Privacy Policy
Updated October 2023
Square One Holdings Limited and its subsidiaries (”We”, “Us” “Square One”) are committed to protecting and respecting your privacy.
Any mention of “Square One” means our subsidiaries (detailed below), our ultimate holding company and its subsidiaries, our associated companies as defined in section 1159 of the UK Companies Act 2006 (our Group).
Square One Resources Limited; and
Square One Resources Sp. z o.o.
This notice sets out the basis on which any personal data We collect from you, or that you provide to us, will be processed by Us.
Data Protection Legislation
To the extent the UK GDPR applies, the law of the United Kingdom or of a part of the United Kingdom which relates to the protection of personal data, has the meaning given to it in section 3(10) (as supplemented by section 205(4)) of the Data Protection Act 2018.
To the extent the EU GDPR applies, the law of the European Union or any member state of the European Union to which the party is subject, which relates to the protection of personal data has the meaning General Data Protection Regulation ((EU) 2016/679). The Legislation aims to harmonise data protection legislation across EU member states, enhancing privacy rights for individuals and providing a strict framework within which commercial organisations can legally operate.
Please read the following carefully to understand our views and practices regarding your personal data and how We will treat it.
For the purposes of data protection legislation in force from time to time the data controllers are the following companies detailed below:
Square One Holdings Limited / Square One Resources Limited of 120 Moorgate, London EC2M 6UR, UK; and
Square One Resources Sp. z o.o. of ul. Pulawska 2, 02-566 Warsaw, Poland
Who We Are and What We do
We are a recruitment agency and recruitment business, in the UK this is defined in the United Employment Agencies and Employment Businesses Regulations 2003 (our business). In Poland We are governed under the Act of April 20, 2004 on promotion of employment and labour market institutions.
We collect the personal data of the following types of people to allow Us to undertake our business:
Data Privacy Principles
The core data privacy principles below are the foundation of this policy:
Lawfulness, Fairness and Transparency
Square One shall process personal information fairly, and in accordance with this policy and applicable laws.
Data Accuracy
Square One will take all reasonable steps to ensure that personal information is accurate and complete and will rectify or erase any incorrect personal information without delay.
Purpose Limitation
Square One will ensure that personal information collected is for specified, explicit and legitimate purposes and only to the extent necessary to fulfil those purposes.
Data Retention
Square One will only keep personal data for as long as is necessary to fulfil the purposes for which it was collected or to comply with applicable law/for tax purposes/for Government or regulatory requirements.
Data Security
All personal information collected will be processed in a secure manner.
Information We May Collect
This is information about you that you give Us by filling in forms on our site or by corresponding with Us by phone, e-mail or otherwise. It includes information you provide to enter our database, subscribe to our services, attend our events, or other social media functions on our site, enter a competition, promotion or survey, and when you report a problem with our site or services.
The information you give Us or We collect about you may include your name, address, private and corporate e-mail address and phone number, financial information, compliance documentation and references verifying your qualifications and experience and your right to work in the relevant country of services, curriculum vitae and photograph, links to your professional profiles available in the public domain including but not limited to e.g. LinkedIn, Twitter, Facebook or corporate website.
Information We Obtain From Other Sources
This is information We obtain about you from other sources such as LinkedIn, corporate websites, job board websites (online CV databases and job advert applications), personal recommendations, and any other publicly available website or platform.
We work closely with third parties including, business partners, sub-contractors in technical, professional, payment and other services, advertising networks, analytics providers, search information providers, credit reference agencies, professional advisors.
We may receive information about you from them for the purposes of our recruitment services.
Purposes of the Processing and the Legal Basis for the Processing
We use information held about you in the following ways:
The core service We offer to our candidates and clients is the introduction of candidates to our clients for the purpose of temporary or permanent engagement. However, our service expands to supporting individuals throughout their career and to supporting businesses’ resourcing needs and strategies.
To carry out our obligations arising from any contracts We intend to enter into or have entered into between you and Us and to provide you with the information, products and services that you request from Us or We think will be of interest to you because it is relevant to your career or to your organisation.
To provide you with information about other goods and services We offer that are similar to those that you have already purchased, been provided with or enquired about.
Our legal basis for the processing of personal data is our legitimate interests, described in more detail below, although We will also rely on contractual obligations to which you are subject, legal obligations and consent for specific uses of data.
We will rely on contractual obligations if We are negotiating or have entered into a placement agreement with you or your organisation or any other contract to provide services to you or receive services from you or your organisation.
We will rely on legal obligation in some cases, where We are required by law or regulation to process your data.
Our Legitimate Interests
Our legitimate interests in collecting and retaining your personal data is described below:
As a recruitment business and recruitment agency We introduce candidates to clients for permanent employment, temporary worker placements or independent professional contracts. The exchange of personal data of our candidates’ and our clients’ contact details is a fundamental part of this process.
In order to support our candidates’ career aspirations and our clients’ resourcing needs, We require a database of candidate and client personal data. The database will contain historical information as well as current resourcing requirements.
To maintain, expand and develop our business We need to record the personal data of prospective candidate and client contacts.
Cooperating with law enforcement agencies/courts, management of legal disputes/claims. Processing is necessary for the purpose of the legitimate interests pursued by Square One, which include the protection of company assets and protecting its legal interests.
Consent
Should We want or need to obtain consent to lawfully process your data We will request your consent orally, by email or by an online process for the specific activity We require consent for and record your response on our system. Where consent is the lawful basis for our processing you have the right to withdraw your consent to this particular processing at any time.
Do You Have to Provide Us With Personal Data?
You may refuse to give Us your personal and sensitive personal data. Furthermore, you have the right to ask Us to delete, change or stop processing your data that We have already received or collected. If you do not provide Us with personal or sensitive personal data, or if you request a restriction of processing however, We may not be able to provide you with the services that you have requested and that are stated in this policy.
IP Addresses and Cookies
Square One or its website provider may collect information about your computer including where available your IP address, operating system and browser type for system administration. This is data about our users’ browsing actions and patterns and does not identify any individual.
For the same reason We may obtain information about your usage of our website by using a cookie file which is stored on the hard drive of your computer. Cookies contain information that is transferred to your computer’s hard drive. They help Us to improve our site and to deliver a better and more personalised service and analyses of our traffic.
They enable Us:
These cookies allow Us to distinguish you from other users of our website, which helps Us to provide you with a good experience when you browse our website and also allows us to improve our site. The cookies We use are "analytical" cookies. They allow Us to recognise and count the number of visitors and to see how visitors move around the site when they are using it. We do not share the information the cookies collect with any third parties.
A breakdown of the list of cookies that our website uses is as follows:
You may refuse to accept cookies by activating the setting on your browser, which allows you to refuse the setting of cookies. However, if you select this setting, you may be unable to access certain parts of our website.
Disclosure of Your Information Inside and Outside of the UK and the EEA
We will share your personal information with:
Selected third parties including:
We will disclose your personal information to third parties:
We will provide your data to potential employers that have notified Us of vacancies for which you may be qualified for, but only with your express permission. It is your responsibility to notify Us of any employers to whom you do not wish to submit your details.
The lawful basis for the third-party processing will include:
Where We Store and Process Your Personal Data
The data that We collect from you may be transferred to, and stored at, a destination outside the UK or European Economic Area (”EEA”). It may be transferred to third parties outside of the UK or the EEA for the purpose of our recruitment services. It may also be processed by staff operating outside the UK or the EEA who work for Us or for one of our suppliers’. This includes staff engaged in, among other things, our recruitment services and the provision of support services. By submitting your personal data, you agree to this processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy notice.
All information you provide to Us is stored on our secure servers. Where We have provided you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
Unfortunately, the transmission of information via the Internet is not completely secure. So, whilst We will do our best to protect your personal data, We cannot ensure the security of your data transmitted to our site. Any transmission is at your own risk. Once We have received your information We will use strict procedures and security features to prevent unauthorised access.
How Long Will We Store Data
Retention of Your Data
We understand our legal duty to retain accurate data and only retain personal data for as long as We need it for our legitimate interests and that you are happy for Us to do so.
We do the following to try to ensure that the data We hold on you is accurate:
Your Rights
You have the right to request Us not to disclose any of your personal data or information or to pass information to third parties as well as the following:
Review of the information We hold about you:
Our site may from time to time contain links to and from our advertisers’, partners’ and affiliates’ websites. If you follow a link to their sites, please note that these sites have their own privacy policy and that Square One does not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these sites.
Access to Information
The Legislation gives you various rights including the right to access information held about you. Your right to access can be exercised in accordance with the Legislation.
A subject access request should be submitted to gdpr@squareoneresources.com. No fee will apply unless the requests from a data subject are manifestly unfounded or excessive, in particular because of their repetitive character. In such circumstances, We may charge a fee or refuse to act on the request.
Changes to Our Privacy Notice
Any changes We make to our privacy notice in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our privacy notice.
Contact
Questions, comments and requests regarding this privacy notice are welcomed and should be addressed to gdpr@squareoneresources.com.
To the extent the UK GDPR applies, the law of the United Kingdom or of a part of the United Kingdom which relates to the protection of personal data, has the meaning given to it in section 3(10) (as supplemented by section 205(4)) of the Data Protection Act 2018.
To the extent the EU GDPR applies, the law of the European Union or any member state of the European Union to which the party is subject, which relates to the protection of personal data has the meaning General Data Protection Regulation ((EU) 2016/679). The Legislation aims to harmonise data protection legislation across EU member states, enhancing privacy rights for individuals and providing a strict framework within which commercial organisations can legally operate.
Please read the following carefully to understand our views and practices regarding your personal data and how We will treat it.
For the purposes of data protection legislation in force from time to time the data controllers are the following companies detailed below:
Square One Holdings Limited / Square One Resources Limited of 120 Moorgate, London EC2M 6UR, UK; and
Square One Resources Sp. z o.o. of ul. Pulawska 2, 02-566 Warsaw, Poland
Who We Are and What We do
We are a recruitment agency and recruitment business, in the UK this is defined in the United Employment Agencies and Employment Businesses Regulations 2003 (our business). In Poland We are governed under the Act of April 20, 2004 on promotion of employment and labour market institutions.
We collect the personal data of the following types of people to allow Us to undertake our business:
- Prospective and placed candidates for permanent or temporary roles;
- Prospective and live client contacts;
- Supplier contacts to support our services;
- Employees, consultants, temporary workers.
Data Privacy Principles
The core data privacy principles below are the foundation of this policy:
Lawfulness, Fairness and Transparency
Square One shall process personal information fairly, and in accordance with this policy and applicable laws.
Data Accuracy
Square One will take all reasonable steps to ensure that personal information is accurate and complete and will rectify or erase any incorrect personal information without delay.
Purpose Limitation
Square One will ensure that personal information collected is for specified, explicit and legitimate purposes and only to the extent necessary to fulfil those purposes.
Data Retention
Square One will only keep personal data for as long as is necessary to fulfil the purposes for which it was collected or to comply with applicable law/for tax purposes/for Government or regulatory requirements.
Data Security
All personal information collected will be processed in a secure manner.
Information We May Collect
This is information about you that you give Us by filling in forms on our site or by corresponding with Us by phone, e-mail or otherwise. It includes information you provide to enter our database, subscribe to our services, attend our events, or other social media functions on our site, enter a competition, promotion or survey, and when you report a problem with our site or services.
The information you give Us or We collect about you may include your name, address, private and corporate e-mail address and phone number, financial information, compliance documentation and references verifying your qualifications and experience and your right to work in the relevant country of services, curriculum vitae and photograph, links to your professional profiles available in the public domain including but not limited to e.g. LinkedIn, Twitter, Facebook or corporate website.
Information We Obtain From Other Sources
This is information We obtain about you from other sources such as LinkedIn, corporate websites, job board websites (online CV databases and job advert applications), personal recommendations, and any other publicly available website or platform.
We work closely with third parties including, business partners, sub-contractors in technical, professional, payment and other services, advertising networks, analytics providers, search information providers, credit reference agencies, professional advisors.
We may receive information about you from them for the purposes of our recruitment services.
Purposes of the Processing and the Legal Basis for the Processing
We use information held about you in the following ways:
The core service We offer to our candidates and clients is the introduction of candidates to our clients for the purpose of temporary or permanent engagement. However, our service expands to supporting individuals throughout their career and to supporting businesses’ resourcing needs and strategies.
To carry out our obligations arising from any contracts We intend to enter into or have entered into between you and Us and to provide you with the information, products and services that you request from Us or We think will be of interest to you because it is relevant to your career or to your organisation.
To provide you with information about other goods and services We offer that are similar to those that you have already purchased, been provided with or enquired about.
Our legal basis for the processing of personal data is our legitimate interests, described in more detail below, although We will also rely on contractual obligations to which you are subject, legal obligations and consent for specific uses of data.
We will rely on contractual obligations if We are negotiating or have entered into a placement agreement with you or your organisation or any other contract to provide services to you or receive services from you or your organisation.
We will rely on legal obligation in some cases, where We are required by law or regulation to process your data.
Our Legitimate Interests
Our legitimate interests in collecting and retaining your personal data is described below:
As a recruitment business and recruitment agency We introduce candidates to clients for permanent employment, temporary worker placements or independent professional contracts. The exchange of personal data of our candidates’ and our clients’ contact details is a fundamental part of this process.
In order to support our candidates’ career aspirations and our clients’ resourcing needs, We require a database of candidate and client personal data. The database will contain historical information as well as current resourcing requirements.
To maintain, expand and develop our business We need to record the personal data of prospective candidate and client contacts.
Cooperating with law enforcement agencies/courts, management of legal disputes/claims. Processing is necessary for the purpose of the legitimate interests pursued by Square One, which include the protection of company assets and protecting its legal interests.
Consent
Should We want or need to obtain consent to lawfully process your data We will request your consent orally, by email or by an online process for the specific activity We require consent for and record your response on our system. Where consent is the lawful basis for our processing you have the right to withdraw your consent to this particular processing at any time.
Do You Have to Provide Us With Personal Data?
You may refuse to give Us your personal and sensitive personal data. Furthermore, you have the right to ask Us to delete, change or stop processing your data that We have already received or collected. If you do not provide Us with personal or sensitive personal data, or if you request a restriction of processing however, We may not be able to provide you with the services that you have requested and that are stated in this policy.
IP Addresses and Cookies
Square One or its website provider may collect information about your computer including where available your IP address, operating system and browser type for system administration. This is data about our users’ browsing actions and patterns and does not identify any individual.
For the same reason We may obtain information about your usage of our website by using a cookie file which is stored on the hard drive of your computer. Cookies contain information that is transferred to your computer’s hard drive. They help Us to improve our site and to deliver a better and more personalised service and analyses of our traffic.
They enable Us:
- to estimate our audience size and usage pattern;
- to store information about your preferences and so allow Us to customise our site according to your individual interests;
- to speed up your searches;
- to recognise you when you return to our site.
These cookies allow Us to distinguish you from other users of our website, which helps Us to provide you with a good experience when you browse our website and also allows us to improve our site. The cookies We use are "analytical" cookies. They allow Us to recognise and count the number of visitors and to see how visitors move around the site when they are using it. We do not share the information the cookies collect with any third parties.
A breakdown of the list of cookies that our website uses is as follows:
- Google Analytics - used for tracking and monitoring the behaviour of users on the website to understand user experience and how users interact with the website
- Google Tag Manager - a container used to house all additional tracking scripts added to the site to understand user behaviour and to help with page speed
- Cookie to remember pagination when on the jobs/blogs - remembers a user’s pagination when visiting job or blog listing pages, so your place and search terms are retained
You may refuse to accept cookies by activating the setting on your browser, which allows you to refuse the setting of cookies. However, if you select this setting, you may be unable to access certain parts of our website.
Disclosure of Your Information Inside and Outside of the UK and the EEA
We will share your personal information with:
- Any member of our group both in the UK, the EEA and outside of the EEA.
Selected third parties including:
- Clients for the purpose of introducing candidates to them;
- Candidates for the purpose of arranging interviews and engagements;
- Clients, business partners, suppliers and sub-contractors for the performance and compliance obligations of any contract We enter into with them or you;
- Subcontractors including service providers for contract, compliance and financial services
- Credit reference agencies, our insurance broker, compliance partners and other sub-contractors for the purpose of assessing your suitability for a role where this is a condition of Us entering into a contract with you.
We will disclose your personal information to third parties:
- In the event that we sell or buy any business or assets, in which case We will disclose your personal data to the prospective seller or buyer of such business or assets.
- If Square One substantially transfer all of its assets, or are acquired by a third party, in which case personal data held will be one of the transferred assets.
- If We are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms and conditions and other agreements; or to protect the rights, property, or safety of Square One, our customers’, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction. Where potential employers require Us to assist them in the carrying out of criminal record searches or police checks you agree that We have the right to use your data for this purpose.
- Legal provisions requiring the transfer of data to a specific public institution (Police, court, prosecutor's office, etc.).
- Internal needs of Square One regarding obtaining a specific service to support the achievement of business goals (entities providing legal advisory services, legalisation of the stay of foreigners, booking hotel accommodation, sending mass-mailings, etc.).
We will provide your data to potential employers that have notified Us of vacancies for which you may be qualified for, but only with your express permission. It is your responsibility to notify Us of any employers to whom you do not wish to submit your details.
The lawful basis for the third-party processing will include:
- Their own legitimate interests in processing your personal data, in most cases to fulfil their internal resourcing needs;
- Satisfaction of their contractual obligations to Us as our data processor;
- For the purpose of a contract in place or in contemplation;
- To fulfil their legal obligations.
Where We Store and Process Your Personal Data
The data that We collect from you may be transferred to, and stored at, a destination outside the UK or European Economic Area (”EEA”). It may be transferred to third parties outside of the UK or the EEA for the purpose of our recruitment services. It may also be processed by staff operating outside the UK or the EEA who work for Us or for one of our suppliers’. This includes staff engaged in, among other things, our recruitment services and the provision of support services. By submitting your personal data, you agree to this processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy notice.
All information you provide to Us is stored on our secure servers. Where We have provided you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
Unfortunately, the transmission of information via the Internet is not completely secure. So, whilst We will do our best to protect your personal data, We cannot ensure the security of your data transmitted to our site. Any transmission is at your own risk. Once We have received your information We will use strict procedures and security features to prevent unauthorised access.
How Long Will We Store Data
Retention of Your Data
We understand our legal duty to retain accurate data and only retain personal data for as long as We need it for our legitimate interests and that you are happy for Us to do so.
We do the following to try to ensure that the data We hold on you is accurate:
- Prior to making an introduction We check that We have accurate information about you;
- We try to keep in touch with you so you can let Us know of changes to your personal data;
- We may archive part or all of your personal data, retain it on our financial systems only or delete all or part of the data from our main Customer Relationship Manager (CRM) system;
- We may pseudonymise parts of your data, particularly following a request for restriction or erasure of your data, to ensure that We do not re-enter your personal data on to our database, unless requested to do so. For your information, pseudonymised data is created by taking identifying fields within a database and replacing them with artificial identifiers, or pseudonyms.
Your Rights
You have the right to request Us not to disclose any of your personal data or information or to pass information to third parties as well as the following:
Review of the information We hold about you:
- Request correction of the personal information that We hold about you. This enables you to have any incomplete or inaccurate information We hold about you corrected.
- Request erasure of your personal information. This enables you to ask Us to delete or remove personal information where there is no good reason for Us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
- Object to processing of your personal information where We are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where We are processing your personal information for direct marketing purposes.
- Request the restriction of processing of your personal information. This enables you to ask Us to suspend the processing of personal information about you, for example if you want Us to establish its accuracy or the reason for processing it.
- Request the transfer of your personal information to another party in certain formats, if practicable.
- Make a complaint to the relevant supervisory body, as detailed below:
- In the United Kingdom is the Information Commissioner’s Office. The ICO can be contacted through this link: https://ico.org.uk/concerns/.
- In Poland please contact the President of the Personal Data Protection Office, contacts through this link https://uodo.gov.pl/en.
Our site may from time to time contain links to and from our advertisers’, partners’ and affiliates’ websites. If you follow a link to their sites, please note that these sites have their own privacy policy and that Square One does not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these sites.
Access to Information
The Legislation gives you various rights including the right to access information held about you. Your right to access can be exercised in accordance with the Legislation.
A subject access request should be submitted to gdpr@squareoneresources.com. No fee will apply unless the requests from a data subject are manifestly unfounded or excessive, in particular because of their repetitive character. In such circumstances, We may charge a fee or refuse to act on the request.
Changes to Our Privacy Notice
Any changes We make to our privacy notice in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our privacy notice.
Contact
Questions, comments and requests regarding this privacy notice are welcomed and should be addressed to gdpr@squareoneresources.com.
