Data Protection & Privacy Policy

for NEW MINDS RESOURCING LIMITED (“NEW MINDS” “we” “our” “us”)

Who are we?

NEW MINDS is a consultancy, specialising in the provision of resourcing strategy and recruitment solutions to growing consultancy businesses. We provide consultancy services and permanent and temporary recruitment services to our clients looking to recruit and manage talent for their businesses.

NEW MINDS aims to comply with best practice and local and privacy legislation in the jurisdiction in which it operates with respect to the various individuals (“data subjects”) that interact with our business:

“Website Users”: Individuals who access and/or register on and/or contact NEW MINDS through any NEW MINDS website including but not limited to www.new-minds.co.uk. By visiting https://www.new-minds.co.uk (the “Website”) you are accepting and consenting to the practices described in this Policy as well as consenting to NEW MINDS use of Cookies in accordance with the terms of the Cookie Policy.
“Candidate(s)”: means an individual candidate (or potential candidate) for a role within a Client, or within New Minds, as an employee, worker or otherwise.
“Client(s)”: means UK and international businesses who are clients of NEW MINDS and to whom NEW MINDS provides consultancy (including personnel resourcing needs and strategies) and/or recruitment services, including prospective clients who are yet to enter into a contract with NEW MINDS ; and
Referees and sources;
Employees, associates, and potential employees and associates of NEW MINDS.

If you have any specific queries relating to this Privacy Policy please e-mail NEW MINDS at privacy@new-minds.co.uk

Privacy Policy

NEW MINDS is committed to protecting and respecting your privacy.

This Policy deals with the following issues:

The personal data we collect
Where does New Minds collect the personal data about you from?
How New Minds uses your personal data
Legal basis for using your personal data
Data storage and security
International and web-based transfer
How long do we keep your personal data for?
What rights do you have in relation to the data we hold on you?

Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

Modifications: NEW MINDS reserves the right to modify or amend this Privacy Policy at any time and for any reason. If there are material changes to the Privacy Policy, we will post those changes here and take appropriate measures to keep you informed. Please check this Privacy Policy from time to time to stay informed.

Links: Our Website may, from time to time, contain links to and/or from the Website of our Clients, partner networks, advertisers, and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.

Contact us: If you have any questions about your personal information or this Policy, please e-mail NEW MINDS at privacy@new-minds.co.uk

1. The personal data we collect

We collect, use, process and store a variety of personal data that is necessary to provide our services to our Clients.

Website User Data

When a Website User visits our Website we use third party services, Google Analytics and HubSpot, to collect standard internet log information and details of visitor behaviour patterns. This information is only processed in a way which does not identify anyone personally or the company. Please refer to our Cookie Policy for further details.

A Website User may also choose to contact NEW MINDS through the Website and the data collected will typically compromise an individual’s business contact details, such as name, telephone number, e-mail address, and job title. Once they have done so NEW MINDS will classify them as a Client and they are covered by the applicable sections of this Policy.

Candidate Data

If you are an individual potential Candidate, we collect the information necessary to be enable us and our Clients to assess your eligibility through the different stages of recruitment. This relates to our business, to the extent that it relates to placing Candidates with Clients but also applications to work for NEW MINDS.

This may include both existing data and information we create with you, including:

contact information (e-mail address, postal address, telephone number);
curriculum vitae (which will also include education history, languages, qualifications, career history, professional experience and executive competencies, professional style profile etc;
compensation details (where permitted by applicable legislation);
information relating to references and referees;
identification data (civil/marital status, gender, nationality)
work performance and right to work;
personality and psychometric tests;
interview notes as well as interview recordings and transcripts of such recordings (if applicable);
offer letters;
contact history in respect of your interactions with NEW MINDS and Clients (where applicable);
compliance and identity documentation; and
information from other sources, including but not limited to references and links to your professional profiles available in the public domain e.g., LinkedIn, business Facebook or corporate website.

Depending on the nature of a role considered for, and also depending upon the applicable jurisdiction, our Clients may need to collect and process special categories of personal data about you which may include information about your health (including details of any sick leave taken during your previous roles), details of any disability, details of any offences you have committed or are alleged to have committed and whether you are a member of any professional or trade associations. In addition, a Client may ask you to complete an equality monitoring form. This will be a matter between you the Client directly. Very occasionally NEW MINDS will have incidental access to these types of “sensitive data” but will not process or use this data without your express consent.

Our Clients expect that we identify the best individuals to fill roles within their organisations. So, we need to research systems, online databases, and other information sources, and talk to many individuals. Besides our Clients, these will include referees and sources to help inform the recruitment decision-making process.

The nature of this work means we are required to process personal data quickly, confidentially, and often without reference to you, the data subject. Accordingly, we process such data in accordance with the Data Protection Laws, regularly using our legitimate interest where it is not possible or feasible to speak directly with the data subject. Beyond this, we will seek consent in the circumstances explained later in this Privacy Policy.

Client or Supplier Data

If you are a Client or NEW MINDS supplier, we will collect and use information about your company and individuals within your company for the purposes of fulfilling our obligations to you and furthering our business relationship. Data collected will typically compromise an individual’s business contact details, such as name, telephone number, e-mail address, job title, and business record related to our services.

Referee or Source Data

If you are an individual who provides a personal reference, referee, or feedback for a Candidate (depending on the circumstance we may classify you as a Referee or Source), we may collect and process your contact details, certain professional and employment details (such as title, occupation, qualifications and employment history) and your connection to the Candidate. We may collect this information directly from you, the Candidate, or from publicly available sources such as your professional networking profile. We will use this information to gather information on the relevant potential Candidate such as your connection to, experience with, and opinion about such potential Candidates. Any reference or feedback you provide about a Candidate would not be attributed to you if shared with third parties, unless you consented to this. We may also use your contact details to contact you in relation to any of our services that we believe may be of interest to you. Additionally, we may also use the data for other business purposes, including data analytics, benchmarking, and statistic purposes.

2. Where does New Minds collect the personal data about you from?

NEW MINDS uses different methods to collect data from and about you depending on your relationship with NEW MINDS. These methods include:

Directly from you

If you are a Candidate, this is information you provide while searching for a new opportunity and/or during the different recruitment stages. For example, by filling in a Candidate on-line application form or by corresponding with us in person, by phone, e-mail or otherwise. For other data subjects this might include information you provide when you attend our events, participate in discussion boards or other social media functions on our site, enter a promotion or survey, contribute to a market or insights report, or interact with us at a conference, and when you report a problem with our site.

From an agent/third party acting on your behalf

For example, this may be your own limited company or from another recruitment business or agency where you are applying to work for NEW MINDS.

Through publicly available sources with professional relevance, including the following:

Professional social media and networking sites (including LinkedIn);
Job Boards on which you have registered your details;
Online curriculum vitae libraries; and
Corporate websites.

By Reference or word-of-mouth

For example, you may be recommended by a friend, a former employer, a former colleague or even a present employer or we may get a reference from your previous employer or a named referee included on your application form or curriculum vitae.

Automated technologies or interactions.

As a Website User, when you interact with our website, we will 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. Please see our Cookie Policy for further details.

Where we collect your information through publicly available sources as set out above, we may do this with the aid of software programmes. These programmes are given parameters on the requirements of a role and search through publicly available sources, where there is a reasonable expectation that such information may be collected and processed by recruiters, to find Candidates for particular job roles.

3. How New Minds uses your personal data

We will not process your personal data in a way that is incompatible with what is outlined in this Privacy Policy, and we will use our best efforts to ensure that data is accurate, complete, current and reliable for its intended use. We will not sell your personal information.

Website User Data

The standard internet log information and details of visitor behaviour patterns we collect from a Website User that visits our Website is used only for analysis purposes, allowing us to optimise the performance of our Website. This information is only processed in a way which does not identify anyone personally or the company. Please refer to our Cookie Policy for further details.

Candidate Data

If you are a Candidate your personal data is used in the usual course of our business to provide our services to NEW MINDS’ Clients or to assess your suitability as a worker or employee of NEW MINDS (if relevant). This may include assessing your suitability for executive and non-executive roles, presenting you as a prospective candidate to Clients, verifying the details of your profile, generally assisting in managing our relationship with you and our Clients and performing administration or operational functions.

Your personal information may also be shared with third parties whom we have engaged to provide relevant and associated services such as education checks and/or background checks, to the extent that the checks performed are appropriate and in accordance with local legislation.

If you are engaged by NEW MINDS as an associate your data will be used to manage a temporary or contract assignment.

If you are a Candidate your personal information may also be shared with Referees or other sources to the extent necessary to obtain additional information about you so we can provide a more accurate profile to our Clients.

Further details of the use of Candidate Personal Data will be made clear as part of the Candidate registration and management process. If you do not provide the personal data necessary, object to or withdraw your consent (where applicable) for the processing of your personal data, we may in individual cases not be able to match you with available job opportunities of interest to you.

Client Personal Data

Any personal data collected in respect of Client individuals will be used in the context of the provision of NEW MINDS services to the Client, including communicating about Candidates, managing the Client-Candidate relationship and otherwise carrying out our obligations arising from any contracts we intend to enter into or have entered into between the Client and us. We may also use the data for other business purposes, including data analytics, benchmarking and statistic purposes. We may use the personal data collected to contact Client individuals with respect to any of our services that we believe may be of interest to the Client, including

Intellectual Capital: We may contact you from time to time to share intellectual capital and thought leadership that we have published which we believe could be of interest to you or relevant to your role at your organisation. You may opt out of receiving these communications at any time.
Convening: From time-to-time we may contact you with an invitation to attend an industry or role-specific event, such as a webinar. You may opt out of receiving these invitations at any time using the contact details provided above.
Market Intelligence: We may retain and use personal information for research, benchmarking, and market norms in order to provide and develop our services and intellectual capital and remain aligned with market standards.

Referee or Source Data

We will use the collected data to obtain information regarding your experience with, and thoughts and opinions on, a particular or potential Candidate. If a Candidate provides us with your details as a Referee, we may share your contact information with our Clients to allow them to evaluate a Candidate for a specific position. Any reference, opinion or feedback you provide to NEW MINDS as a Referee or Source shall in no case be attributed to you if shared with a Client. We may also use your contact details to contact you in relation to any of our services that we believe may be of interest to you. Additionally, we may also use the data for other business purposes, including data analytics, benchmarking and statistic purposes.

Other Business Management and Compliance Purposes

In certain limited cases, we may disclose a minimum degree of personal information for internal business purposes. Such business purposes include, but are not limited to, audit procedures, security processes, maintenance of our systems and infrastructure, internal research of our business and services, performance of our services, tests of our services, and other short-term uses.

This may include limited disclosure to our third-party service providers who perform functions on our behalf (for example outsourced document storage providers, analytics, applicant tracking systems, CRM platforms and interview transcription services), all of whom will be required to process your personal information in accordance with applicable data protection laws and this Privacy Policy.

Your information may also be shared with any competent law enforcement, regulatory or governmental body, or a court of law if necessary to exercise our legal rights, protect your interests or as required by applicable law.

4. Legal basis for using your personal data

NEW MINDS legal basis for collecting and using the personal information described in this Policy, and in particular section 3 above will depend on the personal information and processing activity involved and the context in which it was obtained.

Website Users

The legal basis for the processing of cookies, server logs and other similar technologies, as outlined in our Cookie Policy, is our legitimate interest. Specifically, operation of a website and user interaction.

Candidates

With respect to a Candidate’s recruitment and interviews in particular:

We will process basic personal information about you, such as your contact details (name, address, e-mail, phone number) and information that would normally be included in a curriculum vitae (education history, employment history, professional experience, offer letters, compensation history where permitted by local law, etc.), and competencies, as well as any additional information that may assist us in presenting the best Candidates for the most appropriate roles (such as professional or relocation interests) on the basis of legitimate interest, or other legal grounds (such as consent) where required by applicable local legislation, provided the processing of such information is not overridden by your own privacy interests or your rights and freedoms as provided by the law
Once we have contacted you and both you and our Client (the prospective employer) are in agreement to proceed with your application for a role, we will ask you to provide us with your express consent to process and share with our Client (and background check providers if relevant and necessary to the search process) any information required for background checks and/or employment diversity requirements, including any potentially sensitive information that may come to light during interviews, as well as any insights that we may provide to our Clients based on the foregoing.
If we are unable to gain your consent at the relevant stage of the process, any information we gather for employment diversity requirements shall be done on the basis of reasons of substantial public interest, or applicable laws and/or the requirements imposed by local authorities. However, we shall obtain your consent prior to sharing such information with our Clients.
In order to facilitate the interview processes for recruitment services, we may request to record the interview session. In the event of a planned recorded interview sessions, we will obtain your consent prior to the recording.

Clients & Supplier

The legal basis for processing Client or Supplier Data is to fulfil a contract, or take steps linked to a contract or potential contract, with you or your organisation. This includes:

to register you as a client/supplier of NEW MINDS;
to provide and/or administer services and solutions, as instructed by you or your organisation (if a Client) or to receive goods or services from you (if you are a supplier);
to process payments, billing and collection; and
as required by NEW MINDS to conduct our business and pursue our legitimate interests.

Referee or Sources

The legal bases for processing your data are either our legitimate interest, or in some instances, your consent. Consent is sought before attributing any reference or feedback provided about a candidate to you when presenting it to a Client.

5. Data storage and security

To prevent unauthorised access, maintain accuracy of data and ensure the proper use of information, NEW MINDS has implemented appropriate legal, physical, technical and security procedures to protect the confidentiality of and safeguard the personal information collected, and prevent against accidental loss, unauthorised access, or unlawful processing. These measures will be reviewed over time and update to remain aligned with legal and technological developments.

All cloud services we use internally for NEW MINDS and our subsidiary platforms use industry-standard TLS (Transport Layer Security) and have up-to-date security measures and protocols.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

6. International and web-based transfer

The data that we collect from you will be transferred to, and stored at, a destination inside the UK and/or European Economic Area (“EEA”) by preference and wherever possible.

From time-to-time personal data may be transferred, viewed and processed outside of the UK and/or EEA. By submitting your personal data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy.

Using our website and Internet-based transfers: Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our Website or via e-mail; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

If you would like additional information regarding where the Personal Data is held, please e-mail NEW MINDS at privacy@new-minds.co.uk

7. How long do we keep your personal data for?

We only retain your information for as long as is necessary for us to use your information as described above or to comply with our legal obligations. However, please be advised that we may retain some of your information after you cease to use our services, for instance if this is necessary to meet our legal obligations, such as retaining the information for tax and accounting purposes.

When determining the relevant retention periods, we will take into account factors including:
a.   our contractual obligations and rights in relation to the information involved;
b.   legal obligation(s) under applicable law to retain data for a certain period of time;
c.   our legitimate interest;
d.   statute of limitations under applicable law(s);
e.   (potential) disputes;
f.   if you have made a request to have your information deleted; and
g.   guidelines issued by relevant data protection authorities.

Otherwise, we securely erase your information once this is no longer needed.

8. What rights do you have in relation to the data we hold on you?

By law, you have a number of rights when it comes to your personal data. Further information and advice about your rights can be obtained from us using the contact details at the end of this Policy or the data protection regulator in your country.

Please e-mail NEW MINDS at privacy@new-minds.co.uk if you have any queries

Rights	What does this mean?
1. The right to be informed	You have the right to be provided with clear, transparent and easily understandable information about how we use your information and your rights. This is why we’re providing you with the information in this Policy.
2. The right of access	You have the right to obtain access to your information (if we’re processing it), and certain other information (similar to that provided in this Privacy Policy). This is so you’re aware and can check that we’re using your information in accordance with data protection law.
3. The right to rectification	You are entitled to have your information corrected if it’s inaccurate or incomplete.
4. The right to erasure	This is also known as ‘the right to be forgotten’ and, in simple terms, enables you to request the deletion or removal of your information where there’s no compelling reason for us to keep using it. This is not a general right to erasure; there are exceptions.
5. The right to restrict processing	You have rights to ‘block’ or suppress further use of your information. When processing is restricted, we can still store your information, but may not use it further. We keep lists of people who have asked for further use of their information to be ‘blocked’ to make sure the restriction is respected in future.
6. The right to data portability	You have rights to obtain and reuse your personal data for your own purposes across different services. For example, if you decide to switch to a new provider, this enables you to move, copy or transfer your information easily between our IT systems and theirs safely and securely, without affecting its usability.
7. The right to object to processing	You have the right to object to certain types of processing, including processing for direct marketing or if you no longer want to be contacted with potential opportunities.
8. The right to lodge a complaint	You have the right to lodge a complaint about the way we handle or process your personal data with your national data protection regulator.
9. The right to withdraw consent	If you have given your consent to anything we do with your personal data, you have the right to withdraw your consent at any time (although if you do so, it does not mean that anything we have done with your personal data with your consent up to that point is unlawful). This includes your right to withdraw any consent to us using your personal data for marketing purposes.

You also have a right to complain to your Complain to your regulator – in the UK, the Information Commissioner’s Office.

We usually act on requests and provide information free of charge, but may charge a reasonable fee to cover our administrative costs of providing the information for:

baseless or excessive/repeated requests, or
further copies of the same information.

Alternatively, we may be entitled to refuse to act on the request.

Please consider your request responsibly before submitting it. We’ll respond as soon as we can. Generally, this will be within one month from when we receive your request but, if the request is going to take longer to deal with, we’ll come back to you and let you know.

New Minds Resourcing Limited, June 2021