Kineo Connect Data Privacy Policy

1. Introduction

At Kineo Connect, we’re absolutely committed to protecting the privacy and security of the personal information of everyone we engage with – that’s our candidates, our clients, and all other stakeholders. This comprehensive Data Privacy Policy sets out precisely how we collect, use, process, and protect your personal data, all in line with the latest data protection laws, including the UK General Data Protection Regulation (UK GDPR) and the EU General Data Protection Regulation (GDPR).

By engaging with Kineo Connect, you’re acknowledging and agreeing to the practices we’ve outlined in this policy.

2. Who We Are

Kineo Connect is a recruitment agency based right here in the UK, operating across Europe. We specialise in connecting top-tier talent with leading companies, primarily within the tech and finance sectors.

3. Data Controller

Kineo Connect acts as the data controller for the personal information processed under this policy. This means we’re responsible for deciding how your personal data is used and for what purposes.

4. Scope of this Policy

This policy applies to:

Candidates: Individuals looking for employment opportunities through Kineo Connect.
Clients: Companies or organisations that enlist Kineo Connect for their recruitment needs.
Website Visitors & General Stakeholders: Anyone visiting our website, getting in touch with us, or generally interacting with Kineo Connect in a professional capacity (e.g., our suppliers, business contacts).

5. Data We Collect and How We Use It

The personal information we collect and how we put it to use varies depending on your relationship with Kineo Connect. We handle your data with the utmost care and purpose.

5.1 For Candidates

We collect and use your personal information to provide you with our recruitment services, helping to match you with suitable job opportunities and generally assisting with your job search.

Data We Collect:

Contact Information: Your name, email address, phone number, and postal address.
Employment Information: Your CV/Resume, cover letter, employment history, salary expectations, skills and qualifications, educational background, professional certifications, and references.
Application Information: Your preferred locations, job titles, specific salary expectations, notes from interviews, and any assessment results.
Communication Information: A record of your communications with us, such as emails, phone calls, and messages.
Equal Opportunities Information (Optional): This might include details about your gender, ethnicity, age, disability, and sexual orientation. This information is always collected on a voluntary basis and is used purely to monitor and enhance our diversity and inclusion efforts. Crucially, it will not be used as part of the actual recruitment decision-making process.
Publicly Available Information: Information from professional networking sites (like LinkedIn) or other public profiles that are relevant to your professional background.

How We Collect Your Information:

Directly from you: When you send us your CV/Resume, apply for a job, get in touch for career advice, or interact with us in any other way.
From third parties: We might receive your information from other recruitment agencies (if applicable), professional networking sites, or other publicly accessible professional sources.

How We Use Your Information:

To provide our recruitment services, including matching you with appropriate job opportunities, presenting your profile to potential employers (our clients), and arranging interviews.
To process your job applications and facilitate the entire hiring process.
To keep you informed with job alerts, career advice, invitations to events, or any other relevant information.
To continuously improve our recruitment processes and services, ensuring we offer you the best possible support.
To comply with our legal and regulatory obligations, such as anti-discrimination laws and data protection regulations.

5.2 For Clients

We collect and use your personal information to deliver our recruitment services, manage our ongoing business relationship, and ensure successful placements.

Data We Collect:

Contact Information: The name, job title, email address, phone number, and company address of your representatives we’re working with.
Company Information: Your company’s name, industry, size, specific recruitment needs, detailed job specifications, interview feedback, and contractual details.
Financial Information: Billing and payment details, as necessary for invoicing and processing payments.
Communication Information: Records of our communications, including emails, phone calls, and meeting notes.

How We Collect Your Information:

Directly from you: When you engage our services, discuss your hiring needs with us, or provide feedback.
From publicly available sources: Such as your company’s official website or professional networking sites (e.g., LinkedIn).
From third-party business partners: Where applicable, through referrals or joint ventures.

How We Use Your Information:

To provide and manage our recruitment services, which includes understanding your precise hiring requirements, sourcing and presenting suitable candidates, and facilitating the hiring process.
To manage our client relationship, encompassing all communications, contract management, and invoicing.
To keep you updated on our services, offer market insights, or share relevant industry news.
To refine and improve our services, ensuring they’re always tailored to your specific needs.
To comply with our legal and regulatory obligations.

5.3 For Website Visitors & General Stakeholders

We collect and use your personal information to manage our general business operations, continually enhance our website, and ensure effective communication.

Data We Collect:

Contact Information: Your name, email address, phone number, and company details (if you provide them during an inquiry).
Technical Data: Your IP address, browser type and version, operating system, and website usage data (like pages visited, time spent on site) collected through cookies and analytics tools.
Communication Information: Records of any inquiries or general communications you have with us.

How We Collect Your Information:

Directly from you: When you complete contact forms on our website, send us emails, or call us.
Automatically: Through cookies and similar tracking technologies when you browse our website.

How We Use Your Information:

To respond to your inquiries and provide you with information.
To improve our website’s functionality and your overall user experience.
To analyse website traffic and identify trends.
To send general business updates or marketing information (but only where we have your consent).
To comply with our legal obligations.

6. Legal Basis for Processing

We process your personal information based on the following legal grounds, depending on the nature of our interaction with you:

Legitimate Interests: This applies where it’s necessary for our legitimate interests to provide our services effectively, grow our business, prevent fraud, and meet legal obligations, as long as your rights and interests don’t override those. For instance, this covers:
- Providing recruitment services to both candidates and clients.
- Improving our website and services.
- Carrying out business development and marketing activities (where permissible).
Contract: This is when processing is essential for performing a contract with you, or taking steps at your request before entering into a contract. This applies, for example, when:
- Managing recruitment agreements with our clients.
- Facilitating employment contracts with candidates we place with our clients.
Consent: This is where we’ve specifically obtained your explicit and informed consent for certain processing activities. Examples include:
- Collecting optional Equal Opportunities Information from candidates.
- Sending you direct marketing communications if required by law.
- Using certain non-essential cookies on our website.
Legal Obligation: This covers situations where processing is necessary to comply with a legal or regulatory obligation that Kineo Connect is subject to. This includes, for example, adherence to tax laws, anti-discrimination legislation, and data protection regulations.

7. Data Sharing and Disclosure

We may share your personal information with the following types of recipients, always with a clear purpose and appropriate safeguards:

Our Clients: For our candidates, your information (such as your CV/Resume and professional background) will be shared with our clients (potential employers) for job matching and application purposes. This will only happen with your explicit consent for each specific application, or where we have a legitimate interest to do so and have informed you beforehand.
Service Providers: We work with carefully selected third-party vendors and service providers who carry out services on our behalf, such as IT support, cloud hosting, email services, and payment processing. These providers are strictly bound to protect your data and only use it for the precise purposes for which we disclose it to them.
Professional Advisors: This includes our lawyers, accountants, and other professional advisors who need access to your data to provide their services to us.
Legal and Regulatory Authorities: We’ll share data when legally required, or in response to valid legal requests, such as court orders or government investigations.
Business Transfers: In the event of a¹ merger, sale of company assets, financing, or the acquisition of all or part of our business by another company, your information might be transferred in connection with or during the negotiations of such a transaction.

We absolutely will not sell or rent your personal information to third parties for their marketing purposes without your explicit consent.

8. International Data Transfers

Given our European operations, we may transfer your personal information to countries outside the European Economic Area (EEA) and the UK. When we do transfer your personal information to a country outside the EEA or UK, we make sure that robust, appropriate safeguards are in place to protect your information. These safeguards typically include:

The use of Standard Contractual Clauses (SCCs) approved by the European Commission and the UK Information Commissioner’s Office (ICO).
Transfers to countries that are officially deemed to provide an adequate level of data protection by the European Commission or the UK government.
Other legally approved mechanisms.

9. Data Security

We take rigorous technical and organisational measures to shield your personal information from unauthorised access, use, disclosure, alteration, and destruction. These measures include:

Access Controls: Limiting access to your personal information to only our authorised personnel, and strictly on a need-to-know basis.
Data Encryption: Encrypting sensitive data where appropriate, both during transmission and when it’s stored.
Physical Security: Implementing robust physical security measures to protect our offices and data centres.
Regular Security Audits: Conducting regular assessments of our systems and processes to spot and rectify any vulnerabilities.
Staff Training: Providing ongoing, comprehensive data protection and security training to all our employees.

Whilst we go to great lengths with our security efforts, no system is entirely impenetrable, and we cannot guarantee the absolute security of your information.

10. Data Retention

We’ll hold onto your personal information for as long as it’s necessary to fulfil the purposes for which it was collected, or to meet any legal, accounting, or reporting requirements.

The specific retention periods will naturally vary depending on the type of data and our relationship with you:

For Candidates: We typically keep candidate data for a period of two years from your last active engagement or update of your profile. This allows us to consider you for future opportunities, unless you ask for earlier deletion or we’re legally obliged to keep it longer.
For Clients: We retain client data for the entire duration of our business relationship and for a period thereafter as required by legal obligations (such as tax and accounting records) or our legitimate business interests.
For General Inquiries: Information from general inquiries will be kept for as long as needed to resolve the query, plus a short period afterwards for proper record-keeping.

Once the retention period is over, your personal information will be securely deleted or anonymised.

11. Your Rights

Under current data protection laws, you have a number of important rights concerning your personal information:

Right of Access: You have the right to request access to the personal information we hold about you.
Right to Rectification: You have the right to ask us to correct any inaccurate or incomplete information we hold about you.
Right to Erasure (Right to be Forgotten): You have the right to request that your personal information is deleted in certain circumstances (for example, if the data is no longer necessary for the purposes for which it was collected).
Right to Restriction of Processing: You have the right to ask us to restrict the processing of your personal information in specific circumstances (e.g., if you’re disputing the accuracy of the data).
Right to Data Portability: You have the right to receive your personal information in a structured, commonly used, and machine-readable format, and to transmit that data to another controller, where technically feasible.
Right to Object: You have the right to object to the processing of your personal information in certain situations, particularly where we’re relying on legitimate interests as the legal basis for processing.
Right to Withdraw Consent: Where our processing of your personal information relies on your consent, you have the right to withdraw that consent at any time. Withdrawing your consent won’t affect the lawfulness of any processing based on consent before its withdrawal.
Right to Lodge a Complaint: You have the right to lodge a complaint with a supervisory authority if you believe your data protection rights have been infringed. In¹⁰ the UK, this is the Information Commissioner’s Office (ICO) (www.ico.org.uk). In the EU, you can contact your local data protection authority.

To exercise any of these rights, please don’t hesitate to get in touch using the details provided in Section 13.

12. Changes to this Data Privacy Policy

We may update this Data Privacy Policy from time to time to reflect any changes in our practices or new legal requirements. We’ll always let you know about any significant changes by posting the updated policy on our website and, where appropriate, through other means (like an email notification). We encourage you to review this policy periodically to stay informed about how we’re protecting your information.

13. Contact Us

If you have any questions about this Data Privacy Policy, our data practices, or if you’d like to exercise any of your rights, please contact us:

Email: info@kineorecruitment.com