1. What does this notice cover?
This notice describes how Aaydin uk Ltd(“AAYDIN“, “we“, ” us” or “our“) uses and discloses your personal data as part of your application to and potential engagement as a consultant working with Aaydin uk Ltd. It also describes your data protection rights, including a right to object to some of the processing which we carry out. More information about your rights, and how to exercise them, is set out in the “Your choices and rights” section.
This notice applies to applicants and consultants that are appointed to provide services to Aaydin uk Ltd’s clients. It is not the notice relevant to employees or contractors hired as part of Aaydin uk Ltd’s own internal teams. Processing of these individual’s data is described in our Corporate Employee Privacy Notice. The data processing described in this notice may be limited as required by applicable law.
We also may provide you with additional information when we collect personal data, where we feel it would be helpful to provide relevant and timely information.
2. What categories of personal data we process:
We collect different information about you at different stages of your application and engagement.
Where you declare an interest in applying for a role or apply for a role, whether in response to a job advert you have seen or proactively, we collect the following information:
- Personal identification information: your name, home address, phone number; email address; date of birth, gender, immigration status, and information about your entitlement to work;
- Application-related information: curriculum vitae (CV), cover letter, employment history, education history, qualifications and skills, reference contact information, position preferences, willingness to relocate, desired salary, interests and aspirations, your interest in hearing about other roles, background screening information and answers to pre-screening questionnaires if relevant and bank account information if we will re-imbrues expenses; and
- Sensitive information: for example, information about your health and disabilities where we need to make any reasonable adjustments; equal opportunities monitoring information, including information about your ethnic origin, sexual orientation, health and religion or belief.
We collect most of this information from you directly. For example, data is collected through our website and CVs; from correspondence or in-person meetings with you; or through interviews, meetings or other assessments. We also collect some information about you from other people (e.g. recruiters, referrals), your referees or third-party job websites (e.g. from LinkedIn if you choose to connect to us with your LinkedIn profile). Where applicable, we also collect data from our third-party background screening provider during the pre-employment screening process, or confirm details directly with educational or professional licensing and certification organisations where confirming your qualifications. This may include checks of your driving license with the DVLA where necessary for a role for which you have applied.
We may also generate our own information, based on our assessment of your application, and may make use of analytics product in our review of applications. These might include relevance scores or ranking systems based on the roles we are assessing. We do not make any decisions solely based on automated scoring or ranking.
If you are successfully engaged as a consultant for Aaydin uk Ltd, we will collect the following additional information:
- Role and engagement related information: information concerning your appointed role, the length of your engagement, performance, time and attendance, compensation and employment contract information, conduct, and information about violation of laws or breach of company or our client’s policies;
- IT information : information relating to your use of our or our clients’ IT systems including your website activity and IP address in accordance with our (or our clients’, as applicable) internal policies; and
If you are engaged directly by Aaydin uk Ltd, rather than through a third-party organisation, we will also collect the following additional information:
- Personal identification information: additional information relating to your identification documents and government issued identifiers;
- Application-related information: information relating to right to work checks;
- Employment relationship information: information about you or about other family members that enables us to provide benefits, your bank details and information about compensation and expenses to allow us to pay you, your contract, and other legal information;
- Conduct information: information concerning any grievances and disciplinary issues outside of your engagement with an Aaydin uk Ltd client;
- Communication information ; records of communication (where permissible) and communication metadata; and
- Sensitive information: medical leave information and information necessary to make reasonable adjustments for health conditions and disabilities, equal opportunities monitoring information including information about your ethnic origin, sexual orientation, health and religion or belief.
We again collect most of this information from you directly. For example, data is obtained from your passport or other identity documents; from forms completed by you at the start of or during your engagement; from correspondence with you; or through interviews, meetings or other assessments.
We also collect some information about you from other people or organisations. In addition to the sources previously mentioned, we obtain information about you any third-party organisation that engages you, and from the Aaydin uk Ltd client where you are placed. We also obtain information about performance and conduct information from our clients when we carry out performance reviews and in the course of organising our business. We also receive personal data from public bodies to manage tax and payroll deductions; and medical information from healthcare providers if you are absent on medical grounds.
- respect for the dignity of the individual;
- recognition of the importance of each individual’s human rights;
- securing and increasing equality of opportunity and inclusion;
- not accepting any form of discrimination, harassment or bullying; and
- not tolerating any form of slavery, human trafficking of forced or compulsory labour.
These Values inform all of our policies and processes related to the rights and freedoms of every person who works for us or with us through our supply chain. We have also developed and implemented policies and processes which are intended to extend these commitments to the Values through our supply chain.
3. How do we use this information and what is the legal basis for its use?
Aaydin uk Ltd collects uses and stores your personal data for the following purposes, which in each case are justified by the legal basis set out in bold:
- Where necessary to enable Aaydin uk Ltd’s business to function and pursue our legitimate interests, where these interests are not overridden by your data protection rights, in particular:
- to process your application, including storing and updating your personal information to make informed decisions on recruitment and assess your suitability for the role, communicating with you about your application, responding to your inquiries and scheduling interviews, and to reimbursing you for any agreed expenses incurred in the application process;
- verifying information and carrying out appropriate background checks;
- obtaining information about your performance, presence and conduct on an Aaydin uk Ltd engagement , including obtaining time recording information, feedback from Aaydin uk Ltd clients and details on your work product;
- To provide access to our offices and IT systems and software, and manage these premises, systems and software;
- To provide communication services such as e-mail, telephone and internet access.
- To protect the security of our premises, assets, systems, and intellectual property and enforce company policies, and those of our clients , including those relating to equal opportunities and monitoring communications (where permitted by local law and in accordance with internal and clients’ policies), and to conduct necessary investigations and take appropriate disciplinary action.
- For resource planning and consultant management, including disciplinary and grievance purposes, in the context of discussions or decisions relating to reorganisation or restructuring, and for reviews, appraisals and assessments for talent management.
- For general business operations , which may include use in connection with planning, budgeting, calibration, headcount, database administration, diversity metrics, surveys, evaluations, reports, legal claims, compliance, regulatory, audit, investigative and disciplinary purposes (including disclosure of such information in connection with legal process or litigation) and other ethics and compliance reporting tools.
- For health and safety planning and management. We may collect information regarding your health, location and/or activities in accordance with any relevant health and safety obligations.
- For analysing and monitoring the equality, diversity and inclusivity of our workforce (as permitted by local law). We may do so in order to better understand our workforce, to prevent discrimination in the workplace and/or to respond to allegations or claims.
- Where necessary for Aaydin uk Ltd to establish and perform its contract with you, to maintain or terminate its contractual relationship with you and to enable you to perform your job .
- Where you are engaged as a consultant by Aaydin uk Ltd itself, it will process certain information where necessary to fulfil and maintain this contractual relationship. This includes processing for the purpose of the administration of personnel records, administration of your engagement and the administration of payroll and benefits, absence, sickness, compensation, performance and talent management, succession, training and leadership development, disciplinary and grievance procedures, awards / recognition, employee surveys, medical insurance, occupational health, fitness for work, references, retirement plans, stock plans, expense management and professional travel.
- Where necessary to comply with applicable laws These legal obligations, and the processing operations they require us to undertake, include the following:
- Tax laws and similar obligations. These require us to undertake tax and national insurance reporting, filing and withholding;
- Health and safety obligations. These require us to process occupational health records, location and/or activities;
- Employment and social security law obligations. These include obligations for us to carry out right to work checks on the consultants we directly engage and process family leave and sick leave and pay information, and to provide reasonable adjustments for the benefit of disabled staff engaged by Aaydin uk Ltd. Sometimes it is also necessary for us to comply with the orders or instructions of the UK court and tribunals, the UK government and government bodies, regulatory bodies and other legal or regulatory processes or law enforcement bodies.
- Where you have given your consent: in circumstances where we seek your consent. This includes the sending of details of further roles with Aaydin uk Ltd clients we think might interest you. We will explain the purpose of our processing in any request for consent. Such processing shall be truly voluntary, and you shall be able to withdraw this consent at any time.
Values and practical application and implications of those Values. Aaydin’s Legal Team and Human Resources Team
Monitor Aaydin’s compliance with best practices and adherence to the Values on an ongoing basis, and adjust those policies and processes accordingly.
4. How we share your personal data
Aaydin uk Ltd Clients
We share certain information about our applicants and consultants with our Aaydin uk Ltd Clients. This includes your application related data, such as your CV and relevant experience.
Other Aaydin uk Ltd Entities
We share some of your personal data with relevant managers at other Aaydin uk Ltd entities, located in the United Kingdom and/or Other country. This is to take decisions at a strategic level, to manage client relationships and to make central systems available to our consultants and employees. You may also be provided group services such as legal or IT support provided from the United Kingdom. Group entities are required to take appropriate security measures to protect your personal data in line with our policies.
Government or law enforcement bodies
Personal data may be shared with government authorities and/or law enforcement officials as required for the purposes described above.
Third party service providers
Personal data will also be shared with Aaydin uk Ltd’s third party service providers (who will process it on our behalf). These third parties include recruitment agencies, recruitment software providers, HR & payroll providers, tax equalization/advice partners, global relocation service partners, whistle blowing hotline provider, IT service providers, facilities and security providers. Third parties that process personal data on our behalf are required by contract to implement safeguards that are no less protective than those implemented by us in order to protect any personal data they receive from us. Third party service providers are further prohibited from using the personal data for any purpose other than to perform the services as instructed by Aaydin uk Ltd. Third party benefits providers
Personal data will also be shared with third party benefit providers as required.
Sale of our business
In the event that Aaydin uk Ltd’s business is sold or integrated with another business, your details may be disclosed to our advisers and any prospective purchaser’s advisers and will be passed to the new owners of the business as required for the purposes set out above.
5. Where we transfer your personal data
As a UK company, a number of our IT systems are hosted in the United Kingdom and most of our executive team is located there. Relevant information is shared with our affiliated Aaydin uk Ltd companies as described in this notice. It will primarily be processed by employees in the executive, Human Resources, IT and Finance, and Facilities departments and, where they are located outside of your country, by your line manager.
We may transfer your data to some third parties which host or access personal data outside of the UK and EEA. In the event such an organisation is in a country which is not subject to an adequacy decision by the UK government or otherwise considered adequate as determined by applicable data protection laws, we take steps to ensure your personal data is adequately protected, including by adopting standard contractual clauses, unless we can rely on a relevant exemption.
A copy of the relevant mechanism can be obtained for your review on request by using the contact details below.
6. Your choices and rights
You have the right to ask Aaydin uk Ltd for a copy of your personal data; to correct, delete or restrict processing of your personal data; and to obtain the personal data you provide in a structured, machine-readable format. In addition, you can object to the processing of your personal data in some circumstances (in particular, where we don’t have to process the data to meet a contractual or other legal requirement). Where we have asked for your consent, you may withdraw consent at any time. If you ask to withdraw your consent to Aaydin uk Ltd processing your data, this will not affect any processing which has already taken place at that time.
These rights may be limited, for example if fulfilling your request would reveal personal data about another person, or if you ask us to delete information which we are required by law or have compelling legitimate interests to keep. If you have unresolved concerns, you have the right to complain to a data protection authority. In the UK, this will be the Information Commissioner’s Office.
Where we collect personal data to administer our contract with you or to comply with our legal obligations, this is mandatory and we will not be able to manage the employment relationship without this information. In all other cases, provision of the requested personal data is optional, but this may affect your ability to participate in certain programs or systems, where the information is needed for those purposes. For example, you may not be able to participate in additional offered benefits or programs, or a team activity, if you choose not to provide the relevant information.
7. How long we retain your personal data
Aaydin uk Ltd will retain and process personal data relating to you during and following the recruitment stage for the purposes of performing administrative tasks related to your engagement, and for archival, record-keeping and legal purposes,
Applicant personal data will generally be kept for 6 months following their application, unless you have opted in to receiving further information about other roles, in which case your information will be retained until you tell us you no longer want to receive this further information.
Details about consultants who have carried out a placement with an Aaydin uk Ltd Client, or been directly engaged by Aaydin uk Ltd, will be held for 5 years after termination of employment, unless there are relevant legal proceedings for which the data is reasonably required or specific legal requirements to retain this for longer, such as accounting or health and safety rules. After this period, we will take steps to delete your personal data or hold it in a form that no longer identifies you.
Our retention policies have more information about this and are available on request.
8. Updates to this privacy notice
We reserve the right to update this privacy notice at any time, and we will provide you with a new updated privacy notice when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal data.
9. Contact us
The data controller for your personal data will be Aaydin uk Ltd.
If you have questions about this privacy notice or wish to contact us for any reason in relation to our personal data processing, please contact us at info@aaydin.uk