Company may hold personal data on individuals for the following purposes:
- Staff administration.
- Advertising, marketing and public relations.
- Accounts and records.
- Administration and processing of Candidates personal data for the purposes of providing work-finding services, including processing using software solution providers and back office support.
- Administration and processing of Clients' personal data for the purposes of supplying / introducing Candidates.
The legal bases we rely upon to offer these services to you are:
- Your consent.
- Where we have a legitimate interest.
- To comply with a legal obligation that we have.
- To fulfil a contractual obligation that we have with you.
We will collect your personal data from you in various ways:
- Job applications.
- Directly from you i.e. if you call or email one of our offices.
- The Minerva Appointments Ltd website.
- From Social Media (i.e. Linkedin).
- Referred from one of our Clients.
- An uploaded CV onto a Job Site that we subscribe to.
Minerva Appointments Ltd has a legitimate reason to process your data provided it is reasonable and does not go against what you would reasonably expect from us. Where Minerva Appointments Ltd has relied on a legitimate interest to process your personal data our legitimate interests is / are as follows:
- We believe that processing your personal data means that we can continue to provide you with our Recruitment Services.
- Managing our database and keeping Candidates records up to date.
- Contacting the Candidates to seek your consent where we need it.
- Providing work-finding services to the Candidate, including sending your information to our Clients where they have demonstrated an interest in doing that particular type of work but not expressly consented to you passing on your CV.
- Contacting the Candidate with information about similar types of work.
- Passing Candidates information on to debt collection agencies.
- You have the right to object to us processing your personal data on this basis.
Recipient / s of data:
Minerva Appointments Ltd will process your personal data and / or sensitive personal data with the following recipients in order to provide work finding services:
- Clients that we introduce or supply Candidates to.
- Candidates' former or prospective new employers that we obtain or provide references to.
- The Recruitment and Employment Confederation (and any other trade body that we are a member of who may have access to our candidates' data).
- Any other third parties who carry out audits to ensure that we run our business correctly.
- Any umbrella companies that we pass candidate data to.
- Other recruitment agencies in the supply chain (e.g. master / neutral vendors and second tier suppliers).
- Our Accounts.
- Our insurers.
- Our legal advisers.
- Social networks.
- Our IT and CRM providers.
- Any public information sources and third party organisations that we may use to carry out suitability checks on work-seekers e.g. Companies House, the Disclosure and Barring Service (DBS), National College for Teaching and Leadership (NCTL), DVLA, Industry Institutes, Government law enforcement agencies and other regulators e.g the Police, Home Office, HMRC, Employment Agencies Standards Inspectorate (EASI), Local Authority Designated Officers (LADOs), GLAA, and Trade unions.
- Any other organisations you ask us to share your data with.
- The Company will not transfer the information you provide to us to countries outside the European Economic Area (‘EEA') for the purposes of providing you with work-finding services. The EEA comprises the EU member states plus Norway, Iceland and Liechtenstein.
The Company will retain your personal data only for as long as is necessary for the purpose we collect it. Different laws may also require us to keep different data for different periods of time.
The Conduct of Employment Agencies and Employment Businesses Regulations 2003, require us to keep work-seeker records for at least one year from (a) the date of their creation or (b) after the date on which we last provide you with work-finding services.
We must also keep your payroll records, holiday pay, sick pay and pensions auto-enrolment records for as long as is legally required by HMRC and associated national minimum wage, social security and tax legislation.
By registering your details with Minerva Appointments Ltd by way of:
Online registration via the Company's website
Directly contacting the Company by any other means, electronically or otherwise
Via the Company accessing your details via Job Boards for the purpose of providing work seeking services
You are deemed to have given consent to the Company to process your personal and sensitive data, we will do so in line with our retention policy. Upon expiry of that period Minerva Appointments will seek further consent from you. Where consent is not granted Minerva Appointments Ltd will cease to process your personal data.
Please be aware that you have the following data protection rights:
- The right to be informed about the personal data Minerva Appointments Ltd processes on you.
- The right of access to the personal data the Minerva Appointments Ltd processes on you.
- The right to rectification of your personal data.
- The right to erasure of your personal data in certain circumstances.
- The right to restrict processing of your personal data.
- The right to data portability in certain circumstances.
- The right to object to the processing of your personal data that was based on a public or legitimate interest.
- The right not to be subjected to automated decision making and profiling.
- The right to withdraw consent at any time.
You have the right to withdraw your consent at any time by contacting firstname.lastname@example.org
There may be circumstances where Minerva Appointments Ltd will still need to process your data for legal or official reasons. We will inform you if this is the case. Where this is the case, we will restrict the data to only what is necessary for the purpose of meeting those specific reasons.
If you believe that any of your data that Minerva Appointments Ltd processes is incorrect or incomplete, please contact us using the details above and we will take reasonable steps to check its accuracy and correct it where necessary.
You can also contact us using the above details if you want us to restrict the type or amount of data we process for you, access your personal data or exercise any of the other rights listed above.
Complaints or queries:
If you wish to complain about this privacy notice or any of the procedures set out in it please contact email@example.com
You also have the right to raise concerns with Information Commissioner's Office on 0303 123 1113 or at https://ico.org.uk/concerns/, or any other relevant supervisory authority should your personal data be processed outside of the UK, if you believe that your data protection rights have not been adhered to.
We are committed to providing users of this website with a safe and secure service. Please take the time to read and understand our Privacy Statement, which outlines how your personal information is treated. This should be read in conjunction with Minerva Appointments Limited Terms & Conditions of Use.
Aggregate Information about Visitors
Minerva Appointments Limited uses IP addresses and will collect demographic data provided by registered users to analyse trends, administer the site and track users' movement patterns for aggregate use. Minerva Appointments Limited will only disclose data and statistics to third parties in aggregate form and will not include any personally identifiable information. Minerva Appointments Limited will follow the appropriate legal requirements and take all reasonable precautions to ensure only satisfactory third parties see the information. However, Minerva Appointments Limited are not responsible for any breach of security or any actions of third parties who receive the information.
Information we collect about you and how we use it
When you register online at Minerva Appointments Limited we collect personal information about you, including your name, phone number, email address and job search preferences. This data is held in our central recruitment database for the following business purposes:
- To assist Minerva Appointments Limited recruitment staff in finding you a new job
- To keep you informed of new jobs matching your criteria via available channels of communications
- To facilitate your personal use of our online service
- To track activity and trends on the website in order to improve usefulness and content
- To advise you of new developments, products and services from Minerva Appointments Limited and other companies that may be of interest to you
Personal information provided by you is retained as long as the purpose for which the data was collected continues. It is then archived or destroyed unless its retention is required to satisfy audit, legal, regulatory or accounting requirements or to protect Minerva Appointments Limited interests. Minerva Appointments Limited will not sell, trade or rent your personal information to others unless you have given us your permission.
Minerva Appointments Limited is registered as a data controller with the office of the Data Protection Commission. Details of our company registration can be viewed by visiting Companies House.
Curriculum Vitae (CV)
Minerva Appointments Limited give you the option to submit your CV using this website. Your CV and all personal information provided by you is stored on our central recruitment database and is accessible by Minerva Appointments Limited's Recruitment Consultants, working inside the European Union.
Minerva Appointments Limited will use our best efforts to ensure that your CV and/or personal information is not submitted to any third parties, until we have received oral or written communication from you.
The information contained in your CV may be summarised by Minerva Appointments Limited before submitting it to a prospective employer. By logging into your account at Minerva Appointments Limited you have the facility to update your CV at any time.
Minerva Appointments Limited will take every precaution to protect your personal information. All personal information entered on Minerva Appointments Limited is protected using a secure server. When you enter a page protected by the secure server a padlock icon will be displayed at the foot of your web browser.
Email Job Alerts
As a registered user of Minerva Appointments Limited you have the option to subscribe to receive job alert notifications that meet your criteria by email. By logging into your account at Minerva Appointments Limited you have the facility to change the criteria of the alerts at any time or choose to unsubscribe.
Updates to your Information
Minerva Appointments Limited do our best to ensure that information we hold on you is accurate and kept up-to-date. To achieve this we rely on you to let us know when your information requires updating. The most efficient way for you to action a change is to login to your account at Minerva Appointments Limited and amend your own record. Alternatively, you can use the "contact us" facility on our website to request that we make updates to your information on your behalf.
Hyperlinks to other Sites
Hyperlinks to other websites are provided on the Minerva Appointments Limited website. If you use these hyperlinks then you are leaving the website and Minerva Appointments Limited is not responsible for the privacy practices on other sites. We recommend that you check the Privacy Statements of each and every other website you visit.
Notification of Changes
Any changes Minerva Appointments Limited make to our Privacy Statement will be set out here on this page of the website. If at any time you have questions or concerns about Minerva Appointments Limited's Privacy Statement please convey them using the Contact Us facility on this website.
You agree that personal information including your CV which is collected by Minerva Appointments Limited on this website may be used and disclosed for such purposes and to such third parties in accordance with Minerva Appointments Limited's Privacy Statement.
By submitting your personal information including your CV you agree that you have read, understood and accept Minerva Appointments Limited's Privacy Statement.
You also consent to the use, transfer and disclosure of this information referred to in Minerva Appointments Limited's Privacy Statement.
Data Protection Policy
- Data processing under the Data Protection Laws
- The data protection principles
- Legal bases for processing
- Privacy by design and by default
- Rights of the Individual
- Privacy notices
- Subject access requests
- Restriction of processing
- Data portability
- Object to processing
- Enforcement of rights
- Automated decision making
- Personal data breaches
- Personal data breaches where the Company is the data controller
- Personal data breaches where the Company is the data processor
- Communicating personal data breaches to individuals
- The Human Rights Act 1998
All organisations that process personal data are required to comply with data protection legislation. This includes in particular the Data Protection Act 1998 (or its successor) and the EU General Data Protection Regulation (together the ‘Data Protection Laws'). The Data Protection Laws give individuals (known as ‘data subjects') certain rights over their personal data whilst imposing certain obligations on the organisations that process their data.
As a recruitment business the Company collects and processes both personal data and sensitive personal data. It is required to do so to comply with other legislation. It is also required to keep this data for different periods depending on the nature of the data.
This policy sets out how the Company implements the Data Protection Laws. It should be read in conjunction with the Data Protection Procedure.
In this policy the following terms have the following meanings:
- ‘consent' means any freely given, specific, informed and unambiguous indication of an individual's wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her;
- ‘data controller' means an individual or organisation which, alone or jointly with others, determines the purposes and means of the processing of personal data;
- ‘data processor' means an individual or organisation which processes personal data on behalf of the data controller;
- ‘personal data'* means any information relating to an individual who can be identified, such as by a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person;
- ‘personal data breach' means a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data;
- ‘processing' means any operation or set of operations performed on personal data, such as collection, recording, organisation, structuring, storage (including archiving), adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction;
- ‘profiling' means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to an individual, in particular to analyse or predict aspects concerning that natural person's performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements;
- ‘pseudonymisation' means the processing of personal data in such a manner that the personal data can no longer be attributed to an individual without the use of additional information, provided that such additional information is kept separately and is subject to technical and organisational measures to ensure that the personal data are not attributed to an identified or identifiable individual;
- ‘sensitive personal data'* means personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data, data concerning health, an individual's sex life or sexual orientation and an individual's criminal convictions. * For the purposes of this policy we use the term ‘personal data' to include ‘sensitive personal data' except where we specifically need to refer to sensitive personal data;
- ‘Supervisory authority' means an independent public authority which is responsible for monitoring the application of data protection. In the UK the supervisory authority is the Information Commissioner's Office (ICO).
Data processing under the Data Protection Laws:
The Company processes personal data in relation to its own staff, work-seekers and individual client contacts and is a data controller for the purposes of the Data Protection Laws. The Company has registered with the ICO and its registration number is Z8787392.
The Company may hold personal data on individuals for the following purposes:
- Staff administration.
- Advertising, marketing and public relations.
- Accounts and records.
- Administration and processing of work-seekers' personal data for the purposes of providing work-finding services, including processing using software solution providers and back office support.
- Administration and processing of clients' personal data for the purposes of supplying / introducing work-seekers.
The data protection principles:
The Data Protection Laws require the Company acting as either data controller or data processor to process data in accordance with the principles of data protection. These require that personal data is:
- Processed lawfully, fairly and in a transparent manner.
- Collected for specified and legitimate purposes and not further processed in a manner that is incompatible with those purposes.
- Adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed.
- Accurate and kept up to date; every reasonable step must be taken to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay.
- Kept for no longer than is necessary for the purposes for which the personal data are processed.
Processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures; and that
The data controller shall be responsible for, and be able to demonstrate, compliance with the principles.
Legal bases for processing:
The Company will only process personal data where it has a legal basis for doing so. Where the Company does not have a legal reason for processing personal data any processing will be a breach of the Data Protection Laws.
The Company will review the personal data it holds on a regular basis to ensure it is being lawfully processed and it is accurate, relevant and up to date and the data controller shall be responsible for doing this.
Before transferring personal data to any third party (such as past, current or prospective employers, suppliers, customers and clients, intermediaries such as umbrella companies, persons making an enquiry or complaint and any other third party (such as software solutions providers and back office support), the Company will establish that it has a legal reason for making the transfer.
Privacy by design and by default:
The Company has implemented measures and procedures that adequately protect the privacy of individuals and ensures that data protection is integral to all processing activities. This includes implementing measures such as:
- Data minimisation (i.e. not keeping data for longer than is necessary).
- Cyber security.
Rights of the Individual:
The Company shall provide any information relating to data processing to an individual in a concise, transparent, intelligible and easily accessible form, using clear and plain language. The information shall be provided in writing, or by other means, including, where appropriate, by electronic means. The Company may provide this information orally if requested to do so by the individual.
The Company's website and at the online registration stage.
On all Company emails sent to individuals for reasons of providing work seeking services.
Where the Company collects personal data other than from the individual directly, such as job boards, the individual will receive by way of electronic notification a privacy notice within a reasonable period after obtaining the personal data, but at the latest within one month. If the Company intends to disclose the personal data to a third party then the privacy notice will be issued when the personal data are first disclosed (if not issued sooner).
Where the Company intends to further process the personal data for a purpose other than that for which the data was initially collected, the Company will give the individual information on that other purpose and any relevant further information before it does the further processing.
Subject access requests:
The individual is entitled to access their personal data on request from the data controller.
The individual or another data controller at the individual's request, has the right to ask the Company to rectify any inaccurate or incomplete personal data concerning an individual.
If the Company has given the personal data to any third parties it will tell those third parties that it has received a request to rectify the personal data unless this proves impossible or involves disproportionate effort. Those third parties should also rectify the personal data they hold - however the Company will not be in a position to audit those third parties to ensure that the rectification has occurred.
The individual or another data controller at the individual's request, has the right to ask the Company to erase an individual's personal data.
If the Company receives a request to erase it will ask the individual if s/he wants his personal data to be removed entirely or whether s/he is happy for his or her details to be kept on a list of individuals who do not want to be contacted in the future (for a specified period or otherwise). The Company cannot keep a record of individuals whose data it has erased so the individual may be contacted again by the Company should the Company come into possession of the individual's personal data at a later date.
If the Company has made the data public, it shall take reasonable steps to inform other data controllers and data processors processing the personal data to erase the personal data, taking into account available technology and the cost of implementation.
If the Company has given the personal data to any third parties it will tell those third parties that it has received a request to erase the personal data, unless this proves impossible or involves disproportionate effort. Those third parties should also rectify the personal data they hold - however the Company will not be in a position to audit those third parties to ensure that the rectification has occurred.
Restriction of processing:
The individual or a data controller at the individual's request, has the right to ask the Company to restrict its processing of an individual's personal data where:
- The individual challenges the accuracy of the personal data.
- The processing is unlawful and the individual opposes its erasure
- The Company no longer needs the personal data for the purposes of the processing, but the personal data is required for the establishment, exercise or defence of legal claims; or
- The individual has objected to processing (on the grounds of a public interest or legitimate interest) pending the verification whether the legitimate grounds of the Company override those of the individual.
If the Company has given the personal data to any third parties it will tell those third parties that it has received a request to restrict the personal data, unless this proves impossible or involves disproportionate effort. Those third parties should also rectify the personal data they hold - however the Company will not be in a position to audit those third parties to ensure that the rectification has occurred.
The individual shall have the right to receive personal data concerning him or her, which he or she has provided to the Company, in a structured, commonly used and machine-readable format and have the right to transmit those data to another data controller in circumstances where:
- The processing is based on the individual's consent or a contract; and
- The processing is carried out by automated means.
Where feasible, the Company will send the personal data to a named third party on the individual's request.
Object to processing:
The individual has the right to object to their personal data being processed based on a public interest or a legitimate interest. The individual will also be able to object to the profiling of their data based on a public interest or a legitimate interest.
The Company shall cease processing unless it has compelling legitimate grounds to continue to process the personal data which override the individual's interests, rights and freedoms or for the establishment, exercise or defence of legal claims.
The individual has the right to object to their personal data for direct marketing.
Enforcement of rights:
All requests regarding individual rights should be sent to
The Company shall act upon any subject access request, or any request relating to rectification, erasure, restriction, data portability or objection or automated decision making processes or profiling within one month of receipt of the request. The Company may extend this period for two further months where necessary, taking into account the complexity and the number of requests.
Where the Company considers that a request under this section is manifestly unfounded or excessive due to the request's repetitive nature the Company may either refuse to act on the request or may charge a reasonable fee taking into account the administrative costs involved.
Automated decision making:
The Company will not subject individuals to decisions based on automated processing that produce a legal effect or a similarly significant effect on the individual, except where the automated decision:
- Is necessary for the entering into or performance of a contract between the data controller and the individual;
- Is authorised by law; or
- The individual has given their explicit consent.
The Company will not carry out any automated decision-making or profiling using the personal data of a child.
Personal data breaches:
Reporting personal data breaches:
- All data breaches should be referred to firstname.lastname@example.org.
Personal data breaches where the Company is the data controller:
- Where the Company establishes that a personal data breach has taken place, the Company will take steps to contain and recover the breach. Where a personal data breach is likely to result in a risk to the rights and freedoms of any individual the Company will notify the ICO.
- Where the personal data breach happens outside the UK, the Company shall alert the relevant supervisory authority for data breaches in the effected jurisdiction.
Personal data breaches where the Company is the data processor:
- The Company will alert the relevant data controller as to the personal data breach as soon as they are aware of the breach.
Communicating personal data breaches to individuals:
- Where the Company has identified a personal data breach resulting in a high risk to the rights and freedoms of any individual, the Company shall tell all affected individuals without undue delay.
The Company will not be required to tell individuals about the personal data breach where:
- The Company has implemented appropriate technical and organisational protection measures to the personal data affected by the breach, in particular to make the personal data unintelligible to any person who is not authorised to access it, such as encryption.
- The Company has taken subsequent measures which ensure that the high risk to the rights and freedoms of the individual is no longer likely to materialise.
- It would involve disproportionate effort to tell all affected individuals. Instead, the Company shall make a public communication or similar measure to tell all affected individuals.
All individuals have the following rights under the Human Rights Act 1998 (HRA) and in dealing with personal data these should be respected at all times:
- Right to respect for private and family life.
- Freedom of thought, belief and religion.
- Freedom of expression.
- Freedom of assembly and association.
- Protection from discrimination in respect of rights and freedoms under the HRA.
If you have a complaint or suggestion about the Company's handling of personal data then please contact email@example.com
Alternatively you can contact the ICO directly on 0303 123 1113 or at https://ico.org.uk/global/contact-us/email/
The Human Rights Act 1998:
The lawfulness of processing conditions for personal data are:
- Consent of the individual for one or more specific purposes.
- Processing is necessary for the performance of a contract with the individual or in order to take steps at the request of the individual to enter into a contract.
- Processing is necessary for compliance with a legal obligation that the controller is subject to.
- Processing is necessary to protect the vital interests of the individual or another person.
- Processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the data controller.
- Processing is necessary for the purposes of legitimate interests pursued by the controller or a third party, except where such interests are overridden by the interests or fundamental rights or freedoms of the individual which require protection of personal data, in particular where the individual is a child.
The lawfulness of processing conditions for sensitive personal data are:
- Explicit consent of the individual for one or more specified purposes, unless reliance on consent is prohibited by EU or Member State law.
- Processing is necessary for carrying out data controller's obligations under employment, social security or social protection law, or a collective agreement, providing for appropriate safeguards for the fundamental rights and interests of the individual.
- Processing is necessary to protect the vital interests of the individual or another individual where the individual is physically or legally incapable of giving consent.
- In the course of its legitimate activities, processing is carried out with appropriate safeguards by a foundation, association or any other not-for-profit body, with a political, philosophical, religious or trade union aim and on condition that the processing relates only to members or former members (or those who have regular contact with it in connection with those purposes) and provided there is no disclosure to a third party without the consent of the individual.
- Processing relates to personal data which are manifestly made public by the individual.
- Processing is necessary for the establishment, exercise or defence of legal claims or whenever courts are acting in their judicial capacity.
- Processing is necessary for reasons of substantial public interest on the basis of EU or Member State law which shall be proportionate to the aim pursued, respects the essence of the right to data protection and provide for suitable and specific measures to safeguard the fundamental rights and interests of the individual.
- Processing is necessary for the purposes of preventative or occupational medicine, for assessing the working capacity of the employee, medical diagnosis, the provision of health or social care or treatment or the management of health or social care systems and services on the basis of EU or Member State law or a contract with a health professional and subject to the necessary conditions and safeguards.
- Processing is necessary for reasons of public interest in the area of public health, such as protecting against serious cross-border threats to health or ensuring high standards of quality and safety of healthcare and of medicinal products or medical devices, on the basis of EU or Member State law which provides for suitable and specific measures to safeguard the rights and freedoms of the individual, in particular professional secrecy.
- Processing is necessary for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes, which shall be proportionate to the aim pursued, respect the essence of the right to data protection and provide for suitable and specific measures to safeguard fundamental rights and interests of the individual.