Privacy and Cookies Policy

Aaron Wallis Recruitment and Training Limited (in the trading style of Aaron Wallis) understands that your privacy is important to you and that you care about how your personal data is used and shared online. We respect and value the privacy of everyone who visits this website, www.aaronwallis.co.uk (“Our Site”) and will only collect and use personal data in ways that are described here, and in a manner that is consistent with Our obligations and your rights under the law.

Please read this Privacy Policy carefully and ensure that you understand it. Your acceptance of Our Privacy Policy is deemed to occur upon your first use of Our Site If you do not accept and agree with this Privacy Policy, you must stop using Our Site immediately.

1. Definitions and Interpretation

In this Policy, the following terms shall have the following meanings: 

• “Account” means an account required to access and/or use certain areas and features of Our Site;
• “Cookie” means a small text file placed on your computer or device by Our Site when you visit certain parts of Our Site and/or when you use certain features of Our Site. Details of the Cookies used by Our Site are set out in section 13, below;
• “Cookie Law” means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003;
• “personal data” means any and all data that relates to an identifiable person who can be directly or indirectly identified from that data. In this case, it means personal data that you give to Us via Our Site. This definition shall, where applicable, incorporate the definitions provided in the EU Regulation 2016/679 – the General Data Protection Regulation (“GDPR”); and
• “We/Us/Our” means Aaron Wallis Recruitment and Training Limited (in the trading style of Aaron Wallis), a limited company registered in England under company number 6356563, whose registered address (and main trading address) is 22 Walker Avenue, Stratford Business Village, Wolverton Mill, Milton Keynes, MK12 5TW.

2. Information About Us

2.1 Our Site is owned and operated by Aaron Wallis Recruitment and Training Limited (in the trading style of Aaron Wallis), a limited company registered in England under company number 6356563, whose registered address is The Stable Yard 25-33 Vicarage Road, Stony Stratford, Milton Keynes, Buckinghamshire, England, MK11 1BN.  The Company is a recruitment business which provides work-finding services to its clients and work-seekers. The Company must process personal data (including sensitive personal data) so that it can provide these services – in doing so, the Company acts as a data controller with responsibilities of retaining information accurately, and sharing data with data processors legally and only the required information to meet the service.

You may give your personal details to the Company directly, such as on an application or registration form or via our website, or we may collect them from another source such as a jobs board. The Company must have a legal basis for processing your personal data. For the purposes of providing you with work-finding services and/or information relating to roles relevant to you we will only use your personal data in accordance with this privacy statement. At all times we will comply with current data protection laws. 

2.2 Our VAT number is GB 918 1077 27.

2.3 Our Data Protection Officer is Robert Scott, and can be contacted by email at rob.scott@aaronwallis.co.uk, by telephone on 01908 061400, or by post at 22 Walker Avenue, Stratford Business Village, Wolverton Mill, Milton Keynes, MK12 5TW.

2.4 We are a member of the Recruitment & Employment Confederation (REC), Dorset House, First Floor, 27-45 Stamford Street, London, SE1 9NT

3. What Does This Policy Cover?

This Privacy Policy applies only to your use of Our Site. Our Site may contain links to other websites. Please note that We have no control over how your data is collected, stored, or used by other websites and We advise you to check the privacy policies of any such websites before providing any data to them.

This statement sets out below:

1. How personally identifiable information of yours is collected from you through the website.

2. How the information is used by us

3. With whom the information may be shared and for what purpose(s)

4. What choices are available to you regarding collection, use and distribution of the information.

5. The kind of security procedures that are in place to protect the loss, misuse or alteration of information collected through our website

6. How you can correct any inaccuracies in the information.

If you feel that this company is not abiding by its posted privacy policy, you should first contact Rob Scott, the Managing Director on 01908 061400 or write to him at info@aaronwallis.co.uk

4. Your Rights

4.1.1 As a data subject, you have the following rights under the GDPR, which this Policy and Our use of personal data have been designed to uphold:

4.1.2 The right to be informed about Our collection and use of personal data;

4.1.3 The right of access to the personal data We hold about you (see section 12);

4.1.4 The right to rectification if any personal data We hold about you is inaccurate or incomplete (please contact Us using the details in section 14);

4.1.5 The right to be forgotten – i.e. the right to ask Us to delete any personal data We hold about you (We only hold your personal data for a limited time, as explained in section 6 but if you would like Us to delete it sooner, please contact Us using the details in section 14);

4.1.6 The right to restrict (i.e. prevent) the processing of your personal data;

4.1.7 The right to data portability (obtaining a copy of your personal data to re-use with another service or organisation);

4.1.8 The right to object to Us using your personal data for particular purposes; and

4.1.9 Rights with respect to automated decision making and profiling.

4.1.10 Where you have consented to the Company processing your personal data and sensitive personal data you have the right to withdraw that consent at any time by completing the withdrawal consent form.  Please note that if you withdraw your consent to further processing that does not affect any processing done prior to the withdrawal of that consent, or which is done according to another legal basis.

4.1.11 There may be circumstances where the Company will still need to process your data for legal or official reasons. Where this is the case, we will tell you and we will restrict the data to only what is necessary for those specific reasons.

4.1.12 If you believe that any of your data that the Company processes is incorrect or incomplete, please contact us using the details at the bottom of this notice and we will take reasonable steps to check its accuracy and correct it where necessary.

4.1.13 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.

4.1.14 If you have any cause for complaint about Our use of your personal data, please contact Us using the details provided in section 14 and We will do Our best to solve the problem for you. If We are unable to help, you also have the right to lodge a complaint with the UK’s supervisory authority, the Information Commissioner’s Office.

4.1.15 For further information about your rights, please contact the Information Commissioner’s Office or your local Citizens Advice Bureau.

5. What Data Do We Collect?

Aaron Wallis is the sole owner of the information collected on this site.  We will not sell or rent this information to others.  Aaron Wallis collects information from our users at several different points on our website.  Information is shared with Data Processors such as Google, CRM software, accountant/auditor, website developer, web host, etc., etc. Only the minimum information is shared, and sharing is in a legal manner to third parties detailed in this Privacy Policy and Candidate Privacy Notice.

Aaron Wallis collects personally identifiable information, such as your e-mail address, name, home or work address or telephone number. Aaron Wallis also collects anonymous demographic information, which is not unique to you, such as your postcode, age, gender, preferences, interests and favourites. 

There is also information about your computer hardware and software that is automatically collected by Aaron Wallis. This information can include: your IP address, browser type, domain names, access times and referring Web site addresses. This information is used by Aaron Wallis for the operation of the service, to maintain the quality of the service, and to provide general statistics regarding use of the Aaron Wallis website.  Further information can be found in Our Use of Cookies

Candidate registration forms are transmitted securely to the SSL server via 256-bit High-grade SSL encryption. When transferred the field values on the form are encrypted using JavaScript library before it is submitted to the server.  It is stored as an encrypted form on the server and can only be viewed by personnel with an encryption key.  

This web site contains links to other sites. Please be aware that Aaron Wallis is not responsible for the privacy practices of such other sites.  We encourage our users to be aware when they leave our site and to read the privacy statements of each and every web site that collects personally identifiable information.  This privacy statement applies solely to information collected by this Web site.  Aaron Wallis is not responsible for the privacy statements or other content on Web sites.

5.1 Purpose of processing and legal basis

The Company will collect 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.

We must have a legal basis to process your personal data. The legal bases we rely upon to offer our work-finding 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

5.2 Legitimate interest

This is where the Company 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 the Company has relied on a legitimate interest to process your personal data our legitimate interests is/are as follows:

• Managing our database and keeping work-seeker records up to date;
• Providing work-finding services to you and our clients;
• Contacting you to seek your consent where we need it;
• Giving you information about similar products or services that you have used from us recently;

5.3 Statutory/contractual requirement

The Company has certain legal and contractual requirements to collect personal data (e.g. to comply with the Conduct of Employment Agencies and Employment Businesses Regulations 2003, immigration and tax legislation, and in some circumstances safeguarding requirements.)  Our clients may also require this personal data, and/or we may need your data to enter into a contract with you. If you do not give us personal data we need to collect we may not be able to continue to provide work-finding services to you. 

5.4 Recipient/s of data

The Company will process your personal data and/or sensitive personal data with the following recipients:

• Clients (whom we may introduce or supply you to)
• Former employers whom we may seek references from
• Backoffice service providers who manage invoicing on our behalf
• Other recruitment agencies in the supply chain

5.5 Information to be provided when data collected not from the data subject

Categories of data.  The Company has collected the following personal data on you, dependent on your use of Our Site. 

• For website visitors only we may collect some or all of the following personal data detailed in section 13 entitled Our Use of Cookies and similar technologies.  These Cookies are all clearly detailed in Our Cookie Declaration.
• For candidates that have applied to the Company for work-finding services please see Our Candidate Privacy Notice for the Personal Data and Sensitive Personal Data that we may collect on you, together with its source.

6. How Do We Use Your Data?

6.1 We request information from the user on our online registration forms.  Here a user must provide contact information and information regarding the type of work you are seeking and your skills, qualifications and experience.  This information is used to enable us to provide you with work-finding services.  If we have trouble processing your application, this contact information is used to get in touch with you. Aaron Wallis does not use this information for any other purpose.

6.2 By submitting your CV or registering your data with Aaron Wallis we assume that you have read and agree to our candidate terms and conditions.

6.3 All personal data is processed and stored securely, for no longer than is necessary in light of the reason(s) for which it was first collected. We will comply with Our obligations and safeguard your rights under the GDPR at all times. For more details on security see section 7, below.

6.4 Our use of your personal data will always have a lawful basis, either because it is necessary for Our performance of a contract with you, because you have consented to Our use of your personal data (e.g. by subscribing to emails), or because it is in Our legitimate interests. Specifically, We may use your data for the following purposes:

6.4.1 Providing and managing your Account;

6.4.2 Providing and managing your access to Our Site;

6.4.3 Personalising and tailoring your experience on Our Site;

6.4.4 Supplying Our services to you (please note that We require your personal data in order to enter into a contract with you);

6.4.5 Personalising and tailoring Our services for you;

6.4.6 Replying to emails from you;

6.4.7 Supplying you with emails that you have opted into (you may unsubscribe or opt-out at any time by clicking the remove hyperlink or emailing remove@aaronwallis.co.uk;

6.4.8 Market research;

6.4.9 Analysing your use of Our Site and gathering feedback to enable Us to continually improve Our Site and your user experience;

6.4.10 If your personally identifiable information changes (such as office address), we will endeavour to provide a way to correct, update or remove the personal data provided to us.  This can usually be done by emailing info@aaronwallis.co.uk 

6.4.11 We may share aggregated demographic information with our clients (salary surveys, regional differences, etc.). This is not linked to any personal information that can identify any individual person.

6.4.12 We partner with other parties to provide the specific services of skills testing and psychometric profiling. When the user signs up for these services, we will share names, or other contact information that is necessary for the third party to provide these services. These parties are not allowed to use personally identifiable information except for the purpose of providing these services.

6.4.13 With your permission and/or where permitted by law, We may also use your data for marketing purposes which may include contacting you by email, telephone, text message or post with information, news and offers on Our services. We will not, however, send you any unsolicited marketing or spam and will take all reasonable steps to ensure that We fully protect your rights and comply with Our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003.

6.4.14 Third party Data Processors (including Google, Microsoft, LinkedIn, Google Analytics and Yahoo) whose content appears on Our Site may use third party Cookies, as detailed below in section 13. Please refer to section 13 for more information on controlling Cookies. Please note that We do not control the activities of such third parties, nor the data they collect and use and advise you to check the privacy policies of any such third parties.

6.4.15 You have the right to withdraw your consent to Us using your personal data at any time, and to request that We delete it using the Withdrawal of Consent form.

6.4.16 We do not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Data will therefore be retained for the following periods (or its retention will be determined on the following bases):

6.4.17 Submitted CVs are typically held for two years as defined in our data retention policy;

6.4.18 We will retain your personal data only for as long as is necessary. Different laws require us to keep different data for different periods of time.

6.4.19 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.

6.4.20 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.

6.4.21 Where the Company has obtained your consent to process your personal and sensitive personal data, we will do so in line with our data retention policy. Upon expiry of that period the Company will seek further consent from you. Where consent is not granted the Company will cease to process your personal data and sensitive personal.

7. How and Where Do We Store Your Data?

7.1 We only keep your personal data for as long as We need to in order to use it as described above in section 6, and/or for as long as We have your permission to keep it.  Consent will be requested to keep personal and sensitive data for a two-year period and further consent will be requested after that time.  The personal and sensitive data for candidates that we placed into permanent roles will be kept on our recruitment system, JobAdder, for as long as is required by HMRC.  This is currently 3 to 6 years. 

7.2 Your data will only be stored within the European Economic Area (“the EEA”) (The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein).

7.3 Data security is very important to Us, and to protect your data We have taken suitable measures to safeguard and secure data collected through Our Site.

7.4 Steps We take to secure and protect your data include:

7.4.1 All of the data you provide to Us via aaronwallis.co.uk is secured and protected via a valid HTTPS connection.;

7.4.2 Sensitive documents are uploaded via a third-party secure upload facility called https://sslupload.co.uk/

7.4.3 The data on your CV is very securely stored on the recruiting software, ‘JobAdder’, which is SSAE 16 SOC1 Type II compliant.

7.4.4 We are registered with the ICO (Z1059320). 

7.4.5 Notwithstanding the security measures that We take, it is important to remember that the transmission of data via the internet may not be completely secure and that you are advised to take suitable precautions when transmitting to Us data via the internet.

7.4.6 Candidate registration forms are transmitted securely to the SSL server via 256 bit High-grade SSL encryption. When transferred the field values on the form are additionally encrypted using JavaScript library before it is submitted to the server.  It is stored as an encrypted form on the server and can only be viewed by personnel with an encryption key.  

8. Do We Share Your Data?

8.1 Your information may be shared internally for the purposes of the recruitment exercise. This includes:

8.1.1 members of the HR and recruitment team, interviewers involved in the recruitment process, managers in the business area with a vacancy and IT staff if access to the data is necessary for the performance of their roles;

8.1.2 We will not share your data with third parties, unless your application for employment is successful and we make you an offer of employment. We will then share your data with former employers to obtain references for you, employment background check providers to obtain necessary background checks.

8.2 We need to process data to take steps at your request prior to entering into a contract with you. It may also need to process your data to enter into a contract with you.

8.3 In some cases, We need to process data to ensure that it is complying with its legal obligations. For example, it is required to check a successful applicant’s eligibility to work in the UK before employment starts.

8.4 We have a legitimate interest in processing personal data during the recruitment process and for keeping records of the process. Processing data from job applicants allows the organisation to manage the recruitment process, assess and confirm a candidate’s suitability for employment and decide to whom to offer a job. The organisation may also need to process data from job applicants to respond to and defend against legal claims.

8.5 We may process information about whether or not applicants are disabled to make reasonable adjustments for candidates who have a disability. This is to carry out its obligations and exercise specific rights in relation to employment.

8.6 Where We process other special categories of data, such as information about ethnic origin, sexual orientation, health or religion or belief, this is for equal opportunities monitoring purposes.

8.7 For some roles, We are obliged to seek information about criminal convictions and offences. Where the organisation seeks this information, it does so because it is necessary for it to carry out its obligations and exercise specific rights in relation to employment.

8.8 We will not use your data for any purpose other than the recruitment exercise for which you have applied.

8.9 We will not sell or rent your information to third parties. We will not share your information with third parties for marketing purposes.

8.10 We may pass your information to our third party Data Sub-Processors, service providers, subcontractors and other associated organisations for the purposes of completing tasks and providing services to you. However, when we use third party service providers, we disclose only the personal information that is necessary to deliver the service and we have a contract in place that requires them to keep your information secure.

8.11 In certain circumstances, We may be legally required to share certain data held by Us, which may include your personal data, for example, where We are involved in legal proceedings, where We are complying with legal obligations, a court order, or a governmental authority.

8.12 We may compile statistics about the use of Our Site including data on traffic, usage patterns, user numbers, sales, and other information. All such data will be anonymised and will not include any personally identifying data, or any anonymised data that can be combined with other data and used to identify you. We may from time to time share such data with third parties such as prospective investors, affiliates, partners, and advertisers. Data will only be shared and used within the bounds of the law.

8.13 We may sometimes use third party data processors that are located outside of the European Economic Area (“the EEA”) (The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein). Where We transfer any personal data outside the EEA, We will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within the UK and under the GDPR including:

a) Recruitment Software – JobAdder (https://www.bullhorn.com/privacy/);

b) Applicant Tracking System – Broadbean (https://www.broadbean.com/uk/privacy-policy/?r=set)

c) Forms – Jotform (https://www.jotform.com/privacy/);

d) Electronic IDentification Authentication and trust Services or eIDAS for short  - Signable (https://www.signable.co.uk/privacy-policy/);

e) Candidate Checks – Know Your Candidate (https://www.knowyourcandidate.co.uk/privacy-policy);

9. What Happens If Our Business Changes Hands?

9.1 We may, from time to time, expand or reduce Our business and this may involve the sale and/or the transfer of control of all or part of Our business. Any personal data that you have provided will, where it is relevant to any part of Our business that is being transferred, be transferred along with that part and the new owner or newly controlling party will, under the terms of this Privacy Policy, be permitted to use that data only for the same purposes for which it was originally collected by Us.

9.2 In the event that any of your data is to be transferred in such a manner, you will not be contacted in advance and informed of the changes. When contacted, you will not, however, be given the choice to have your data deleted or withheld from the new owner or controller.

10. How Can You Control Your Data?

10.1 When you submit personal data via Our Site, you may be given options to restrict Our use of your data. In particular, We aim to give you strong controls on Our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from Us which you may do by unsubscribing using the links provided in Our emails and at the point of providing your details.

10.2 You may also wish to sign up to one or more of the preference services operating in the UK: The Telephone Preference Service (“the TPS”), the Corporate Telephone Preference Service (“the CTPS”), and the Mailing Preference Service (“the MPS”). These may help to prevent you receiving unsolicited marketing. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receiving.

11. Your Right to Withhold Information

11.1 You may access certain areas of Our Site without providing any data at all. However, to use all features and functions available on Our Site you may be required to submit or allow for the collection of certain data.

11.2 You may restrict Our use of Cookies. For more information, see section 13 and Our Cookie Policy

12. How Can You Access Your Data?

You have the right to ask for a copy of any of your personal data held by Us (where such data is held). Under the GDPR, no fee is payable and We will provide any and all information in response to your request free of charge. Please contact Us for more details at sar@aaronwallis.co.uk, or using the contact details below in section 14, or completing a Subject Access Request (SAR) Form.  Alternatively, please refer to Our Data Protection Policy.

13. Our Use of Cookies

13.1 A cookie is a piece of data stored on the user's hard drive containing information about the user.  Usage of a cookie is in no way linked to any personally identifiable information while on our site.  Once the user closes their browser, the cookie simply terminates.  For instance, by setting a cookie on our site, the user would not have to log in a password more than once, thereby saving time while on our site.  If a user rejects the cookie, they may still use our site.  By using the Website, you agree that we can place these types of cookies on your device;

13.2 Most Web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. If you choose to decline cookies, you may not be able to fully experience the interactive features of Aaron Wallis services or Web sites you visit.

13.3 Our Site may place and access certain first-party Cookies on your computer or device. First-party Cookies are those placed directly by Us and are used only by Us. We use Cookies to facilitate and improve your experience of Our Site and to provide and improve Our services. We have carefully chosen these Cookies and have taken steps to ensure that your privacy and personal data is protected and respected at all times.

13.4 By using Our Site, you may also receive certain third-party Cookies on your computer or device. Third-party Cookies are those placed by websites, services, and/or parties other than Us. Third-party Cookies are used on Our Site for advertising. For more details, please refer to section 6, above, and to section 13.6 below. These Cookies are not integral to the functioning of Our Site and your use and experience of Our Site will not be impaired by refusing consent to them.  We also use Google Cookies for the use of Google Analytics and AdWords. This can also be accessed by a third party data processor, our SEM Agency, who use cookie data to optimise our account in areas such as conversion tracking and improvement.

13.5 All Cookies used by and on Our Site are used in accordance with current Cookie Law.

13.6 Before Cookies are placed on your computer or device, you will be shown a prompt at the bottom of your entry page, requesting your consent to set those Cookies. By giving your consent to the placing of Cookies you are enabling Us to provide the best possible experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of Our Site may not function fully or as intended. Also, you will be given the opportunity to allow only first-party Cookies and block third-party Cookies.

13.7 Certain features of Our Site depend on Cookies to function. Cookie Law deems these Cookies to be “strictly necessary”. These Cookies are shown below in section 13.8. Your consent will not be sought to place these Cookies, but it is still important that you are aware of them. You may still block these Cookies by changing your internet browser’s settings as detailed below in section 13.15, but please be aware that Our Site may not work properly if you do so. We have taken great care to ensure that your privacy is not at risk by allowing them.

13.8 You can manage your cookie preferences by clicking here.