As a recruitment finance business, QUBA has two main business models:
Please note that, in some cases, you will fall into more than one of the above categories.
Agency Partner: a recruitment agency to which we are providing recruitment finance services, either as the principal in the contracting arrangement or on a standard factoring basis.
Agency Partner Representative: means a person who is employed or engaged by the Agency Partner and who we may contact in the course of our dealings with the Agency Partner.
Candidate: a person who is recorded in QUBA’s records as seeking or potentially suitable for an engagement with a Client. This includes individuals who are not actively seeking a new role but who are in contact with the Agency Partner about potential opportunities which may be of interest from time to time.
Client: a hirer which has engaged QUBA to provide recruitment services.
Client Contact: a person who is employed or engaged by a Client and with whom QUBA may liaise in respect of any services which QUBA is providing to the Client. In some cases, the Client Contact and the Client may be the same person e.g. where a Client is a sole trader.
Data Protection Legislation: the Data Protection Act 2018, the retained UK-GDPR, and all other primary and secondary legislation relating to data protection in the United Kingdom.
Prospect: a person who is employed or engaged by a recruitment agency which is not an Agency Partner but with whom we are dealing with a view to providing recruitment finance services to such recruitment agency.
Supplier: a business which provides services to QUBA and which may process personal data relating to any Candidate, Client Contact or Supplier Representative in the course of performing such services.
Supplier Representative: a person who is employed or engaged by a Supplier and with whom QUBA may liaise from time to time in respect of the services which are provided by that Supplier.
Third-Party Services Provider: any relevant third-party business which provides services to QUBA or with which QUBA has a professional relationship, including our:
We obtain personal data from a number of different sources, depending on the capacity in which you are dealing with us.
If you are a Candidate, we may obtain personal data relating to you:
If you are a Client Contact, Agency Partner Representative, Supplier Representative or Prospect, we may obtain personal data relating to you:
If you are a Candidate, we may collect, store and process the following types of personal information about you:
We may also collect, store and use the following “special categories” of more sensitive personal information:
If you are a Client Contact, we will collect, store, and use the following categories of personal information about you:
We do not collect, store or use any “special categories” of sensitive personal information if you are a Client Contact.
If you are an Agency Partner Representative or Prospect, we will collect, store, and use the following categories of personal information about you:
We do not collect, store or use any “special categories” of sensitive personal information if you are an Agency Partner Representative or Prospect.
If you are a Supplier Representative, we will collect, store, and use the following categories of personal information about you:
We do not collect, store or use any “special categories” of sensitive personal information if you are a Supplier Representative.
If you are a Candidate, we may use your personal data to:
If you are a Client Contact, we may use your personal data to:
If you are an Agency Partner Representative, we may use your personal data to:
If you are a Supplier Representative, we may use your personal data to:
If you are a Prospect, we may use your personal data to:
If you are a Candidate:
We have determined that we have a legitimate interest to process your personal data where you are:
Your personal data is held and processed by us in the United Kingdom.
We have put in place appropriate safeguards to ensure that your data is only transferred to jurisdictions with enforceable data subject rights and effective legal remedies in respect of data privacy breaches. We will therefore only transfer your personal data to jurisdictions outside of the UK and EEA where:
If you are a Candidate, we may share your personal data for legitimate purposes with:
If you are a Client Contact or Agency Partner Representative, we may share very limited data relating to you with a Candidate where such sharing is strictly required for the recruitment process e.g. so that the Candidate may contact you directly. We will also share your personal data with Third-Party Services Providers for legitimate business purposes.
If you are a Supplier Representative or Prospect, we will share your personal data with other Third-Party Services Providers for legitimate business purposes.
Automated decision-making takes place when an electronic system uses personal information to make a decision without human intervention.
All decisions which are made in the course of our business processes involve human intervention. We do not therefore make any decisions about you using automated means, whether you are a Candidate, Client Contact, Agency Partner Representative, Supplier Representative or Prospect.
We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.
We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
Our standard data retention period is seven years as, during this period, we may need to produce data for audit purposes or to bring or defend legal proceedings.
Your duty to inform us of changes. It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your working relationship with us.
Your rights in connection with personal information. Under certain circumstances, you have the right to:
If you want to exercise any of the above rights, please contact the Data Protection Manager in writing. We will consider your request and confirm the actions which we have taken in response to such request.
We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is an appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.
In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact the Data Protection Manager. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law. We will confirm the actions which we have taken in respect of any such request.
If you are unhappy with any aspect of the manner in which we have processed your personal data or dealt with your decision to exercise any of the rights set out in this section, you have the right to complain to the ICO in the United Kingdom. Their details are: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF. Tel: 0303 123 1113 (local rate) or 01625 545 745. Email: firstname.lastname@example.org