Privacy Notice (when personal data is obtained from the data subject)
Education Supply Pool
Education Supply Pool 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.
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 the terms of
the following statement.
1. Collection and use of personal data
a. 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. The legal bases we rely upon to offer these services to you are:
• Employment agencies act 1973 and the conduct of employment agencies and
employment business regulations 2003 ESP have a legal obligation to check the
candidates rights to work in the UK. We will check your identification, work history and
criminal records to enable you to work with children and vulnerable adults.
Education Supply Pool under the employment agencies act we are obliged to hold your
data for at least 12 months after it was last used. Under finance act legislation, payroll data
must be held for six years. Other acts impose different requirements. After the final
obligation has been satisfied or following twelve months of non-usage, we will contact you
and ask you if you want to keep your details on our database. If you do not indicate that
you wish your details to be retained on our database, we will archive your account.
b. Legitimate interest
For the purpose of training and monitoring phone calls may be recorded and kept on
record for six weeks. Following the six weeks these recordings will be erased from the
secure server on which they are stored (within the EU).
c. Recipient/s of data
The Company will process your personal data and/or sensitive personal data with the
• BackOffice Support Services (Payroll)
• NEST Corporation (pension provider)
• Atlantic Data (DBS Checks)
• Access Group (Secure CRM Database Provider)
• HMRC (Tax)
• Kane Communications (Telephone provider)
d. Statutory/contractual requirement
Your personal data is required by law and/or a contractual requirement (e.g. our client may
require this personal data), and/or a requirement necessary to enter into a contract. You
are required to provide us with your identification, satisfactory references, rights to work in the UK and an
enhanced DBS check. You are obliged to provide the personal data and if you do not the
consequences of failure to provide the data are:
• Inability to honour our contractual obligation to find you work.
We have a statutory obligation to share your personal data with HMRC and statutory
2. Data Retention
The Company 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.
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.
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.
Where the Company has obtained your consent to process your personal and sensitive
personal data, we will do so in line with our 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 data if we do not have a
legal basis to keep it.
3. Your rights
• The right to be informed about the personal data the Company processes on you;
• The right of access to the personal data the Company processes on you;
• The right to rectification of your personal data;
• The right to erasure of your personal data in certain circumstances;
• The right to restrict processing of your personal data;
• The right to data portability in certain circumstances;
• The right to object to the processing of your personal data that was based on a public or
• The right not to be subjected to automated decision making and profiling; and
• The right to withdraw consent at any time.
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 contacting Claire
Carter on 01633 546100 or email firstname.lastname@example.org
4. Complaints or queries
If you wish to dispute this privacy notice or any of the procedures set out in it please
Claire Carter on 01633 546100 or email email@example.com.
You also have the right to raise concerns with Information Commissioner’s Office on 0303
123 1113 or at https://ico.org.uk/concerns/, or any other relevant supervisory authority
should your personal data be processed outside of the UK, if you believe that your data
protection rights have not been adhered to.