Beament Leslie Thomas Recruitment Consultancy Ltd
Beament Leslie Thomas Recruitment Consultancy Ltd (BLT) is a UK registered recruitment business, operating globally from offices in central London. We provide work-finding and recruitment solutions in the fields of Indirect Tax and Management Consulting. We also provide associated services, including running recruitment related events and network groups and producing salary surveys and market reports.
BLT must process personal data so that it can provide these services – in doing so, BLT acts as a Data Controller.
Beament Leslie Thomas is registered as a Data Controller with the Information Commissioner’s Office, reference Z7536270.
BLT (‘we’; ‘us’; ‘our’) take your privacy very seriously and are committed to protecting the personal information that we collect. We will take appropriate care to keep your information secure and to prevent any unauthorised access or use of it. We implement various security measures to maintain appropriate controls over the processing and transfer of personal data.
This Policy was last revised on: 21st February 2023.
How is personal data collected?
BLT collect personal data in a number of ways. Most commonly these include:
- Registration with BLT as a candidate for employment when you apply for jobs via our website, app, LinkedIn or other third party websites where we advertise; or when you email or telephone us directly.
- Contact from an employer to whom recruitment services are to be provided, whether via our website, app, LinkedIn or other third party websites where we advertise; or when you email or telephone us directly.
- Prospective future candidates for employment or prospective employers whose data is gleaned from widely available sources (such as LinkedIn, corporate websites, job board websites or online CV libraries).
- When invited to join any networking group or attend any event that BLT runs.
- When you enter a survey that BLT runs.
- As an employee or prospective employee of BLT.
- As a supplier contact that support our services.
What personal data is collected?
The type of personal data BLT collect about you will depend on the circumstances in which that data is collected.
The standard personal data BLT collect and store is: your name, your employer, your job title, and your contact details (e.g. email address, telephone number).
Additional data is collected if you have registered with BLT as a candidate for employment, whether currently or in the past. Such data is likely to include a copy of your CV, salary details and expectations, right to work documents, details of applications, recruitment history.
If you are, or intend to be, an employee of BLT, additional data is collected such as next of kin and emergency contact information, right to work documents, financial information including National Insurance number, bank account details, payroll records and tax status information.
Collecting and processing sensitive personal data
Sensitive personal data is data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation.
BLT do not typically collect or store sensitive personal data. However, in some recruitment assignments, our clients may request us to collect and process sensitive personal data from prospective applicants. In that event, we will contact you to ask for your explicit consent for this sensitive personal data to be collected and processed.
You may refuse to provide any of the sensitive personal information we request.
In addition, as part of our commitment to Equal Opportunity and to monitor compliance with our Equal Opportunity Policy, we may ask you if you would like to complete a Diversity Questionnaire. Should you wish to complete the questionnaire, you will provide your explicit consent for BLT to store this information, and for how long, and the information you provide is given voluntarily, anonymised and stored separately from your personal records.
Legal basis for processing data and the purpose of processing data
BLT have a legitimate interest for processing personal data, given that it is necessary to process personal data in order to provide our services to you. As long as your data protection rights are not infringed, BLT are allowed to process your data when it is in the interests of the business to do so.
The precise purpose of processing personal data will depend on the circumstances in which that personal data is collected.
BLT will only process your personal data for the reason for which you provided it or for reasons that are directly related to this reason. For example, when you register as job seeker with us, we will use your personal data to assess your skills and experience for employment opportunities, to contact you about suitable roles, to provide you with career guidance, to share with you with industry or sector specific information or services that are similar to that which you have contacted us about, to invite you to participate in relevant surveys, and to put you forward for positions when you have agreed that we are to do so.
Similarly, when we collect personal data from an employer, we will collect and process the personal data necessary to provide recruitment services to you; to share with you industry or sector specific information or services that are similar to that which you have contacted us about, to discuss roles with potential candidates and to submit applicants to the prospective employer.
When we collect personal data from an individual invited to join any networking group or event that BLT runs, we will collect and process the personal data necessary to run and administer the networking group or event.
Legitimate interest cannot be used as a lawful basis for collecting and processing sensitive personal data, so in the event that our clients request us to collect and process sensitive personal data, we will contact you to ask for your explicit consent for this sensitive personal data to be collected and processed.
Personal data may also be processed should it be necessary for any contract between you and BLT, or as a requirement necessary to enter into any contract.
In very rare circumstances, we may have a legal obligation to process personal data, for example to law enforcement authorities or to prevent a serious threat to public safety.
Use of personal data for Direct marketing
When we collect personal data from you, we welcome the opportunity to share with you market insights in the form of Newsletters (whether Indirect Tax or Management Consulting), Market Reports, Salary Surveys or information about events and/or networking groups.
You will only receive these communications if you are one of our clients or registered candidates (whether as a current job seeker or client, or in the past); if you have opted-in to receive these communications or if we believe it is in your business interest to receive these communications because it is relevant to your career or your organisation.
You may request not to receive such communications at any time by using the facility to ‘unsubscribe’ included in the email or communication concerned.
Who can access the personal data we collect?
In order to provide our services to you, your personal data will typically be accessible by other employees of BLT as well as the contact by whom the data was originally collected.
Your personal data may also be accessible by third parties who perform functions on our behalf, such as BLT’s IT service providers who carry out testing and development work on our business technology systems.
Disclosure of personal data to third parties
Personal data is disclosed to other companies (‘third parties’) depending on the reason for which that personal data is primarily held, or for a related reason. This will be for the reason for which you provided it to us; for example when registered as a job seeker with us, in order to provide your data to a prospective employer once you have confirmed that you would like to apply to an available position or where you have otherwise agreed we may disclose it.
In the event of you being registered as a job seeker with BLT, and asking us to make an application outside of the country from which you are applying, your personal data will be sent to employers in that country. Please be aware that the degree of protection of your personal data in a different country may not be the same as in your country of residence. BLT will only transfer personal data to countries outside the European Economic Area (‘EEA’) for the purposes of providing work-finding or recruitment services. This will be with the permission of the relevant data subject and where the risk to the rights of the data subject is low.
Personal data is also processed to third parties who perform functions on our behalf as data processors. These may be physically situated outside of the EEA. These are:
- Bullhorn – a cloud-based customer relationship management (CRM) and operations software company, where data on our computerized database is stored
- iContact – an email marketing company, via whom direct marketing communications are sent to subscribers to our newsletters, market reports, salary surveys etc.
- Westtek – an IT support and technology services company, who manage and maintain our internal IT and technology systems.
These companies have demonstrated to us that they have appropriate safeguards and security measures in place to ensure their compliance with GDPR.
Safeguarding and Storage of personal data
All personal data is stored on secure cloud-based servers, and every endeavour is made to have in place sufficient technical and organisational measures to safeguard personal data. We cannot however guarantee that loss, alteration or misuse of data will not take place, despite the security measures we have in place to minimise the likelihood of this eventuality.
Our website and internet based transfers
Using the internet to collect and process data involves the transmission of data on an international basis, given the internet is a global environment. There are risks involved in transmitting data in this way. For instance, by communicating with BLT electronically via our website (www.blt.co.uk), app, social networking websites (e.g. LinkedIn), via job boards or via other websites where we advertise our services, we are unable to guarantee that the personal data you submit will not be intercepted when submitted. External websites operated by other companies will be subject to that company’s privacy practices over which BLT has no control. BLT cannot guarantee the privacy practices of any third party websites.
BLT will retain your personal data only for as long as is necessary to comply with our statutory and contractual obligations and in accordance with our legitimate interests as a data controller. Different laws require us to keep different data for different periods of time.
The Conduct of Employment Agencies and Employment Business Regulations 2003, require us to keep work-seeker and hirer records for at least one year from (a) the date of their creation or b) after the date on which we last provide work-finding services.
BLT will typically retain personal data for up to fifteen years from the date of last contact, unless it is deemed necessary to retain such personal data for longer. We have chosen fifteen years as the specialist employment markets for which we provide ongoing advice and recruitment services do not typically feature a high turnover of staff. Therefore it is in our legitimate interests to retain the data so that we can provide a long term continuous offering for those who may wish to engage BLT’s services just once or twice during the course of their careers.
Where we have sought explicit consent for the collection and processing of sensitive personal data, this will only be stored and processed for the defined period of time that you have given your explicit consent for such to be stored and processed.
Please be aware that you have the following data protection rights: the right to be informed about the personal data BLT processes on you; the right of access to the personal data BLT 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 any given consent at any time.
You may contact BLT to seek access to, rectify, and/or request deletion of the personal data we hold on you. We will require that you provide suitable identification.
To make a request to access your personal information, please email us with your request and provide verification of your identity. We will provide this information within 30 days, excepting any information that would interfere with the privacy rights and confidentiality of other individuals or companies.
Your co-operation in helping us store accurate personal data for you is very valuable to us. Please email us to rectify any personal data we hold on file you, for example change of name, address details, or to provide us with an up-to-date CV.
Should you wish for your file to be deleted, we will process this where possible, but please be aware that there may be occasions where we may not be required to do so, particularly where your file also includes financial/employment records that we need to keep for periods up to six years.
Should you wish to access, rectify or delete the personal data we hold, please email BLT’s Data Protection Officer.
How to make a complaint
If you believe this policy has been breached in any way, please write to or email BLT’s Data Protection Officer, verifying your identity, and setting out in as much as detail as possible the detail of the personal data affected, and the reason for and circumstances of your complaint. We will provide a written response within 30 days after concluding an internal investigation. We may contact you should we need any additional information.
You also have the right to raise any concerns with the Information Commissioner’s Office in the UK 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.
Contact BLT’s Data Protection Officer
Contact: Guy Barrand
Address: Central Court, 25 Southampton Buildings, Chancery Lane, London WC2A 1AL