The online service Odyssey Enterprises Limited trading as “Odyssey Recruitment” known as the “Company” respects your privacy and is committed to protecting your personal data. The Company is compliant with the Data Protection Act 2018 and UK GDPR (“Data Protection Laws”). This privacy notice will inform you of our methods of looking after your personal data and your privacy rights pursuant to this legislation.

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A Controller For Personal Data

• A “controller” is a person or organisation who alone or jointly determines the purposes for which and the way in which any personal data is or is likely to be processed. Unless we notify you otherwise the Company is the controller for your personal data.
• We are registered with the UK regulator the Information Commissioner’s Office (ICO).

How We Collect Your Personal Information

Candidates:

Directly From You

When you register with us as a candidate we process your personal data including, but not limited, to your name, contact details and information from your Curriculum Vitae (CV).

• Your CV may be submitted electronically via the website. This can be done by means of application for specific advertised vacancies or speculatively for consideration by us for positions as they arise.
• The CV is entered into a secure database which can be accessed only by authorised personnel working for the Company.
• The CV will be sent to prospective employers with your consent only.
• Where applicable we may also collect special categories of data i.e., sensitive data. This can include personal data relating to your health for example, disability information for reasonable work adjustment purposes, diversity information, including race, ethnic origin, sexual orientation and religion for equal opportunity monitoring purposes as well as details of any unspent criminal convictions where required by a client or by us if you apply for a role with us. We will only use your explicit consent to process special categories of data.
• If you use our website, click on links in emails we send to you, open or forward them or sign up to receive job alerts or other content from us, we also collect personal data from those interactions.

Indirectly from third parties

We can obtain personal data about you from third parties including:

• your former employers. This is to confirm dates of employment and for references.
  
• your educational institutions. This is to check your academic qualifications.
  
• any criminal convictions.
  
• credit reference agencies. This is where we need to check your financial standing.
  
• publicly available sources such as LinkedIn and social media sites so we can enhance the information we hold about you so we can find more suitable roles for you.
  
• word of mouth or referrals by a third party.

Clients:

• We collect personal data such as your name, job title and contact details and other details that you may pass to us.
• We can also process personal data about what communications we have had with you.
• We also process feedback that you provide about our candidates.
• We process financial transaction details.

Suppliers:

• In the course of our business activities we collect your name and contact details and financial transaction details.

From Use Of Our Website

• Odyssey Recruitment gathers information and statistics collectively about all visitors to the Company's website. Analysis of this information demonstrates the most frequently used sections of the website and assists us in continually improving the online service.

Cookies and similar technologies

• Odyssey Recruitment use cookies that identify your browser.
• Cookies collect and store information when you visit our website about how you use it where the use of cookies permits that it is possible to record your use of the website.
• The use of cookies can provide you with a better service and experience when browsing our website.
• Please see our cookies notice [insert cookies notice link] for more information about cookies and how we use them.

Providing Personal Data

• Where we need to collect personal data by law or under the terms of a contract we have with you and you do not provide that information when requested, we may not be able to perform the contract we have or are trying to enter into with you to provide you with services. In this case we may have to cancel our service but we will notify you if this is the case at the time.

How We Use Your Personal Data

Candidates:

We use your personal data to: 

• find and provide you with work when you engage in our services and match you to suitable roles. 
  
• provide you with information about news, our services and other matters of interest.
  
• personalise your experience by creating a candidate profile.
  
• provide you with interviewing and salary advice; and
  
• send you direct marketing for the purposes of informing you about job opportunities.
  
• enable you to use the job alert service. Your email address is used for the purpose of sending by email alerts of the latest jobs in the nominated sector, region or discipline. Job alert preferences can be changed or stopped by altering preferences in the candidate account section of the website.

Clients:

We use your personal data to:

• communicate and provide our services to you.
  
• fulfil contractual obligations to you.
  
• send you relevant marketing material of interest.
  
• maintain our business relationship with you.
  
• answer your enquiries when you contact us.
  
• establish, exercise or defend legal claims.

 Suppliers:

We use your personal data to:

• communicate with you.
  
• fulfil contractual obligations to you.
  
• maintain our business relationship with you.
  
• send you relevant marketing material of interest.
  
• establish, exercise or defend legal claims.

Marketing Communications

• Whether you are a Candidate, Client or Supplier you can unsubscribe from receiving marketing communications from us by using the unsubscribe methods contained in communications we send to you or by contacting us. See Contact us.

Lawful Basis For Processing Personal Data

Our lawful basis for processing your personal data does depend on the personal information used and the specific context when we collect it. We rely on the following lawful basis:

• Performing a contract: This is where it is necessary to perform our obligations under a contract with you or to take steps at your request to enter into a contract with us.
• Compliance with a legal obligation: This is where we need to process your personal information to comply with legal or regulatory obligations such as information required by government bodies.
• Our legitimate interests or those of a third party: This is based on our legitimate business interests provided this does not override any interests or rights that you have as an individual.

Our legitimate interests include:

• optimising the performance of our website and user experience.
  
• informing you about our services.
  
• ensuring that our operations are conducted in an efficient manner.
  
• managing our business and relationship.
  
• understanding and responding to feedback.
  
• understanding how you use our services and websites.
  
• improving our services and offerings.
  
• ensuring our systems and premises are secure.
  
• research and analysis of salaries and candidates.

Consent

• In some circumstances we will ask for your consent to process your personal consent. Where we process special categories of data i.e., sensitive data we will request your personal data based on your explicit consent.
• You have the right to withdraw your consent at any time. If you would like to withdraw your consent please contact us. See Contact us. Note: We will not forward your details or your CV without your consent where you are a potential candidate for a role.

How We Share Your Personal Data

We share your data as follows:

• Internally: Your personal data will be used by our employees, contractors and staff who are working on providing your services to you on a need-to-know basis.
  
• Suppliers: This would include service providers who support our business including IT and communication suppliers and outsourced business support.
  
• Professional advisers: This would include lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
  
• Law enforcement bodies, regulators and other authorities: This is to comply with our legal requirements or adhere to good practices.
  
• Advertising networks and analytics service providers: to support and display ads on our website, apps and other social media tools.
  
• Third parties: in the context of the acquisition or transfer of any part of our business or in connection with the business reorganisation.

International Transfers

How we safeguard personal data when we transfer it internationally

Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

1. We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data; or
   
2. We will use specific contracts approved for use in the UK which give personal data the same protection it has in the UK. For example the use of Article 46 UK GDPR safeguard mechanisms to transfer personal data.

Data Security

• We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
• The transmission of information via the internet is not completely secure. Although we will take reasonable measures to protect your personal data, we cannot guarantee the security of your information transmitted and any transmission is at your own risk.

Data Retention

• We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements.
• We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
• To determine the appropriate retention period for personal data we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means and the applicable legal, regulatory, tax, accounting or other requirements.

Anonymisation

• In some circumstances we will anonymise your personal data so that it can no longer be associated with you for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

Child Data

• This website is not intended for children and we do not knowingly collect data relating to children.

Data Subject Rights

Under certain circumstances, you have rights under Data Protection Laws. You can:

• Request access to your personal data: This is known as a "data subject access request" and enables you to receive a copy of the personal data we hold about you.
• Request correction of your personal data: This enables you to have any incomplete or inaccurate information we hold about you corrected.
• Request erasure of your personal data: This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. Note: We may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you at the time of your request.
• Object to processing of your personal data: This is where we are processing your personal data based on a legitimate interest or those of a third party and you may challenge this. However, we may be entitled to continue processing your information based on our legitimate interests or where this is relevant to legal claims. 

Direct Marketing

• You have the right to object to processing of your personal data for direct marketing purposes.

Request Restriction Of Processing Your Personal Data

This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the information's accuracy; (b) where our use of the information is unlawful but you do not want us to erase it; (c) where you need us to hold the information even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your information but we need to verify whether we have overriding legitimate grounds to use it.

Request Transfer Of Your Personal Data (Data Portability): 

• We will provide to you, or a third party you have chosen, your personal information in a structured, commonly used, machine-readable format.

Right to withdraw consent

• Where we are relying on consent to process your personal data this will not affect the lawfulness of any processing carried out before you withdraw your consent.
• If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

Automated Decision Making

• We use a CV parsing tool that enables us to filter through CVs appropriate for jobs that we advertise and to enter relevant key words such as years of experience and specific skillsets.
• The tool analyses the CVs uploaded to the website and will find suitable candidates by matching key words in candidates’ CVs.
• You have the right to object to the use of automated decision making and to request human intervention. Please contact us if you would like to exercise this right. 

Keeping Personal Data Accurate And Current

• It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
• Please cotact us if you wish to update your personal data. Our details can be found at the end of this notice.

Carrying Out Your Data Subject Rights

• You will not have to pay a fee to access your personal data or to exercise any of the other rights. However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive.
• We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data or to exercise any of your other rights. This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
• We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. We will notify you and keep you updated in this case.
• If you wish to exercise any of the rights set out above, please contact us at contact@odysseyrecruitment.com.

Concerns And Complaints

We would appreciate the chance to deal with your concerns in the first instance. Please see the Contact us section. If you have unresolved concerns and you live or work in the UK or believe that a personal data breach happened in the UK, you have the right to complain to the ICO who can be contacted at: 

Telephone: 0303 123 1113.                     

Website: https://ico.org.uk/concerns/ .

Post: Information Commissioner's Office

Wycliffe House

Water Lane

Wilmslow

Cheshire SK9 5AF.

If you live or work outside the UK or you have a complaint concerning our activities you may lodge a complaint with another supervisory authority. 

Changes To Our Privacy Notice

• This notice may be changed from time to time in response to legal, technical or business developments.
• We will take appropriate measures to inform you when we update our notice.
• We will obtain your consent to any material privacy notice changes if and where this is required by applicable Data Protection Laws.

Contact Us

If you would like more information about the way we manage personal information that we hold about you please contact us at:

Telephone: +44 203 409 5597

Email: contact@odysseyrecruitment.com

Post: Odyssey Enterprises Ltd 71-75 Shelton St, Covent Garden, London WC2H 9JQ, UK.

This version was last updated in February 2024