GDPR & Privacy Policy
As a recruitment company, Steadman Hub Trades under Steadman Brown Limited specialises in providing specific work-finding services to its clients and HubSpot-related job seekers. In order to provide these services, Steadman Brown must process personal data, excluding sensitive data. By doing so, Steadman Brown acts as a data controller.
Steadman Brown may collect personal information directly from you, such as on an application form or online registration form, or from another source such as a job board or LinkedIn. To process your personal data, Steadman Brown must have a legal basis for doing so. In order to provide 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:
In order to provide you with work-finding services, Steadman Brown will collect your personal information (excluding sensitive information). Our legal basis as per The Data Protection Act 2018 regulation, for providing these services is as follows:
Used fairly, lawfully, and transparently with specified, explicit purposes
When Steadman Brown has relied on a legitimate interest to process your personal data, our legitimate interests are as follows:
- We have advertised an opportunity on either our website or on various job boards that you have applied directly for. As part of this process, you will be required to provide your name and contact information.
- Our company is solely focused on Hubspot recruitment, and you are Hubspot-experienced, so we would have reached out to you, using a third-party platform such as LinkedIn or another job board to find your name and contact details.
Consent
Upon successful onboarding with our recruiting company, a 'right to represent' form will be completed outlining your data rights and the intended use of your data.
Your rights
Please be aware that you have the following data protection 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 legitimate interest;
- The right not to be subjected to automated decision-making and profiling;
- the right to withdraw consent at any time.
Data retention
The Company will retain your personal data only for as long as is necessary. The Conduct of Employment Agencies and Employment Businesses Regulations 2003 require us to retain work-seeker records for at least one year following (a) the date on which they were first created or (b) the date on which we last provided you with work-finding services. In the event that further consent is not obtained, your data will be permanently removed from our databases.
It is confirmed by Steadman Brown that any information requested will be used for recruitment purposes only, including contact information, location, professional profile, educational background, and work experience. Steadman Brown ensures that all data is obtained in a lawful manner. The collection of information from social profiles is legal under GDPR if the profiles are publicly accessible and if it is reasonable to assume that candidates expect to be contacted. This data is accurate and, where necessary, kept up to date.
All data processed by Steadman Brown is handled in a way that ensures appropriate security, including protection against unlawful or unauthorized processing, access, loss, destruction or damage.
Sensitive Data
Sensitive information, such as racial and ethnic background, political opinions, religious beliefs, genetics, biometrics, health, sex orientation and membership in unions, is more strongly protected under the law. This type of information is not collected by Steadman Brown, nor will it be requested by anyone using our services. Thus, we do not store this information and do not plan to do so in the near future.
Complaints or queries
If you wish to complain about this privacy notice or any of the procedures set out in it please contact our Data Protection Officer, Lewis Steadman
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.
Annex A - GDPR ACT 2018
a) The lawfulness of processing conditions for personal data are:
- Consent of the individual for one or more specific purposes.
- Processing is necessary for the performance of a contract with the individual or in order to take steps at the request of the individual to enter into a contract.
- Processing is necessary for compliance with a legal obligation that the controller is subject to.
- Processing is necessary to protect the vital interests of the individual or another person.
- Processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the data controller.
- Processing is necessary for the purposes of legitimate interests pursued by the controller or a third party, except where such interests are overridden by the interests or fundamental rights or freedoms of the individual which require protection of personal data , in particular where the individual is a child.
b) The lawfulness of processing conditions for sensitive personal data are:
- Explicit consent of the individual for one or more specified purposes, unless reliance on consent is prohibited by EU or Member State law.
- Processing is necessary for carrying out data controller’s obligations under employment, social security or social protection law, or a collective agreement, providing for appropriate safeguards for the fundamental rights and interests of the individual.
- Processing is necessary to protect the vital interests of the individual or another individual where the individual is physically or legally incapable of giving consent .
- In the course of its legitimate activities , processing is carried out with appropriate safeguards by a foundation, association or any other not-for-profit body, with a political, philosophical, religious or trade union aim and on condition that the processing relates only to members or former members (or those who have regular contact with it in connection with those purposes) and provided there is no disclosure to a third party without the consent of the individual.
- Processing relates to personal data which are manifestly made public by the individual.
- Processing is necessary for the establishment, exercise or defence of legal claims or whenever courts are acting in their judicial capacity.
- Processing is necessary for reasons of substantial public interest on the basis of EU or Member State law which shall be proportionate to the aim pursued, respects the essence of the right to data protection and provide for suitable and specific measures to safeguard the fundamental rights and interests of the individual.
- Processing is necessary for the purposes of preventative or occupational medicine, for assessing the working capacity of the employee, medical diagnosis, the provision of health or social care or treatment or the management of health or social care systems and services on the basis of EU or Member State law or a contract with a health professional and subject to the necessary conditions and safeguards.
- Processing is necessary for reasons of public interest in the area of public health, such as protecting against serious cross-border threats to health or ensuring high standards of quality and safety of healthcare and of medicinal products or medical devices, on the basis of EU or Member State law which provides for suitable and specific measures to safeguard the rights and freedoms of the individual, in particular professional secrecy.
- Processing is necessary for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes, which shall be proportionate to the aim pursued, respect the essence of the right to data protection and provide for suitable and specific measures to safeguard fundamental rights and interests of the individual.