Privacy

The data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
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• Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth, gender, passport details, nationality, ethnicity and NI numbers.
• Contact Data includes residential address, billing address, delivery address, email address, and telephone numbers (including next-of-kin).
• Employment and Background Data includes DBS disclosures, CV’s, qualifications, accreditations, education and previous employment details.
• Financial Data includes bank account and payment processing details.
• Transaction Data includes details about payments to and from you and other details of services you have purchased from us.
• Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
• Profile Data includes your username and password, your interests, preferences, feedback and survey responses.
• Usage Data includes information about how you use our website and services, including tracking information, analytics, geographic and device information.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
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We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice. We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data).
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• Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
  
  

How is your personal data collected?

We use different methods to collect data from and about you including through:

• Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
• Apply to be a member or partner or to receive services;
• create an account on our website or app;
• subscribe to our services or publications;
• request marketing to be sent to you;
  
• enter a competition, promotion or survey; or
• give us some feedback.
• Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy for further details.
• Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:
• Technical Data from the following parties:
  

(a) analytics providers such as Google and Hubspot;
(b) advertising networks such as The Guardian, Totaljobs, The Stage, Ladders and LinkedIn;
(c) search information providers based inside or outside the UK;
(d) Contact, Financial and Transaction Data from providers of payment services, delivery service providers and umbrella companies based inside the UK;
(e) Identity and Contact Data from publicly available sources such as the DBS, Department of Education and a postcode look-up provider based inside the UK.

Legal Basis for Processing

We only process your personal data where we have a lawful basis to do so under UK GDPR:

• Consent – You have given clear consent for us to process your personal data for a specific purpose.
  
• Contract – The processing is necessary for a contract we have with you.
  
• Legal obligation – We must comply with the law.
  
• Legitimate interests – For business interests not overridden by your rights and freedoms.
  

Where consent is required (e.g. for email marketing or non-essential cookies), we will obtain it explicitly and you can withdraw it at any time.

How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• Provide, manage, and improve our services.
  
• Process payments and deliver services or products.
  
• Communicate with you (e.g., service updates, account information).
  
• Deliver personalised content and marketing (if you consent).
  
• Maintain our website and digital security.
  
• Comply with legal obligations (e.g., HMRC reporting, law enforcement requests).
  

Click to find out more about the types of lawful basis that we will rely on to process your personal data. Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
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We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which services and offers may be relevant to you (we call this marketing). You will receive marketing communications from us if you have requested information from us or purchased services from us or if you provided us with your details when you entered a competition or registered for promotion and, in each case, you have not opted out of receiving that marketing.
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We will get your express opt-in consent before we share your personal data with any company outside the Opogo group of companies for marketing purposes.
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You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time.
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You can set your browser to refuse all or some browser cookies or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our cookie policy.
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Disclosures of your personal data

We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.

• Internal Third Parties as set out in the Glossary.
  
• External Third Parties as set out in the Glossary.
  
• Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
  

We require all third parties to respect the security of your personal data and to treat it in accordance with UK GDPR standards. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
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International transfers

If we transfer your data outside the UK, we ensure appropriate safeguards are in place, including:

• Adequacy decisions by the UK Government.
  
• Standard Contractual Clauses (SCCs).
  
• Binding corporate rules or certifications.
  

Data security

We use a range of security measures to protect your data:

• Encryption and access controls.
  
• Secure server environments.
  
• Regular risk assessments and audits.
  
• Staff training on data protection.
  

In the event of a data breach, we follow ICO guidance and notify you and the regulator where required.

Data retention periods

We retain personal data only for as long as necessary to fulfill legal and business obligations. Retention periods are as follows:
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• Candidate Data (CVs, applications, interview notes) – 12 months from last contact unless consent is obtained for extended retention.
  
• Placed Candidates – 6 years from the end of employment for tax and compliance purposes.
  
• Payroll and Financial Records – 6 years in compliance with HMRC regulations.
  
• Right to Work Documentation – 2 years after employment or placement ends.
  
• Client and Supplier Data – 6 years from last interaction for contractual purposes.
  

Your legal rights

Under UK GDPR, you have the following rights:

• Access – Request access to your personal data.
  
• Rectification – Request correction of inaccurate or incomplete data.
  
• Erasure – Request deletion of your data where appropriate ("right to be forgotten").
  
• Restriction – Request restriction of processing.
  
• Data Portability – Request transfer of your data to another provider.
  
• Objection – Object to processing where we rely on legitimate interests.
  
• Withdraw Consent – At any time where processing is based on consent.
  

If you wish to exercise any of the rights set out above, please contact us. We may require proof of identity for verification.

No fee usually required
‍You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

What we may need from you
‍We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond
‍We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

Glossary

Lawful basis

• Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
  
• Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
  
• Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
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Third parties
Internal third parties;

• Other companies in the Opogo group of companies acting as joint controllers or processors and who are based in the UK and provide IT and system administration services and undertake leadership reporting.
  

External third parties;

• Service providers acting as processors in the United Kingdom who provide IT and system administration services.
  
• Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the United Kingdom who provide consultancy, banking, legal, insurance and accounting services.
  
• HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom and who require reporting of processing activities in certain circumstances.