PURPOSE OF OUR POLICY
UpbeatIdeas UK Ltd (Company Number 09353519) of 71-75 Shelton Street, Covent Garden, London WC2H 9JQ, England (we, us or our ) BeatMySalary website (www.beatmysalary.com) and/or mobile application and related services (Platform).
For the purposes of the Data Protection Act 1998 (UK) (Act), we are the data controller (if any).
Providing the Platform and the other products and services that we offer; and
The normal day-to- day operations of our business.
By using the Platform, you expressly approve and consent to our collection, storage, use and disclosure of your personal information, as described in this Policy and our Terms & Conditions.
WHO AND WHAT THIS POLICY APPLIES TO
We handle data in our own right and also for and on behalf of our clients and users, Candidates and Recruiters.
If, at any time, an individual provides data or other information about someone other than himself or herself, the individual warrants that they have that person's consent to provide such information for the purpose specified.
The Platform is not available to persons under the age of 18 years, unless with the permission of a parent or guardian and otherwise under appropriate supervision.
You acknowledge that in the event that our assets are transferred to or acquired by a third party, that such third party may continue to use your personal information in accordance with this policy.
BeatMySalary, a trading name of Upbeatideas UK Ltd is committed to protecting and respecting your privacy. We have created this policy to inform you and make sure we are transparent about our processes.
If you are a resident of the European Union, looking for a job – a permanent or contractor role – and using BeatMySalary to either apply for a job or using as a tool to find the right job match, this policy applies to you and we would like to share with you the details of how we process your data.
When you use our services, you trust us with your information and we want you to understand what data we collect, why we collect it and what we do with it. This is important, and we hope you will take time to read it carefully. Your new rights under GDPR will only apply once the GDPR comes into effect on 25 May 2018.
General Data Protection Regulation
In accordance with the General Data Protection Regulation (EU) 2016/679 (‘GDPR’) that comes into effect on 25 May 2018, BeatMySalary is obliged to issue a Data Processing Notice if we store your personal data in our database.
The GDPR is a new regulation which replaces the Data Protection Directive 95/46. The GDPR aims to harmonise data protection legislation across EU member states, enhancing privacy rights for individuals and providing a strict framework within which commercial organizations can legally operate.
This Data Processing Notice will outline:
- BeatMySalary as a data controller and data processor
- Which personal data BeatMySalary collects
- How BeatMySalary collects personal data
- Why we hold your data and legal basis
- Optional Marketing communication
- Cross-border transfers
- How long will we store your data?
- What are your rights under GDPR
- Automated decision making, including profiling
- Lodging a complaint
- Changes to this Data Processing Notice
- Contact details for GDPR and data queries
1. BeatMySalary as a data controller and data processor
BeatMySalary will be what’s known as the ‘Controller’ of the personal data you provide to us since we control your data on our system and we also process your data on our system when recruitment agencies or any employers would like to consume it. We are a part of Upbeatideas UK Ltd, our ultimate holding company.
Upbeatideas UK Ltdis headquartered in the UK but also has freelancers and other staff working in countries outside of the EU, such as USA, Europe, India, Ukraine, etc.
Your personal data will be stored on AWS cloud. The data is available to employers and recruitment agencies through our website interface.
Your personal data broadly forms two categories :
- Everything other than your email id, phone number and your identiy (name). This would include your job type preferences, your work location preferences, day rates, salaries (current and expected), your existing and past employer information, your educational details and your skills and language proficiency.
Your identify : That includes your name, email id & phone number.
Unless an employer/recruitment agency is particularly interested in your identity we do not reveal it. This is revealed or shared only on-demand when the employer or the recruiter thinks that you are a potential match to their job. So “a” is initially shared with the employer/recruitment agency to allow them to make an informed decision about your suitability for a job and only on-demand “b” is revealed. This is the case even if you have applied for a job yourself.
We may furthermore disclose your personal information to third parties in the event that we sell or buy any business or assets, in which case we will have to disclose your personal data to the prospective seller or buyer of such business or assets. Furthermore, we may be under a duty to disclose or share your personal data in order to comply with any legal obligation, to defend our business against a legal claim or in order to enforce or apply our standard terms of business or other agreements or to protect the rights, property or safety of our company, our customers, or other parties.
2. Which personal data BeatMySalary collects
BeatMySalary only collects personal data to help us match you with the right career opportunity.
BeatMySalary would typically collect the following personal data:
- Your full name
- Your Email id
- Your phone number (is shared with a third-party “call verification” automated system to verify your phone number through a missed call) - This is done through API
- Your current, previous and any other employer details you provide.
- Your (mobile) telephone number that you use to verify for our services.
- Your current job type (permanent or contract)
- Your current and expected salaries, remuneration or day rate
- Other Job preferences such as work location preference and current work location
- Visa or work permit status (without asking for any proof)
- Education details and degree information.
In addition to this, if you use our Linkedin authentication, we receive most of this above information from Linkedin as they share the "basic" profile information to us through the API.
We may also collect data about an individual such as information regarding their computer, network and browser. This may include their IP address. We use this to serve you the jobs and contents of the geography you reside in or related to your IP address.
3. How BeatMySalary collects personal data
We collects your personal data in the following ways:
- You apply for a job in response to a job ad on BeatMySalary
- You create one or more profile cards on our system.
- You respond to one or more invitations from the recruiters/employers.
4. Why we hold your data and legal basis
BeatMySalary will collect your information to carry out our core business and ancillary activities – for the purpose of recruitment services. In particular, BeatMySalary will collect and process your personal data for the following purposes:
- Introducing you to (potential) clients or employers when you apply for a job and the client/recruiter/employers thinks you are a potential match to a role you have applied for.
- To match your skills and automatically submit your profile cards to any potential job opportunities that our system/algorithms think you are a potential match to. This is done to minimize your efforts to apply for various jobs and also save your time to do so. Another reason is we would want to offer you the best possible chance to be shortlisted for any job that we may get on our portal and you may be a suitable match.
The following legal basis applies for processing your data if we have been in touch with you within the last three years:
We will process your data as we believe that we have legitimate interests to do so.
Your data is shared with the recruiters/employers only within our portal and not outside our portal.
Your data is always shared under only these 3 circumstances:
- if you have made an application to a job
- Your profile cards (your email id, phone number and your name is hidden in this search, while other information about you is shown) are searched by the recruiter or employers on our portal in order to send you an invite for a job.
- If the recruiter or employer has invited you with a job description and requested to share your details via an invite through our portal and you provide the consent to it by clicking “accept” on your dashboard.At this stage we share your email id, phone number and your name to the employer/recruiter.
You are entitled to withdraw consent or restrict the use of your personal information for whatever purpose at any time, without affecting the lawfulness of processing based on consent before its withdrawal. To opt out of any data processing and/ or email communications from us, please please send us an email on email@example.com for immediate removal from our database and /or further communications.
Furthermore, if you previously agreed to us holding or using your personal information, you may change your mind at any time by accessing the preferences to change your settings. Alternatively, you can email firstname.lastname@example.org. We will process the restriction of use in our marketing communications or removal of your personal information within 30 working days.
There are some circumstances in which we must disclose an individual’s information:
- As we consider necessary to preserve security, protect the rights, property and safety of the Company, its directors, employees, agents, representatives and the general public;
- Where we reasonably believe that an individual may be engaged in fraudulent, deceptive or unlawful activity that a governmental authority should be made aware of, or requires communication with a third party claimant;
- As required by any law (including the Act); and/or
- In order to sell our business or part thereof (as we may transfer data to a new owner).
Where relevant, you consent to the posting and use on the Platform of any photographs, content and/or personal information you might upload on the Platform or have otherwise provided consent to publish on the Platform, in our marketing collateral or social media channels, which we may use in order to provide our services, the marketing of our services or for the purpose of our functions and/or activities.
We may partner with or utilize third-party service providers (such as Gmail from Google, Inc) to communicate with an individual and to store contact details about an individual. These service providers may be located outside the United Kingdom, including the United States of America.
5. Other communication with you
We may contact you from time to time on emails or phone to discuss your needs about a job, your work situation or to understand what you feel about our services.
Sometimes we may also contact you if a potential job is awaiting your response and we may want to expedite the process of getting your response to the same.
We will use your data, preferences, user behaviour and information you have provided to personalize your experience, provide you with relevant service announcements and updates, and to better understand your needs and interests in relation to your job search.
We use the personal data and information you have provided to us by creating an account with us to match your profile with relevant job opportunities. Our marketing team analyses your profile to provide you with additional information which helps you to better position yourself in the job market, i.e. with invitations to networking events in your city, news and updates relevant for your area of expertise, or job alerts tailored to your preferences.
We may additionally show contents such as articles and posts related to the job your are searching for.
You are entitled to withdraw consent or restrict the use of your personal information for whatever purpose at any time, without affecting the lawfulness of processing based on consent before its withdrawal. To opt out of any data processing and/ or marketing communications from us. please click the 'unsubscribe' link in the footer of the respective email or tell us by writing to us on email@example.com where we ensure you get response within 3-5 business working days (in UK) and we provide a reasonable solution within 30 days of getting all the necessary information from you.
6. Cross-border transfers
As all our teams are connected via the cloud-based tools, your personal information may be held on any instance of the AWS and be backed up in another country server of AWS or instance. By using our service, you agree to the transfer of information to countries outside of your country of residence, including to the United States, which may provide for different data protection rules than in your country. We take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Data Processing policy.
BeatMySalary also uses various other software/cloud providers who may transfer your personal data outside the EEA. BeatMySalary will ensure that adequate safeguards are in place to protect your data from being misused.
Please also note that if we transfer personal data to our clients, this data may be transferred outside the EEA for the purpose of our recruitment services. BeatMySalary has reasonable safeguards in place to ensure a safe data transfer outside the EEA. However please note that if the Client/Recruiters/Employers uses your data they qualify as data controller as they determine the purposes and means of your personal data and as such our Client/Recruiters/Employers are also responsible for processing your data.
If you have any further queries about data transfer outside the EEA, please contact firstname.lastname@example.org
7. How long will we store your data?
We give you full control of your data.
The controls you can execute are :
- You may opt to become completely non-searchable from the Client/Recruiters/Employers - can be done using your “Settings”
- You may opt to just switch off one or more profile cards and they no longer can be searched by the Client/Recruiters/Employers
- If you would want your data to be completed deleted from our servers then you need to email us on email@example.com requesting the same.
8. What are your rights under GDPR
Under GDPR you are entitled to various rights:
- You can 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. This means you can login using our website and update any information you like.
- You can 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). This means should you wish to be removed from our database, please email firstname.lastname@example.org. We will review and process your request within 30 days. We may not acknowledge that we have removed your information from the system but we would ensure we do it. If you require us to specifically acknowledge you of completion, please request this on the same email.
- You can object to the 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. This means we will only send you marketing communication if you have opted in. You can opt out at any time by clicking the 'unsubscribe' link in the footer of the email in question and will be removed from the any marketing mailing list.
- You can 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.
- You can request the transfer of your personal information to another party in certain formats, if practicable.
All such requests need to be addressed to email@example.com
The fact that you can lodge a request does not necessarily mean we will grant your request, at all times, especially if BeatMySalary has a legitimate interest that outweighs your interests as an individual.
BeatMySalary will, however, provide information without undue delay and in any event within one month (this can be extended to 2 months in exceptional circumstances) of the receipt of the request, however where requests are manifestly unfounded or excessive, in particular, because of its repetitive character, BeatMySalary may refuse to act upon your request. In that case, we will inform you within one month of the request of the possibility of lodging a complaint with a supervisory authority (in the UK this will be the ICO) or seeking a judicial remedy.
9. Automated decision making, including profiling
BeatMySalary will conduct any forms of automated processing of your personal data consisting of the use of personal data to evaluate certain personal aspects relating to you, in particular, to analyze or predict aspects concerning your job preferences, job roles interests, salary expectations. We will make decisions that are in your best interest of landing you in the right job.
10. Lodging a complaint
If you feel that your rights as a data subject have been breached, you are entitled to lodge a complaint with the national supervisory authority (in the UK this will be the Information Commissioner’s Office via https://ico.org.uk/concerns/) or seek a legal remedy. However, we strongly encourage you to contact us via firstname.lastname@example.org
11. Changes to this Data Processing Notice
Any changes we make to our Data Processing Notice in the future will be posted on this website and where appropriate (if we make any significant changes that may affect your rights as a data subject), notified to you by email. Please check back frequently to see any updates or changes to this Data Processing Notice.
12. Contact details for GDPR and data queries
If you have any questions, comments, and requests regarding your personal data or this policy, please address them to:
Head of Compliance
Phone +44 (0)7404442828
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We use the following cookies:
- Strictly necessary cookies. These are cookies that are required for the operation of the Platform. They include, for example, cookies that enable you to log into secure areas of the Platform or make use of payment services.
- Analytical/performance cookies. They allow us to recognize and count the number of visitors and to see how visitors move around the Platform when they are using it. This helps us to improve the way the Platform works, for example, by ensuring that users are finding what they are looking for easily.
- Functionality cookies. These are used to recognize you when you return to the Platform. This enables us to personalize our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
- Targeting cookies. These cookies record your visit to the Platform, the pages you have visited and the links you have followed. We will use this information to make the Platform more relevant to your interests. We may also share this information with third parties for this purpose.
THE SAFETY & SECURITY OF DATA
The security of your personal information is important to us. We will take all reasonable precautions to protect an individual’s data from unauthorized access. This includes using passwords, encryption, appropriately securing our physical facilities and electronic networks.
The security of online transactions and the security of communications sent by electronic means or by post cannot be guaranteed. Each individual that provides information to us via the internet or by post does so at their own risk. We cannot accept responsibility for misuse or loss of, or unauthorized access to, data where the security of information is not within our control.
We are not responsible for the privacy or security practices of any third party (including third parties that we are permitted to disclose an individual’s data to in accordance with this policy or any applicable laws). The collection and use of an individual’s information by such third parties may be subject to separate privacy and security policies.
If an individual suspects any misuse or loss of, or unauthorized access to, their data, they should let us know immediately and do so in writing and send it to email@example.com
Note : We do not have a telephone based call center support or handle any issues over phone calls.
We are not liable for any loss, damage or claim arising out of another person’s use of the data where we were authorized to provide that person with the data.
HOW TO ACCESS AND/OR UPDATE INFORMATION
The Act gives you the right to request from us the data that we have about you. You may review, edit, correct or delete any of your personal information on the Platform.
If an individual cannot update his or her own information, we will correct any errors in the data we hold about an individual within 30 working days of receiving written notice from them about those errors. The written notice must be sent to firstname.lastname@example.org, if not then, the request would not be considered.
It is an individual’s responsibility to provide us with accurate and truthful data. We cannot be liable for any information that is provided to us that is incorrect.
We may charge an individual a reasonable fee for our costs incurred in meeting any of their requests to disclose the data we hold about them.
Access to your personal information may be denied on certain grounds including, for example: it is unlawful; it may have an unreasonable impact upon the privacy of other individuals; or your request is frivolous or vexatious. If we deny you access we will provide our reason for doing so at the time of your request.
COMPLAINTS AND DISPUTES
If an individual has a complaint about our handling of their data, they should address their complaint in writing to the details below.
If we have a dispute regarding an individual’s data, we both must first attempt to resolve the issue directly between us.
If we become aware of any unauthorized access to an individual’s data we will inform them at the earliest practical opportunity once we have established what was accessed and how it was accessed.
ADDITIONS TO THIS POLICY
All such enquiries or complaints will be taken seriously and will be handled as soon as reasonably practicable.
To the extent permitted by law, we shall not be liable for any loss or damage arising from any disclosure (inadvertent or otherwise) of any personal information (including as relates to credit cards / debit cards), nor for any error, omission or inaccuracy with respect to any information so disclosed and used whether or not in pursuance of a legal process or otherwise.
Last updated on 24 May, 2018