1. Introduction

Coppersmith Recruitment and Services Ltd (“Coppersmith”, “we”, “us” or “our”) is committed to protecting the privacy and personal information of candidates, temporary workers, contractors, clients, prospective clients, suppliers, website visitors and business contacts.

This Privacy Notice explains how we collect, use, store, disclose and protect personal data in connection with our recruitment, staffing and related services, including information collected through our website.

We process personal data in accordance with applicable UK data protection law, including the UK General Data Protection Regulation (UK GDPR), the Data Protection Act 2018 and, where applicable, the Privacy and Electronic Communications Regulations 2003 (PECR), as amended from time to time.

For the recruitment activities described in this notice, Coppersmith Recruitment and Services Ltd will generally act as the data controller, meaning that we determine the purposes and means of processing personal data.

2. Who This Notice Applies To

• Candidates seeking permanent, temporary or contract work, including people we identify as potentially suitable for opportunities.
• Temporary workers, agency workers and contractors.
• Individuals working for or representing clients and prospective clients.
• Referees, emergency contacts and other individuals whose details are supplied to us.
• Suppliers, service providers, business partners and website visitors.

3. Personal Data We May Collect

Candidate and worker information

• Name, address, email address, telephone number and other contact details.
• CV or résumé, employment history, education, qualifications, skills and professional memberships.
• Job preferences, salary or pay expectations, location, availability, working hours and shift preferences.
• Applications, interview notes, recruitment assessments and communications with us.
• References and referee details.
• Identification, immigration status and right-to-work information where required.
• National Insurance, payroll and bank details where required for employment, engagement or payment.
• Assignment records, attendance, hours worked, performance and placement history.
• Information available from job boards, professional networking platforms and other publicly accessible professional sources.
• Technical website information such as IP address, browser/device information, pages visited, access times and cookie data.

Special category and criminal offence information

Where necessary and legally permitted, we may process special category information, for example health or disability information needed to make reasonable adjustments, and equality monitoring information where collected. We may also process criminal conviction or offence information where a role lawfully requires vetting, including an appropriate Disclosure and Barring Service (DBS) check.

Where we process special category or criminal offence information, we will identify an appropriate lawful basis and any additional condition required by the UK GDPR and Data Protection Act 2018.

4. How We Obtain Personal Data

• Directly from you when you register, apply for a role, submit a CV, complete a form or communicate with us.
• From recruitment websites, job boards, professional networking platforms and publicly accessible professional sources.
• From referrals, recommendations, clients, Managed Service Providers (MSPs), Vendor Management Systems (VMSs) and recruitment partners.
• From previous employers, referees, background screening providers, payroll providers and other compliance or employment administration partners.

Where we obtain your personal data from another source rather than directly from you, we will provide the required privacy information within the period required by law, subject to any applicable exemption.

5. How We Use Personal Data

• To provide recruitment and staffing services and match candidates with suitable opportunities.
• To communicate with candidates, workers, clients and business contacts.
• To assess suitability, arrange interviews and manage recruitment processes.
• To introduce or submit candidates to clients and prospective employers.
• To verify experience, qualifications and references and undertake appropriate right-to-work, identity, DBS, background or compliance checks.
• To onboard and administer temporary workers or contractors, including assignments, timesheets, payroll and payments.
• To maintain our recruitment database and consider candidates for current and future opportunities.
• To manage client, supplier and commercial relationships and administer contracts.
• To prevent fraud, protect our business, resolve disputes and establish, exercise or defend legal claims.
• To comply with legal, regulatory, tax, employment, immigration and other obligations.
• To operate, secure, analyse and improve our website, systems and recruitment services.
• To send permitted recruitment alerts, service communications and marketing communications.

6. Lawful Bases for Processing

Depending on the activity, we may rely on one or more of the following lawful bases:

• Legitimate interests – including operating a recruitment business, identifying suitable candidates, filling vacancies, maintaining candidate and client relationships, developing our services and protecting our business, provided those interests are not overridden by your rights and freedoms.
• Contract – where processing is necessary to take steps at your request before entering into a contract or to perform a contract with you.
• Legal obligation – where processing is necessary to comply with applicable legal or regulatory requirements.
• Consent – where consent is the appropriate lawful basis. Where we rely on consent, you may withdraw it at any time without affecting processing already carried out lawfully.

7. Candidate Information Shared with Clients

A core part of our recruitment service is introducing suitable candidates to organisations that may wish to employ or engage them. We may therefore share information such as your CV, employment history, skills, qualifications, availability, location, pay expectations, recruitment assessments and other information relevant to a vacancy with clients or prospective employers.

We aim to limit disclosures to information reasonably necessary and appropriate for the recruitment process.

8. Background Checks, Right to Work and Compliance

Depending on the role, client requirements and applicable law, candidates may be required to undergo identity, right-to-work, employment history, reference, qualification, DBS or other appropriate pre-employment screening. Information may be shared with trusted screening and compliance providers for these purposes.

9. Recruitment Technology, AI and Automated Processing

We use recruitment technology to manage vacancies, applications, candidate records, communications and placements. Technology, including artificial intelligence or automated tools, may assist our recruiters in searching, filtering, organising, matching or prioritising candidates using factors such as skills, experience, qualifications, location and availability.

Where automated tools are used, we will comply with applicable data protection requirements and maintain appropriate safeguards. Unless we specifically tell you otherwise, we do not intend to make recruitment decisions producing legal or similarly significant effects solely through automated processing without appropriate safeguards and human involvement.

10. How We Share Personal Data

Where necessary for the purposes described in this notice, we may share personal data with:

• Clients, prospective employers and organisations involved in a recruitment process.
• MSPs, VMS providers, recruitment partners and other organisations within a recruitment supply chain.
• Payroll, employment administration, umbrella company and worker payment providers.
• Background screening, DBS, identity verification, right-to-work and compliance providers.
• CRM, hosting, cloud, communications, IT support, analytics and other technology providers.
• Professional advisers, insurers, accountants, auditors and legal advisers.
• Coppersmith group companies where appropriate for legitimate business and recruitment purposes.
• Government departments, regulators, courts, law enforcement bodies or other authorities where disclosure is required or permitted by law.

We do not sell personal data.

11. International Transfers

Because we use international technology and service providers and may operate with group companies, partners or clients outside the United Kingdom, personal data may be transferred to or accessed from countries outside the UK.

Where required, we use an appropriate lawful transfer mechanism, which may include UK adequacy regulations, the UK International Data Transfer Agreement (IDTA), the UK Addendum to approved Standard Contractual Clauses or another legally permitted safeguard. You may contact us for further information about safeguards relevant to your personal data.

12. Data Retention

We retain personal data only for as long as reasonably necessary for the purposes for which it was collected, including recruitment and future employment opportunities, contractual administration, legal and regulatory requirements, dispute resolution and the establishment, exercise or defence of legal claims.

Retention periods vary according to the nature of the information, whether you have been placed or employed through us, our ongoing relationship with you, applicable statutory requirements and relevant limitation periods. Where information is no longer required, it will be securely deleted, destroyed or anonymised.

Information obtained specifically for vetting or background-check purposes will not be kept for longer than reasonably necessary, although we may retain an appropriate record that a check was completed and its outcome where legally permitted.

13. Data Security

We use appropriate technical and organisational measures designed to protect personal data against unauthorised access, accidental loss, misuse, alteration, disclosure or destruction. Measures may include access controls, restricted permissions, secure technology platforms, password protection, staff procedures and use of reputable service providers.

No electronic system can guarantee absolute security, but we take reasonable and proportionate measures to protect the information entrusted to us.

14. Your Data Protection Rights

Depending on the circumstances and lawful basis for processing, you may have rights to access your personal data; request rectification; request erasure; restrict processing; object to processing; request data portability; withdraw consent where processing relies on consent; and exercise applicable rights relating to automated decision-making.

These rights are not absolute and exemptions may apply. We may ask for reasonable proof of identity before responding to a request.

RIGHT TO OBJECT: You have an absolute right to object to the use of your personal data for direct marketing. You may also object to processing based on legitimate interests in certain circumstances.

To exercise your rights, contact us using the details in section 20.

15. Recruitment and Marketing Communications

We may contact candidates about employment opportunities that we reasonably believe may be relevant to their experience or preferences. We may also communicate with business contacts about our recruitment services where permitted by law.

You can ask us to stop direct marketing communications at any time. Opting out of marketing does not prevent us from contacting you about an active application, assignment, placement, contract, service matter or legal obligation.

16. Cookies and Website Information

Our website may use cookies and similar technologies for functionality, security, analytics and user experience. Where consent is required for non-essential cookies, we will seek it through an appropriate cookie management mechanism. Further details should be provided in our Cookie Policy.

Our website may contain links to third-party websites. We are not responsible for their privacy practices and encourage you to review their privacy notices.

17. Providing Personal Data

In some circumstances, providing particular personal data is necessary to enter into or perform a contract with us or to comply with legal requirements, for example right-to-work or payroll information. If required information is not provided, we may be unable to progress an application, make a placement, engage you for an assignment or provide certain services.

18. Personal Data Breaches

We maintain procedures for identifying, assessing and responding to suspected personal data breaches. Where required by law, we will notify the Information Commissioner’s Office and affected individuals within the applicable legal timeframes.

19. Complaints and the Information Commissioner’s Office

If you have concerns about how we use your personal data, please contact us first so that we can investigate. You also have the right to complain to the Information Commissioner’s Office (ICO), the UK’s independent data protection regulator. Further information is available at the ICO’s official website.

20. Contact Us

For questions about this Privacy Notice, how we handle personal data, or to exercise your data protection rights, please contact:

Coppersmith Recruitment and Services Ltd

Email: jobs@coppersmith.co.uk

Phone: +44 7551 341 310

Address: Staple House, 5 Eleanors Cross, Dunstable, United Kingdom, LU6 1SU

21. Changes to This Privacy Notice

We may update this Privacy Notice from time to time to reflect changes in law, technology, our recruitment services or business practices. The latest version will be published with an updated revision date. Where required, we will bring material new uses of personal data to the attention of affected individuals before beginning the new processing.