Privacy Policy UK
ALRA Recruitment
Privacy Policy UK
Who are we and what do we do?
We are ALRA Recruitment (previously known as Australia’s Leading Recruitment Agency) trading as ALRA Trust. We provide Recruitment, Advisory and Professional Staffing Solutions to Companies and Job Seekers.
At ALRA, we respect your right to manage your personal data and information and do our absolute best to ensure our actions match your expectations.
If you have any questions about the management of your personal data, please don’t hesitate to get in touch at any time:
1300 002 572
What Personal Data do we Collect?
In our capacity as a Recruitment Agency, the personal information about you we collect is based upon enabling the ALRA team to be successful in helping you find suitable career opportunities.
This may include but is not limited to: name (first and surname), IP address, residential address / location, email address(es), phone number, mobile phone number, job title, current and past places of employment, employment experience, salary and financial information, role responsibilities, education records, resume / CV and previous work history, immigration status, right to work in the UK, applicable identification documents, emergency contact details, references (work and personal), and access to professional profiles (such as on LinkedIn).
We may at times collect sensitive personal data about you in response to the needs of the recruitment process. It is your right to refuse to provide this data and if you do provide it, we will only collect it upon your explicit consent. This data may include: trade union memberships, medical records (as applicable to your ability to perform your role), ethnicity / racial origins, sexual orientation, political leanings, religious beliefs and biometric data.
Where we Collect Data
Your personal data may be collected by us in a number of ways including:
- Directly: through interviews, email and phone conversations and / or in person.
- When you complete one of our registration forms or provide information in an application on our website.
- Through either digital or hard copy CVs via emailing, submitted on the ALRA website, mail or given in person.
- Through a 3rd Party including online job boards, job board databases, social media networks, other agencies acting on your behalf, referring parties, colleagues, past employers etc.
- We may receive information of any complaints or other information from or about you of conduct in the workplace.
- We may receive any information about any insurance investigations, litigation, registration or professional disciplinary matters, criminal matters, inquest or inquiry in which you were involved.
- Extra information that our clients may describe to us.
- We may receive results of inquiries that we might make of your former employers, work colleagues, professional associations or registration bodies.
- We may receive the results of any competency or medical test or background checks including but not limited to work rights, credit and criminal record checks
- Social media sites: LinkedIn, Twitter, Facebook, Instagram and other networking sites.
- Corporate Websites.
- Publicly available sources and databases.
How we use your Personal Data
We endeavour to use your data in an ethical manner and never send it to potential employers and interested parties (referees etc.) without your consent.
How & why we use your data includes:
- For potential or actual work placements including pre-recruitment activities & recruitment activities.
- Career guidance.
- Equal opportunities monitoring.
- To accurately keep you informed about potential job opportunities that match the career prospects you are looking for and / or that may be of interest to you.
- To provide detailed information to a company in order to progress a job opportunity through to the interview stage, offer stage and through to company onboarding.
- To provide relevant and accurate career advice, guidance and management.
- To accurately manage ALRA’s relationship with you.
- To allow the ALRA consultants to best respond to any personal or career related requests.
- To provide any and all recruitment related services including candidate management, consulting services, market analysis and market research.
- To contact you as a client, or potential employer with candidates that are suitable for your advertised needs or company structure, culture or skills.
- To ensure cooperation with relevant authorities.
- Performance assessments (which may include medical tests / assessments) that you may be required to undergo in relation to a possible placement.
- ALRA management and / or resolution of any complaint, inquiry or investigation in which you are involved
- Any workplace insurance claim or proposal that requires disclosure of your personal or sensitive information.
- To help ALRA establish, exercise or defend legal claims.
- Undertaking checks to verify your work rights status, criminal history and any other background checks, including credit checks for positions in the UK involving significant financial risk and otherwise as permitted by law
- To occasionally contact you with relevant marketing communications by email, SMS, post or through social media.
In most cases, we will use your personal data for these purposes if we deem it necessary for our legitimate interests in accordance with Article 6(1)(f) of the GDPR which says that we can process your data where it “is necessary for the purposes of the legitimate interests pursued by us or by a third party, except where such interests are overridden by the interests or fundamental rights or freedoms of you which require protection of personal data.”
We don’t believe that any of the activities in which we rely on the legitimate interests condition prejudice Candidates in any way. If you disagree, you do have the right to object to us processing your personal data on this basis. If you would like to know more about how to do so, please refer to the section below which outlines how you can access, amend or refuse data collection, get in touch or request for your data to be removed from our system.
In certain circumstances, we may process your personal data for the purposes below if it is necessary for us to deliver a contractual service to you (or to fulfil a pre-contract request from you). Article 6(1)(b) of the GDPR says that we can process your data where it “is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract.”
These circumstances may include:
- Collecting & processing your data to provide accurate recruitment services to Candidates and facilitating the recruitment process by:
- Collecting data from you personally and through other sources such as LinkedIn
- Storing candidate details on our database (we use Bullhorn, please go to the Bullhorn website to read their Privacy Policy available HERE).
- Comparing data against ALRA job vacancies.
- Sending candidate information to clients in order to access eligibility to jobs or apply to jobs.
- Enabling candidates to submit CVs, apply for jobs (online or physically in person / mail) or to subscribe to alerts / RSS feeds about jobs.
- Recording information candidates have provided during the interview process which may occasionally be used for ALRA internal training purposes.
- Collecting data in the course of communication with candidates in relation to services-related issues & providing support.
- Verifying candidate provided details (references, qualifications, criminal convictions, etc to the extent it is appropriate within the scope of local laws).
- Types of data that may be used:
- Key identification & contact information.
- Education, employment & experience information.
- Any additional information that you voluntarily choose to provide to ALRA.
- Information that others (past or potential employers, colleagues, referees etc) may provide to us.
- Legal basis relied upon:
- We will rely on legitimate interests – i.e. is it in our interests and your interests for ALRA to provide you with our recruitment services and for you to receive them so that we can function as a profit-making entity and to help both you & other candidates find employment.
- Address any issues you may be experiencing.
- Improve the recruitment services that we provide to you by considering your feedback.
- We will rely on the legitimate interests legal basis, namely it is in our interests and your interests to verify that all of the information that you have provided to us is true and accurate and to obtain references about your prior conduct as part of the process of finding you employment
Marketing:
ALRA will periodically send you information that you may find relevant, or to ask your help connecting / recommending other Candidates with jobs. Specifically, we will use your data for the purposes listed below, where appropriate and in accordance with local laws and requirements. Please note that this list is not exhaustive.
We need your explicit opt-in consent for some aspects of these activities or soft-opt-in (which we explain further below).
Soft opt-in consent: is a specific type of consent which applies where we have obtained your contact details from an occasion when you previously engaged with us (e.g. informing our consultants you are interested in our services, submitting an application or CV), and we are e-marketing or sending by text message, emails or other recruitment-related services of our own. Under ‘soft opt-in’ consent, we will take your consent as given unless or until you object or opt out (and we will remind you of your right to do this and provide you with the opportunity to opt-out, in each e-marketing message that we send to you). For most people, this is beneficial as it allows us to provide you with information that we think will be of interest to you and suggest other jobs to you alongside the specific one you applied for, significantly increasing the likelihood of us finding you a new position.
For other types of e-marketing, we are required to obtain your explicit consent. If you are not happy about our approach to marketing, you have the right to opt out or withdraw your consent at any time. We do try to ensure that your details are removed from marketing & if it does not get properly removed, we apologise, please let us know & our Data Officer will ensure it does.
- Why / How we process your information:
- Using candidate data to carry out marketing activities to promote ALRA services.
- Marketing our range of recruitment services
- Sending industry reports, events & general information we believe may be interesting to you based on your preferences.
- Collection of data via cookies / tracking pixels for ALRA advertisements via platforms like (but not limited to) Facebook, LinkedIn, Instagram etc.
- Lookalike audience targeting / any other data driven marketing to platforms like Facebook & Google.
- Types of data used:
- Key identification & contact information
- Automatically collected information (including advertising platform identifiers)
- Education & employment information
- Any additional information you choose to provide.
- Legal Basis relied upon:
- If we have obtained your contact details during a previous engagement with ALRA and we are marketing recruitment-related services of our own, we will rely on soft opt-in consent if we consider that the legitimate interests legal basis applies, namely if we wish to reach out to you to tell you about our services and we consider that it would be in your interests to hear about similar services to those that you have already expressed interest in
- In other circumstances we will obtain explicit, opt-in consent.
- We will obtain consent via Cookie Preferences on our website.
- We will obtain opt-in consent for collection of advertising identifiers via Cookies on our website & share these with Facebook and Google in reliance on the legitimate interests legal basis, namely it is in our interests to identify and target advertisements to potential customers who share characteristics or demographics with our existing customers, unless we are required by local law to obtain your consent.
Where does your data go?
In line with relevant laws, practices and our confidentiality compliance obligations, your data may be shared by ALRA to the following:
- Our client companies who have positions to fill that match your skills and expertise. These could include local small businesses, SMEs, national and global enterprises across numerous industries in any country or location where ALRA Recruitment conducts its business (primarily but not limited to Australia, New Zealand, the APAC region & UK).
- Other employees that may be able to assist your career goals within the ALRA team / offices.
- Suppliers, 3rd parties, professional advisers (accountants, lawyers, insurance brokers, background check companies, consultants), marketing agencies and events organisers.
- Government authorities or law enforcement agencies. We have a duty to comply with the UK where we believe we have an obligation to do so or to protect, defend or enforce ALRA’s rights.
- We may also need to provide your information to your referees, former employers or clients or relevant third parties in order to verify the information that you have provided.
- Referees
- Internal and external auditors of ALRA or our clients when we are required to share this data upon request to comply with our contractual or regulatory obligations.
- ALRA Recruitment Insurers.
- A Workers Compensation body
- Any person or entity with a reasonable, lawful entitlement to request & obtain the information
- For any disclosures outside of the UK, we take reasonable steps to ensure that the recipients of such information do not breach the GDPR & UK GDPR in relation to that information. We will endeavour to take reasonable steps to ensure, for instance pursuant to a contractual agreement, that your personal information receives an adequate level of protection, for example your information will be stored on secure servers that are protected in controlled facilities. We have put in place appropriate procedures with the third parties we share your personal information with to ensure that (a) your personal information is treated by those third parties in a way that is consistent with and which respects the privacy laws of Australia as appropriate and (b) will only use your information for the purpose of providing services to ALRA and will not use your information for any other purpose.
Refusal of data:
- It is your right to refuse giving the ALRA team any data.
- Please be aware that if you do not provide the data we seek, we may be limited in our ability to provide & locate suitable work to place you in.
How Long do we Keep your Data?
ALRA, in determining the appropriate retention period for different types of personal data, we consider multiple factors.
When determining the retention period we may take the following into consideration.
- Legal obligations to retain data.
- ALRA’s Contractual obligations.
- Our legitimate interests and ethical use intentions.
- Potential risk of harm from unauthorised use or disclosure of that data.
- The purpose for which ALRA needs to process that data
- The Statute of Limitations.
- Accounting, Tax & HR data retention necessities.
- Information required for the settlement of disputes (potential or actual).
- Your communications and requests regarding the use of your data.
- Guidelines as laid out in the GDPR & UK GDPR.
We may retain your information after your services with ALRA cease for legal, HR and / or accounting & tax reasons.
ALRA Retention Practices
Candidates:
- If you are a candidate, we will keep your personal data for a period of up to 2 years from the point of collection OR subsequently have meaningful interaction with you (or the company that you are working for on the basis of whether it is appropriate). There may be circumstances where your data is held for longer than this if it is in good faith that we need to do so (i.e. tax or legal obligations.).
- Meaningful contact is considered as submitting a CV, communicating with us via email, message service or in person about any potential roles or by clicking through to any of our marketing communication.
- If you indicate that as a candidate you would rather us not retain your persona; data, we will delete it from the ALRA database unless for reasons of good faith we are required to preserve it (tax of legal).
Clients / Suppliers:
- If you are a Client or a Supplier we will retain your personal data in order to provide you with services or to receive services from you, or to provide you with information about our services that we believe you may be interested in.
How do we keep your information secure?
Safeguarding the privacy of your information is important to the ALRA team, whether you interact with us personally, by phone, mail, over the internet or any other electronic medium. We hold personal information in a combination of secure computer storage facilities and paper-based files and other records and take such steps as are reasonable in the circumstances to protect the personal information we hold from misuse, interference and loss, unauthorised access, modification or disclosure. We may need to maintain records for a significant period of time. However, when we consider information is no longer needed, we will remove any details that will identify you or we will securely destroy the records.
For Clients:
If you are a client of ALRA, while providing or offering your company services, w we will need to collect and use information about you, or individuals at your organisation. We collect client personal data that we either receive directly from you or collect / receive from other sources. This information may include (where appropriate and in accordance with any applicable laws and requirements), more information about you or your colleagues from other sources generally by way of due diligence or other market intelligence; third party market research and by analysing online and offline media.
The main reason for using information about clients is to enable us to properly introduce ourselves to you and to ensure that the contractual arrangements between us can properly be implemented so that the relationship runs smoothly for both parties. This will involve providing you with our various recruitment and related advisory services. The more information we have, the more tailored & relevant we can make our service to your company.
We manage your data to facilitate this by:
- Storing your details (and updating as necessary) on our database, so that we can contact you in relation to recruitment activities. This information may be disclosed to ALRA employees including Recruiters, Administration & IT who assist with maintenance and development of our IT systems.
- Keeping records of our conversations and meetings
- Processing your data for the purpose of targeting appropriate marketing campaigns for our services, to do this we use marketing technology platforms
Legal Allowances
ALRA conducts regular analysis of our systems in relation to your data to ensure that our retention and processing is both necessary and in line with our legal obligations and your rights.
For candidates, potential ALRA employees, contractors, clients and referees, our processing of your data is necessary for our legitimate interests or our ability to accurately and suitably assess the best career matches, location of new candidates and ability to contact clients and referees.
We may also require the processing of your data to adequately perform a job search for you or find suitable candidates for your company.
Where sensitive information is required from you, we will only obtain this with your explicit consent. It will not be referred to any third parties without your explicit consent.
Legally, we may also use your information for legal purposes (to establish, exercise or defend legal claims) or where personal information already exists within the public domain. The legal basis for this processing activity is that it is in the public interest.
Digital & Security Measures
To ensure an accurate service to you from the ALRA website, we use cookies to collect your personal data.
We utilise security (technical and organizational) measures to ensure the security of your data and endeavour to ensure all our staff is fully trained in these areas. Whilst we cannot guarantee that unauthorised access will not occur as the internet in general is not a completely secure medium, our systems are designed, to the best of our ability, to digitally and managerially protect your personal data from unauthorised access, destruction, transmission, misuse, or unethical / inaccurate alteration.
Whilst we encourage security in any third parties ALRA deals with, we cannot ensure they adhere to best practice data management and therefore accept no responsibility for third party compliance to relevant data and privacy laws.
Your Data Rights
A main objective of the GDPR is to protect the rights of EU citizens & individuals within the EU in regard to data privacy. This means that legally, you have many rights when it comes to the retention and use of your personal information. These include:
- The Right to be Informed. You have the right to the provision of clear, transparent and easily understandable information as to how we use your data and personal information. This is outlined by this Privacy Policy.
- The Right of Access. You can, at any time request and obtain access to your information (if being processed by ALRA) and information like our Privacy Policy. This allows you to check ALRA’s handling of your information is compliant with relevant laws. (DSAR – Data Subject Access Requests).
- The Right to Rectification. You have the right to have your information corrected if it is inaccurate or incomplete.
- The Right to Erasure. This enables you to request the removal / deletion of any and all of your personal data from the ALRA system where there is no compelling reason for us to be holding it. This does not necessitate a general right to erasure as there are necessary exceptions.
- The Right to Restrict Processing. You have the right to prevent of restrict further use of your personal information. In this event, ALRA may still store your information but may no longer use it.
- The Right to Data Portability. You have the right to obtain and reuse your personal data for your own personal use across different services such as moving your information to a different recruitment agency. This allows your data to be safely transferred without affecting its usability.
- The Right to Object to Data Processing. You have the right to object to certain forms of data processing (direct or indirect marketing or in the event you no longer wish to be contacted for career opportunities).
- The Right to Lodge a Complaint. You have the right to lodge complaints about how ALRA handles your data with your national protection regulator. In the UK, this is the Information Commissioner’s Office who you can contact via 0303 123 1113 or email casework@ico.org.uk
- The Right to Withdraw Consent. If you have previously given consent for ALRA to use your data, you have the right to withdraw this at any time. This does not retroactively negate previous consent given but restricts future use.
If any of the above are requested, this information is provided free of charge with potential fee considerations made to cover administrative costs where baseless or excessive / repeated requests are made or further copies of the same information or requested. There are some circumstances in which we may deny the request where it is in line with ALRAs rights and not in conflict with your legal rights. We respectfully ask that you carefully consider any request in a responsible manner before submitting it. In response, we will respond as quickly as is possible.
Data Collection as Pertaining to the ALRA Website
Unless you specifically submit a form to the ALRA team, we gather information about our website users collectively, such as what areas users visit more frequently and what services users access the most. Such data is anonymous and in the aggregate. This information helps us determine what parts of the website are most beneficial for our users, and how we can continually create a better experience. Websites where this general (not specific or personal) information is gathered include: www.alra.com.au and www.alrarecruitment.co.uk
If more specific information is required such as name, address, email address, telephone number etc. This information is only collected if you apply for a job or sign up for a service or enquiry via our website. We may also ask you for other information such as the types of jobs you are interested in to provide you with the best possible recruitment service.
What are ‘Cookies’ and how are they used on the ALRA website?
A ‘cookie’ is a bite-sized piece of data that is stored on your computer’s hard drive. They are used by nearly all websites and do not harm your system. As in the case of most websites, ALRA uses cookies to track your activity to ensure you get the best experience when visiting our website. We can use cookie information to ensure we present you with options tailored to your preferences on your next visit. We can also use cookies to analyse site traffic & for advertising purposes.
If you want to check or change what types of cookies you accept, this can usually be altered within your browser settings. Cookies are either:
Session cookies: these are temporarily stored on your computer during your web session and are deleted when you close your browser – they generally store an anonymous session ID allowing you to browse a website without having to log in to each page but they do not collect any information from your computer; or
Persistent cookies: a persistent cookie is stored as a file on your computer and remains when you close your browser. The cookie can be read by the website that created it when you visit that website again. We use persistent cookies for Google Analytics (these can be deleted by removing your browser history).
Strictly necessary cookies: Essential cookies enabling effective website use, e.g. when applying for a job, and therefore cannot be turned off. Without these cookies, the services available to you on our website cannot be provided. These cookies do not gather information about you that could be used for marketing or remembering where you have been on the internet.
Performance cookies: These cookies enable ALRA to monitor and improve the performance of our website and determine which sections of the website need changing or are working well to provide the best experience for you.
Functionality cookies: These cookies allow our website to remember choices you make (such as your username, language or the region you are in) and provide enhanced features. For instance, we may be able to provide you with news or updates relevant to the services you use. These cookies can also be used to remember changes you have made to text size, font and other parts of web pages that you can customise. They may also be used to provide services you have requested such as viewing a video or commenting on a blog. The information these cookies collect is usually anonymous.
Personalisation cookies: These cookies help us to advertise details of potential job opportunities that we think may be of interest based on what you have looked at previously. These cookies are persistent (for as long as you are registered with us).
How to Reject Cookies?
If you don’t want to receive cookies that are not strictly necessary to perform basic features of our site, you may choose to opt-out by changing your browser settings. Most web browsers will automatically accept cookies but if you would rather we didn’t collect data in this way you can choose to accept all or some, or reject cookies in your browser’s privacy settings. Rejecting all cookies means that you may not be able to take full advantage of all our website’s features. For further information on cookies, including how to disable them, please refer to aboutcookies.org. You will also find details on how to delete cookies from your computer.
Get in Touch
If you are not satisfied with how we have handled your personal information or the processing of your data, you may contact us at:
Beth O’Neil
1300 002 572
Sydney: L2 – 54-56 Darley St, Mona Vale, Sydney Australia 2103
London:
Policy Changes
This Privacy Policy was last updated in July 2023. It will be reviewed as needed to consider any changes in applicable local and international laws and internal ALRA policies to ensure that it maintains best practice.
Complaints:
We aim to acknowledge receipt of all complaints within 10-15 working days and aim to resolve all complaints within 30 working days. This may not be possible in all circumstances depending on the contents of the complaint. In this situation, we will respond to your complaint in a reasonable time. If you are not satisfied with our response to your complaint, in the UK you can contact hello@alrarecruitment.co.uk