GIOS Technology Limited (“GIOS” or “Us” or “We”) understands that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of all our Website Users, Candidates, Clients, Suppliers, and other people whom we may contact, in order to find out more about our Candidates and Staff or whom they indicate is a referee or emergency contact. It also applies to the emergency contacts of our Staff. To be clear, if you are a member of GIOS Staff, you should refer to the GIOS Staff Privacy Policy which is available on the GIOS Technology internal system. We will only collect and use personal data in ways that are described here, and in a way, that is consistent with our obligations and your rights under the law.

GIOS Technology Limited.
Registered in England under company number 6309056
Registered address: 3rd Floor Grove House, 55 Lowlands Road, London, HA1 3AW, UK
Main trading address: 3rd Floor Grove House, 55 Lowlands Road, London, HA1 3AW, UK
VAT number: GB916 9051 17
Contact: Data Protection Officer (“DPO”)
Email address: privacypolicy@giostechnology.com
Telephone number: +44 (0)20 3544 8686
Postal Address: 3rd Floor Grove House, 55 Lowlands Road, London, HA1 3AW, UK

This Privacy Information explains how we use your personal data: how it is collected, how it is held, and how it is processed. It also explains your rights under the law relating to your personal data.

Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.

Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.

The personal data that we use is set out in Part 5, below.

Under the GDPR, you have the following rights, which we will always work to uphold:

1. The right to be informed about our collection and use of your personal data. This Privacy Notice should tell you everything you need to know, but you can always contact us to find out more or to ask any questions using the details in Part 11.
2. The right to access the personal data we hold about you. Part 10 will tell you how to do this.
3. The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in Part 11 to find out more.
4. The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we have. Please contact us using the details in Part 11 to find out more.
5. The right to restrict (i.e. prevent) the processing of your personal data.
6. The right to object to us using your personal data for a particular purpose or purposes.
7. The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.
8. Rights relating to automated decision-making and profiling. We do not use your personal data in this way.

For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Part 11.

Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.

If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office.

We may collect some or all of the following personal data (this may vary according to your relationship with us):

• Name;
• Age/date of birth;
• Birth number;
• Sex/gender;
• Photograph;
• Marital status;
• Contact details;
• Education details;
• Employment history;
• Business name;
• Job title;
• Profession;
• Payment information;
• Information about your preferences and interests;
• Emergency contacts and details of any dependants;
• Referee details;
• Immigration status (whether you need a work permit);
• Nationality/citizenship/place of birth;
• A copy of your driving licence and/or passport/identity card;
• Financial information (where we need to carry out financial background checks);
• Social security number (or equivalent in your country) and any other tax-related information;
• Diversity information including racial or ethnic origin, religious or other similar beliefs, and physical or mental health, including disability-related information;
• Details of any criminal convictions if this is required for a role that you are interested in applying for;
• Details about your current remuneration, pensions and benefits arrangements;
• Information on your interests and needs regarding future employment, both collected directly and inferred, for example from jobs viewed or articles read on our website;
• Extra information that you choose to tell us;
• Extra information that your referees chooses to tell us about you;
• Extra information that our Clients may tell us about you, or that we find from other third party sources such as job sites;
• IP address;
• The dates, times and frequency with which you access our services;
• CCTV footage if you attend our premises.

Your personal data is obtained from the following:
Candidate Data: We collect Candidate personal data in three primary ways:

1. Personal data that you, the Candidate, give to us;
2. Personal data that we receive from other sources; and
3. Personal data that we collect automatically.

Personal data you give to us

• GIOS Technology needs to know certain information about you in order to provide a tailored service. This will enable us to provide you with the best opportunities, and should save you time in not having to trawl through information about jobs and services that are not relevant to you.
• There are numerous ways you can share your information with us. It all depends on what suits you. These may include
  • Entering your details on the GIOS’s website or via an application form, as part of the registration process;
  • Leaving a hard copy CV at a GIOS’s recruitment event, job fair or office;
  • Emailing your CV to a GIOS Technology consultant or being interviewed by them;
  • Applying for jobs through a job aggregator, which then redirects you to the GIOS’s website;
  • Entering your personal details into a GIOS Technology’s microsite; or
  • Entering a competition through a social media channel such as Facebook or Twitter.

Personal data we receive from other sources

• We also receive personal data about Candidate from other sources. Depending on the relevant circumstances and applicable local laws and requirements, these may include personal data received in the following situations:
  • Your referees may disclose personal information about you;
  • Our Clients may share personal information about you with us;
  • We may obtain information about you from searching for potential Candidate from third party sources, such as LinkedIn and other job sites;
  • If you ‘like’ our page on Facebook or ‘follow’ us on Twitter we will receive your personal information from those sites; and
  • If you were referred to us through an RPO or an MSP supplier, they may share personal information about you with us.

Personal data we collect automatically

• To the extent that you access our website or read or click on an email from us, where appropriate and in accordance with any local laws and requirements, we may also collect your data automatically or through you providing it to us.
  For more information please contact us as outlined in section 11.
• Client Data: We collect Client personal data in three ways:
  1. Personal data that we receive directly from you;
  2. Personal data that we receive from other sources; and
  3. Personal data that we collect automatically.

Personal data that we receive directly from you

• We both share the same goal – to make sure that you have the best staff for your organisation. We will receive data directly from you in two ways:
  • Where you contact us proactively, usually by phone or email; and/or
  • Where we contact you, either by phone or email, or through our consultants’ business development activities more generally.

Personal data we receive from other sources

• Where appropriate and in accordance with any local laws and requirements, we may seek more information about you or your colleagues from other sources generally by way of due diligence or other market intelligence including:
  • From third party market research and by analysing online and offline media (which we may do ourselves, or employ other organisations to do for us);
  • From delegate lists at relevant events; and
  • From other limited sources and third parties (for example from our Candidates to the extent that they provide us with your details to act as a referee for them).

Personal data we collect via our website

• To the extent that you access our website or read or click on an email from us, where appropriate and in accordance with any local laws and requirements, we may also collect your data automatically or through you providing it to us.
  For more information please contact us as outlined in section 11.
• Website Users: When you visit our website there is certain information that we may automatically collect, whether or not you decide to use our services. This includes your IP address, the date and the times and frequency with which you access the website and the way you browse its content. We will also collect data from you when you contact us via the website, for example by using the chat function.

We collect your data automatically via cookies, in line with cookie settings in your browser. If you are also a Candidate or Client of GIOS Technology, we may use data from your use of our websites to enhance other aspects of our communications with or service to you. If you would like to find out more about cookies, including how we use them and what choices are available to you.
For more information please contact us as outlined in section 11.

Under the GDPR, we must always have a lawful basis for using personal data. This may be because the data is necessary for our performance of a contract with you, because you have consented to our use of your personal data, or because it is in our legitimate business interests to use it. Your personal data may be used for one of following purposes:

• Candidate Data: The main reason for using your personal details is to help you find employment or other work roles that might be suitable for you. The more information we have about you, your skillset and your ambitions, the more bespoke we can make our service. Where appropriate and in accordance with local laws and requirements, we may also use your personal data for things like marketing, profiling and diversity monitoring. Where appropriate, we will seek your consent to undertake some of these activities.
• Client Data: The main reason for using information about Clients is to ensure that the contractual arrangements between us can properly be implemented so that the relationship can run smoothly. This may involve: (i) identifying Candidates who we think will be the right fit for you or your organisation; (ii) providing you with an Managed or Outcome based Service programme (or assisting another organisation to do so); and/or (iii) providing you with RPO Lite services (or assisting another organisation to do so), (iv) Providing and managing your account, (v) Communication with you. The more information we have, the more personalise and tailor our products services for you.
• Supplier Data: The main reasons for using your personal data are to ensure that the contractual arrangements between us can properly be implemented so that the relationship can run smoothly, and to comply with legal requirements.
• People Whose Data We Receive From Candidates AND Staff, Such as Referees AND Emergency Contacts: We use referees’ personal data to help our Candidates to find employment which is suited to them. If we are able to verify their details and qualifications, we can make sure that they are well matched with prospective employers. We may also use referees’ personal data to contact them in relation to recruitment activities that may be of interest to them. We use the personal details of a Candidates or Staff member’s emergency contacts in the case of an accident or emergency affecting that Candidates or member of Staff.
• Website Users: We use your data to help us to improve your experience of using our website, for example by analysing your recent job search criteria to help us to present jobs to you that we think you’ll be interested in. If you are also a Candidate or Client of GIOS Technology, we may use data from your use of our websites to enhance other aspects of our communications with, or service to, you.

With your permission and/or where permitted by law, we may also use your personal data for marketing purposes, which may include contacting you by email AND/OR telephone AND/OR text message AND/OR post with information, news, and offers on our products AND/OR services. You will not be sent any unlawful marketing or spam. We will always work to fully protect your rights and comply with our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out.

Please note that communications to and from GIOS Staff including emails may be reviewed as part of internal or external investigations or litigation.

We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Your personal data will therefore be kept for the following periods (or, where there is no fixed period, the following factors will be used to determine how long it is kept):

• We will Delete your personal data from our systems if we have not had any meaningful contact with you (or, where appropriate, the company you are working for or with) for two years (or for such longer period as we believe in good faith that the law or relevant regulators require us to preserve your data). After this period, it is likely your data will no longer be relevant for the purposes for which it was collected.
• For those Candidates whose services are provided via a third-party company or other entity, “meaningful contact” with you means meaningful contact with the company or entity which supplies your services. Where we are notified by such company or entity that it no longer has that relationship with you, we will retain your data for no longer than two years from that point or, if later, for the period of two years from the point we subsequently have meaningful contact directly with you.
• When we refer to “meaningful contact”, we mean, for example, communication between us (either verbal or written), or where you are actively engaging with our online services. If you are a Candidate we will consider there to be meaningful contact with you if you submit your updated CV onto our website or take part in any of our online training. We will also consider it meaningful contact if you communicate with us about potential roles, either by verbal or written communication or click through from any of our marketing communications. Your receipt, opening or reading of an email or other digital message from us will not count as meaningful contact – this will only occur in cases where you click-through or reply directly

We may store or transfer some or all of your personal data in countries that are not part of the European Economic Area (the “EEA” consists of all EU member states, plus Norway, Iceland, and Liechtenstein). These are known as “third countries” and may not have data protection laws that are as strong as those in the UK and/or the EEA. In order to provide you with the best service and to carry out the purposes described in this Privacy Notice, your data may be transferred:

• • between and within GIOS entities;
  • to third parties (such as advisers or other Suppliers to the GIOS’s business);
  • to overseas Clients;
  • to Clients within your country who may, in turn, transfer your data internationally;
  • to a cloud-based storage provider; and
  • to other third parties,

• We want to make sure that your data are stored and transferred in a way which is secure. We will therefore only transfer data outside of the European Economic Area or EEA (i.e. the Member States of the European Union, together with Norway, Iceland and Liechtenstein) where it is compliant with data protection legislation and the means of transfer provides adequate safeguards in relation to your data, for example:
  • by way of data transfer agreement, incorporating the current standard contractual clauses adopted by the European Commission for the transfer of personal data by data controllers in the EEA to data controllers and processors in jurisdictions without adequate data protection laws; or
  • by signing up to the EU-U.S. Privacy Shield Framework for the transfer of personal data from entities in the EU to entities in the United States of America or any equivalent agreement in respect of other jurisdictions; or
  • transferring your data to a country where there has been a finding of adequacy by the European Commission in respect of that country’s levels of data protection via its legislation; or
  • where it is necessary for the conclusion or performance of a contract between ourselves and a third party and the transfer is in your interests for the purposes of that contract (for example, if we need to transfer data outside the EEA in order to meet our obligations under that contract if you are a Client of ours); or
  • where you have consented to the data transfer.
• To ensure that your personal information receives an adequate level of protection, we have put in place appropriate procedures with the third parties we share your personal data with to ensure that your personal information is treated by those third parties in a way that is consistent with and which respects the law on data protection.

Please contact us using the details below in Part 11 for further information about the particular data protection mechanism used by us when transferring your personal data to a third country.

We may share your personal data between and within GIOS entities and third parties to supply products AND/OR services to you on our behalf which may require those third parties to access to some or all of your personal data that we hold. The purpose would be:

• Candidate Data: We may share your personal data with various parties, in various ways and for various reasons. Primarily we will share your information with prospective employers to increase your chances of securing the job you want. Unless you specify otherwise, we may also share your information with any of our group companies and associated third parties such as our service providers where we feel this will help us to provide you with the best possible service.
• Client Data: We will share your data: (i) primarily to ensure that we provide you with a suitable pool of Candidates; (ii) to provide you with an Managed or Outcome based Service programme (or assist another organisation to do so); and/or (iii) to provide you with RPO Lite service (or assist another organisation to do so). Unless you specify otherwise, we may share your information with any of our group companies and associated third parties such as our service providers to help us meet these aims.
• Supplier Data: Unless you specify otherwise, we may share your information with any of our group companies and associated third parties such as our service providers and organisations to whom we provide services.
• People Whose Data We Receive from Candidates AND Staff, Such as Referees AND Emergency Contacts: Unless you specify otherwise, we may share your information with any of our group companies and associated third parties such as our service providers and organisations to whom we provide services.
• Website Users: Unless you specify otherwise, we may share your information with providers of web analytics services, marketing automation platforms and social media services to make sure any advertising you receive is targeted to you.

If any of your personal data is required by a third party, as described above, we will take steps to ensure that your personal data is handled safely, securely, and in accordance with your rights, our obligations, and the third party’s obligations under the law, as described above in Part 8.

If any personal data is transferred outside of the EEA, we will take suitable steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the GDPR, as explained above in Part 8.

In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.

If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.

All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 11. To make this as easy as possible for you, a Subject Access Request Form is available for you to use. You do not have to use this form, but it is the easiest way to tell us everything we need to know to respond to your request as quickly as possible.

There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.

We will respond to your subject access request within 30 days of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.

To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the following details (for the attention Data Protection Officer):
Email address: privacypolicy@giostechnology.com
Telephone number: +44 (0)20 3544 8686
Postal Address: Middlesex House, 2ND Floor, 130 College Road, London HA1 1BQ.

We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection.

Any changes will be made available either by visiting our website and click on our Privacy Notice as we will post changes here. Alternatively, you can request this by contacting us as outlined in section 11.