The Company is a recruitment business which provides work-finding services to its clients and work-seekers. The Company must process personal data (including sensitive personal data) so that it can provide these services – in doing so, the Company acts as a data controller.

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You may give your personal details to the Company directly, such as on an application or registration form or via our website, or we may collect them from another source such as a jobs board. The Company must have a legal basis for processing your personal data. For the purposes of providing 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.

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1. Collection and Use of Personal Data - Candidates

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a.Purpose of processing and legal basis

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The Company will collect your personal data (which may include sensitive personal data) and will process your personal data for the purposes of providing you with work-finding services. The legal bases we rely upon to offer these services to you are:

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• Legitimate interest

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b.Legitimate interest

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Where the Company has relied on a legitimate interest to process your personal data our legitimate interests is/are as follows:

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• Navartis Holdings Ltd (and all its subsidiaries) are specialist technical recruiters who specialise in securing job opportunities for white collar professionals working within the Power, Rail, Civil Engineering, Construction and Telecoms sectors. We proactively and jointly work with candidates to secure new contract and/or permanent career opportunities whilst working with relevant clients in these sectors to source and secure the industry’s leading candidates. By processing your data this allows us to contact you about relevant opportunities to carry out our work finding services.

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c.Personal Data we have collected:

• Name

• Email Address

• Telephone Number

• Job Title / history through a CV/Resume

• Qualifications

• Compensation history

• Location of Employment

• Any other information on your CV

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d.How we use your personal data:

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Recruitment Activities

Our main area of work is White Collar Technical Recruitment – connecting the right Candidates with the right jobs. We’ve listed below various ways in which we may use and process your personal data for this purpose, where appropriate and in accordance with any local laws and requirements. Please note that this list is not an exhaustive list.

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Collecting your data from you and other sources, such as LinkedIn, job boards and referrals;

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• Storing your details (and updating them when necessary) on our database, so that we can contact you in relation to recruitment;

• Providing you with our recruitment services and to facilitate the recruitment process;

• Assessing data about you against vacancies which we think may be suitable for you;

• Sending your information to Clients, in order to apply for jobs or to assess your eligibility for jobs;

• Enabling you to submit your CV, apply online for jobs or to subscribe to alerts about jobs we think may be of interest;

• Allow you to participate in any interactive features of our services, when you choose to do so;

• Carrying out our obligations arising from any contracts entered into between us;

• Carrying out our obligations arising from any contracts entered into between Navartis and third parties in relation to your recruitment;

• Verifying details you have provided, using third party resources or to request information (such as references, qualifications and potentially any criminal convictions, to the extent that this is appropriate and in accordance with local laws);

• Complying with our legal obligation in connection with detection of crime or the collection of taxes or duties; and

• Processing your data to enable us to send you targeted, relevant marketing materials or other communications which we are likely to be of interest to you.

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e.Recipient/s of data

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The Company will process your personal data with the following recipients:

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The specific client that you have applied for a job with (Via either our website or any other job board / social media platform

Clients / Client profiles that we have pre-agreed with you that we will proactively approach to create find and secure you relevant work.

In all cases we will endeavour to pre-agree specific clients however with your consent we will proactively discuss your CV and availability with clients who match your requirements

We will never send your CV / details to a client you have specifically requested not to do so

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f.Statutory/contractual requirement

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Your personal data is required by law and/or a contractual requirement (e.g. our client may require this personal data), and/or a requirement necessary to enter into a contract. You are obliged to provide the personal data and if you do not the consequences of failure to provide the data are:

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• We wouldn’t be able to secure you a permanent or contractual work opportunity

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2. Collection and Use of Personal Data – Clients

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a.Purpose of processing and legal basis

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The Company will collect your personal data (which may include sensitive personal data) and will process your personal data for the purposes of providing you with specific and relevant recruitment services. The legal bases we rely upon to offer these services to you are:

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• Legitimate interest

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Where the Company has relied on a legitimate interest as a legal basis to process client data our legitimate interests are as follows:

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We use Client information for:

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• Recruitment activities;

• Marketing Activities; and

• To help us to establish, exercise or defend legal claims.

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Recruitment Activities

Our main area of work is Technical recruitment, through:

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(i) providing you with relevant Candidates;

(ii) Managed services.

(iii) Keeping you up to date with relevant changes in legislation where possible

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We have listed below the various ways in which we use your data in order to facilitate this. ​

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• Storing your details (and updating them when necessary) on our database, so that we can contact you in relation to recruitment activities;

• Keeping records of our conversations and meetings, so that we can provide targeted services to you;

• Undertaking customer satisfaction surveys; and

• Processing your data for the purpose of targeting appropriate marketing campaigns and transactional emails.

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We may use your personal data for these purposes if we deem this to be necessary for our legitimate interests.

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If you would like to know more about what this means contact us at GDPR@navartis.co.uk

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b. Marketing Activities

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Subject to any applicable local laws and requirements, we will not, as a matter of course, seek your consent when sending marketing materials to a corporate postal or email address.

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If you are not happy about this, you have the right to opt out of receiving marketing materials from us.

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3. Data Retention

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The Company will retain your personal data only for as long as is necessary. Different laws require us to keep different data for different periods of time.

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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.

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We must also keep your payroll records, holiday pay, sick pay and pensions auto-enrolment records for as long as is legally required by HMRC and associated national minimum wage, social security and tax legislation.

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​Where the Company has obtained your consent to process your Name, Telephone Number, Email Address and work history from your CV we will do so in line with our retention policy. Upon expiry of that period the Company will seek further consent from you. Where consent is not granted the Company will cease to process your Name, Telephone Number, Email Address, qualifications and work history from holding your CV

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4. Your Rights

Please be aware that you have the following data protection rights:

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• 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; and

• The right to withdraw consent at any time.

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Where you have consented to the Company processing Name, Telephone Number, Email Address, qualifications and work history from your CV you have the right to withdraw that consent at any time by contacting: GDPR@navartis.co.uk

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5. Source of the Personal Data

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The Company sourced your personal data by the following means:

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• A job board where your CV is live in the public domain

• LinkedIn

• A referral

• You were a direct applicant to a job we posted on our website

• You were a direct applicant to a job we posted on a job board

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6. Complaints or queries

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If you wish to complain about this privacy notice or any of the procedures set out in it please contact: GDPR@navartis.co.uk

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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.

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Justyn Faulkner - Managing Director

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Annex A

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a) The lawfulness of processing conditions for personal data are:

1. Consent of the individual for one or more specific purposes.

2. 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.

3. Processing is necessary for compliance with a legal obligation that the controller is subject to.

4. Processing is necessary to protect the vital interests of the individual or another person.

5. 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.

6. 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.

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b) The lawfulness of processing conditions for sensitive personal data are:

1. Explicit consent of the individual for one or more specified purposes, unless reliance on consent is prohibited by EU or Member State law.

2. 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.

3. 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.

4. 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.

5. Processing relates to personal data which are manifestly made public by the individual.

6. Processing is necessary for the establishment, exercise or defence of legal claims or whenever courts are acting in their judicial capacity.

7. 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.

8. 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.

9. 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.

10. 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.