Privacy Notice

Hawksman Group Ltd (“Hawksman Technology”) is committed to protecting and respecting your privacy. Your personal data and privacy matter. Personal data means any information about an individual from which that person can be identified.

Definition of “Our Group”

Any mention of “Our Group” means Hawksman Group’s subsidiaries or our associated companies as defined in section 1159 of the UK Companies Act 2006 (our Group).

Scope of this Privacy Policy

This notice, together with our terms of use [www.hawkmantechnology.com], sets out the basis on which any personal data Hawksman Technology collects from you or that you provide to us will be processed by us.

This privacy policy applies to:

1. Website Users – any individual visitors to, and users of, Hawksman Technology’s websites whose personal data is collected by Hawksman Technology in the course of the Website User’s use and navigation around our website.

2. Candidates – applicants for any type of job or engagement via Hawksman Technology whose personal data is collected in the course of our services.

3. Referees – referees of Candidates whose personal data is collected in the course of our verification of a Candidate.

4. Corporate Staff – individuals who work for, or are engaged by, Hawksman Technology’s customers, clients, or suppliers whose personal data is collected in the course of our work with them.

General Data Protection Regulation (GDPR)

The General Data Protection Regulation (GDPR) (Regulation (EU) 2016/679) is a new regulation that replaces the Data Protection Regulation (Directive 95/46/EC). The Regulation aims to harmonize data protection legislation across EU member states, enhancing privacy rights for individuals and providing a strict framework within which commercial organizations can legally operate.

The UK Government intends for the GDPR to continue in UK law post-Brexit and has therefore enforced the Data Protection Act 2018.

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

Data Controller

For the purposes of data protection legislation in force from time to time, the data controller is Hawksman Technology of International House, 36-38 Cornhill, London, EC3V 3NG, United Kingdom.

Hawksman Technology’s nominated data representative can be reached at connect@hawksmantechnology.com.

Who Hawksman Technology Are and What We Do

Hawksman Technology is a recruitment agency and recruitment business as defined in the Employment Agencies and Employment Businesses Regulations 2003 (our business). Hawksman Technology collects the personal data of the following types of people to allow Hawksman Technology 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.

Hawksman Technology collects information about you to carry out our core business and ancillary activities.

Information You Give to Hawksman Technology or We Collect About You

This is information about you that you give Hawksman Technology by filling in forms on our site (www.hawksmantechnology.com) or by corresponding with Hawksman Technology by telephone, e-mail, or otherwise. It includes information you provide when you register to use Hawksman Technology’s website, enter our database, subscribe to our services, participate in discussion boards, or other social media functions and when you report a problem with our site.

The information you give to Hawksman Technology or Hawksman Technology collects about you may include your name, address, private and corporate e-mail address, telephone number, financial information, compliance documentation, and references verifying your qualifications and experience, and your right to work, curriculum vitae, and photograph, links to your professional profiles available where you have shared your data in the public domain (e.g., LinkedIn, Twitter, business Facebook, or corporate website).

Information Hawksman Technology Obtains from Other Sources

This is information Hawksman Technology obtains about you from other sources such as LinkedIn, corporate websites, job board websites, online CV libraries, your business card, and personal recommendations. In this case, Hawksman Technology will inform you, by sending you this privacy notice, within a maximum of 30 days of collecting the data of the fact we hold personal data about you, the source the personal data originates from, whether it came from publicly accessible sources, and for what purpose we intend to retain and process your personal data.

Hawksman Technology is working closely with third parties, including companies within our Group, business partners, clients of Hawksman Technology, subcontractors, and professional advisors. Hawksman Technology 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

Hawksman Technology uses information held about you in the following ways:

• To carry out our obligations arising from any contracts we intend to enter into or have entered into between you and Hawksman Technology and to provide you with the information 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 organization.

• 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.

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.

Hawksman Technology will rely on contractual obligations if we are negotiating or have entered into a placement agreement with you or your organization or any other contract to provide services to you or receive services from you or your organization.

Hawksman Technology will rely on legal obligation in some cases, where we are required by law or regulation to process your data.

Hawksman Technology will, in some circumstances, rely on consent for particular uses of your data. Where Hawksman Technology relies on consent, you will be asked for your express consent. An example of when we will rely on consent as the legal basis for processing your data is when we process your data for marketing purposes.

Hawksman Technology’s Legitimate Interests

Hawksman Technology’s legitimate interests in collecting and retaining your personal data are 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 client 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 candidates and client contacts.

Consent

Should Hawksman Technology want or need to rely on 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.

Other Uses Hawksman Technology Will Make of Your Data

Hawksman Technology does not undertake automated decision-making or profiling. We use our computer systems to search and identify personal data in accordance with parameters set by a person. A person will always be involved in the decision-making process.

Do You Have to Provide Hawksman Technology with Personal Data?

You may refuse to give Hawksman Technology 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.

Cookies

Our website uses cookies to distinguish you from other users of our website. This helps us provide you with a good experience when you browse our website and also allows us to improve our site. You can set your browser not to accept cookies, but this may cause problems with some features of the website.

Disclosure of Your Information Inside and Outside of the EEA

Hawksman Technology will share your personal information with:

• Any member of our group both in 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 subcontractors for the performance and compliance obligations of any contract we enter into with them or you; subcontractors, including payment and other financial service providers; analytics and search engine providers that assist us in the improvement and optimization of our site; credit reference agencies, our insurance broker, compliance partners, and other subcontractors for the purpose of assessing your suitability for a role where this is a condition of us entering into a contract with you.

Hawksman Technology 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 Hawksman Technology or substantially all of its assets are acquired by a third party, in which case personal data held by Hawksman Technology about its clients will be one of the transferred assets.
• If we are under a duty to disclose or share your personal data to comply with any legal obligation or to enforce or apply our terms of use and other agreements; or to protect the rights, property, or safety of Hawksman Technology, our clients, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

The lawful basis for third-party processing will include:

• Their own legitimate interests in processing your personal data, in most cases to fulfill 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 fulfill their legal obligations.

Where Hawksman Technology Store and Process Your Personal Data

The data that Hawksman Technology collect from you may be transferred to, and stored at, a destination outside the European Economic Area (EEA). It may be transferred to third parties outside of the EEA for the purpose of our recruitment services. It may also be processed by staff operating outside 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. Hawksman Technology 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 given 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. Although Hawksman Technology will do our best to protect your personal data, we cannot guarantee 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 try to prevent unauthorized access.

Retention of Your Data

Hawksman Technology understands 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. Different laws require Hawksman Technology 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.

Hawksman Technology must also keep your records of payments to you or an intermediary for as long as is legally required by national minimum wage, social security, and tax legislation.

Where Hawksman Technology has obtained your consent to process your personal/sensitive personal data, we will do so in line with our retention policy. Where consent is not granted, Hawksman Technology will cease to process your personal data and sensitive personal data.

• Your CV and associated data (when we have not found work for you) – 5 years from the date of our last contact.
• Your CV and associated data (when we have found temporary work for you) – 6 years from the last date of payment.
• Your CV and associated data (when we have found permanent work for you) – 5 years from the date of our last contact.

Hawksman Technology does the following 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 and we keep in touch with you so you can let us know of changes to your personal data.

We segregate our data so that we keep different types of data for different time periods. The criteria we use to determine whether we should retain your personal data include:

• The nature of the personal data.
• Its perceived accuracy.
• Our legal obligations.
• Whether an interview or placement has been arranged.
• Our recruitment expertise and knowledge of the industry by country, sector, and job role.

We may store and handle your data in the following ways:

• 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 pseudonymize 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 onto our database unless requested to do so. Pseudonymized Data is created by taking identifying fields within a database and replacing them with artificial identifiers or pseudonyms.

Marketing

Any information that you choose to give to Hawksman Technology will not be used for marketing purposes by us. Hawksman Technology will hold your personal information only for the purposes of providing you with our business services.

Your Rights

Our site may, from time to time, contain links to and from the websites of our partner networks 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.

The GDPR provides you with the right to:

• 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 to continue processing 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 a supervisory body, which in the United Kingdom is the Information Commissioner’s Office. The ICO can be contacted through this link: https://ico.org.uk/concerns/.

Access to Information

The Data Protection Act 2018 and the GDPR give you the right to access information held about you. Hawksman Technology also encourages you to contact us to ensure your data is accurate and complete. Your right of access can be exercised in accordance with the Act and the GDPR.

A subject access request should be submitted to connect@hawksmantechnology.com. No fee will apply unless the requests from a data subject are manifestly unfounded or excessive, particularly because of their repetitive character. In such circumstances, Hawksman Technology may charge a fee or refuse to act on the request.

Changes to Hawksman Technology’s Privacy Notice

Any changes we make to our privacy notice in the future will be posted on this page. Please check back frequently to see any updates or changes to our privacy notice. This Privacy Policy was last updated on November 2023.

Legal Disclaimer

Hawksman Group Limited (“Hawksman Technology”) has taken, and will continue to take care in the development, preparation, and maintenance of the content for the Hawksman Technology website. Hawksman Technology will use its reasonable endeavors to ensure only accurate information is posted on its website.

However, Hawksman Technology shall not be under any duty nor does it guarantee or warrant the accuracy or reliability of any information, content, or materials on this site and/or that such content is up to date. Hawksman Technology shall not be liable for any losses as a result of reliance on information provided. The content of this website may be changed at any time without notice.

Hawksman Technology expressly excludes any and all liability for errors or omissions with respect to the content and the website, save to the extent that such liability arises from Hawksman Technology’s fraud or fraudulent misrepresentation or from any death or personal injury that arises due to our negligence.

Hawksman Technology accepts no responsibility for any loss or damage whatsoever resulting from reliance on any statements contained on this website. The information provided on this website is provided without any warranty of any kind, either express or implied.

While Hawksman Technology uses reasonable efforts to obtain information from sources which it believes to be reliable, it makes no representation that the information or opinions contained on the website, or associated links to the website, are accurate, reliable, or complete.

Hawksman Technology does not warrant that the functions contained in the site will be uninterrupted or error-free, that defects will be corrected, that the site or any server that makes it available is free from viruses or other harmful components, or that successful or accurate results or outcomes will result from your use of this site. Access to the website is permitted on a temporary basis, and Hawksman Technology reserves the right to withdraw or amend the content provided on the website without Notice. Hawksman Technology is not under any duty to make the website available and will not be liable if for any reason the website is unavailable, totally or partially, at any time or for any period.

Hawksman Technology does not guarantee that any client will offer any candidate an interview or respond to the candidate’s submission of their information. The website does not constitute or purport to constitute a source of advice or a means to establish a business relationship of any kind between you and Hawksman Technology.

Terms and Conditions for Use of this Website

By accessing the website, you acknowledge and expressly accept that your use of the website is made under your sole and exclusive responsibility and agree that you will not perform any acts that may damage Hawksman Technology’s image, interests, or rights or those of any of Hawksman Technology’s affiliates, or that may damage, render useless, or overload the website, or that may impede, in any way, the normal use of the website by other visitors.

You agree to use this website for lawful purposes only and in a manner that is consistent with any and all applicable law and regulation in the country in which you access this site. You agree not to import or transfer to this site either directly or indirectly any information or other content which is or may be inaccurate, misleading, defamatory, obscene, or offensive or in breach of any intellectual property right or similar right or damaging to the software or performance of this site.

Unless otherwise stated, all rights, including copyright and database rights, in this site and its contents are owned by (or licensed to) Hawksman Technology or otherwise used by Hawksman Technology as permitted by applicable law.

Except where your use is permitted above or by copyright law, you may not otherwise copy, store in any medium (including any other website), distribute, transmit, re-transmit, broadcast, modify, or show in public any part of this site without our prior written permission.

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