Privacy Policy (Data Controller)

Purpose of this privacy policy

This privacy policy aims to give you information on how we collect and process your personal data, however you provide it to us, and applies to:

• Students (i.e. someone who uses the platform in order to enhance their employability and facilitate employment opportunities).
• Employers (i.e. an employer or a staff member of an employer who provides his/her personal data in respect of a Student’s proposed event or placement). 
• Account Holders (i.e. staff at educational institutions that use the platform in an administrative capacity). 
• Parents (i.e. a Student’s parent or guardian who provides their personal data in respect of his/her child’s proposed event or placement). 
• Visitors (i.e. someone who visits the website but does not access the platform). 

It is important that you read this privacy policy together with any other privacy policy or fair processing notices we may provide so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.

Controller

We are the “data controller”, meaning that we are responsible for deciding how your personal data is used and more importantly, for keeping your data safe and only using it for legitimate reasons.

Contact details

If you have any questions about this privacy policy or our privacy practices, please email us at privacy@shortlist.me, telephone us on +44 (0)1904 279 400, or use the contact form on our website. 

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Changes to the privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review. If we amend our privacy policy it will be published on www.shortlist.me so please check back regularly to see if there have been any updates. If we make any substantial changes, we may also email you if it’s appropriate.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

• Identity Data includes first name and last name.  
• Contact Data includes email addresses and telephone numbers.
• Profile Data includes your username and password. 
• Marketing and Communications Data includes your preferences in receiving marketing from us and your communication preferences. 
• Video Data includes video recordings that you send to us. 

We may collect the following types of information from you when you use our website (using cookies or other tracking technology):

• Usage Data includes information about how you use our website and services.
• Technical Data includes internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data) unless you provide your explicit consent for us to do so. Nor do we collect any information about criminal convictions and offences.

Aggregated Data 

We also collect, use and share Aggregated Data such as statistical or demographic data. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

We use different methods to collect data from and about you including through:

• Provided by your educational institution. If you are a Student, we will have entered into an agreement with your educational institution for the use of the platform and they may provide us with your Identity and Contact Data. If you are a Parent, your child’s educational institution may provide us with your Identity and Contact Data. 
• Direct interactions. Students may give us their Identity, Contact, Profile and Video Data, as well as their Parents’ Identity and Contact Data by corresponding with us via our website, in particular when signing up for the platform. Employers may give us their Identity and Contact Details when advertising an event or placement via our platform.    
• Automated technologies or interactions. As you interact with our website, we may automatically collect Technical and Usage Data about your equipment and use. We collect this personal data by using cookies, and other similar technologies.

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where you have given your consent to the use of your personal data for one or more specific circumstances. 
• Where we need to comply with a legal obligation.

Please see the Glossary at clause 10 below to find out more about the types of lawful basis that we will rely on to process your personal data.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Marketing 

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

Opting out

You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time. 

Where you opt out of receiving these marketing messages, this will not apply to personal data that we process and use on a different lawful basis, or in respect of which you continue to consent to us processing.

Our Website – Cookies 

We use cookies on our website, which may collect personal data. We may publish a separate Cookie Policy on our website to provide more information about the cookies we use.

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.

Our Website – Third-party links

Our website includes links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

We may share your personal data with the parties set out below for the purposes set out in the table above.

• Service providers (acting as processors) such as hosting providers and other IT services, including in respect of the facilitation and storage of video interviews. 
• Regulators and authorities (acting as controllers) who may require reporting of processing activities in certain circumstances.
• Third parties to whom we may choose to sell, transfer or merge parts of our organisation or our assets. Alternatively, we may seek to merge with other organisations. If a change happens to our organisation, then the new owners may use your personal data in the same way as set out in this privacy policy.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes where they act for us as processors of data, and only permit them to process your personal data for specified purposes and in accordance with our instructions. 

We may transfer Personal Data from the UK to other countries  only pursuant to a specific legal basis. Any such data transfer is usually based on one of the legal bases described below, however you can inquire with us to learn more and in particular which legal basis applies to which specific service, through the contact details provided in this policy.

Data transfer based on standard contractual clauses

If this is the legal basis, the transfer of personal data from the UK to other countries is carried out according to standard contractual clauses made or approved under the Data Protection Act 2018. This means that data recipients have committed to process personal data in compliance with the data protection standards set by UK data protection legislation.

Data transfer to countries that guarantee appropriate data protection standards 

If this is the legal basis, the transfer of personal data is carried out according to adequacy regulations made under the Data Protection Act 2018. These adequacy regulations are issued in respect of specific countries that provide personal data protection standards comparable to those in UK data protection legislation.

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

How long will you use my personal data for?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

If you are a Student or a Parent and we have not had meaningful contact with you for a period of two years, we will delete your personal data from our systems unless we believe in good faith that the law or other regulation requires us to preserve it (for example, because of our obligations to tax authorities or in connection with any anticipated litigation).

By law we have to keep basic information about our customers for six years after they cease being customers for tax purposes. 

In some circumstances you can ask us to delete your data: see clause 10 below for further information.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

Under certain circumstances, you have rights under data protection laws in relation to your personal data and you are entitled to:  

• Access a copy of your personal data.
• Correct or update your personal data.
• Erase your personal data.
• Object to the processing of your personal data where we are relying on a legitimate interest (as set out in the above table).
• Restrict the processing of your personal data.
• Request the transfer of your personal data to a third party. 
• Where you have provided your consent to certain of our processing activities, in certain circumstances, you may withdraw your consent at any time (but please note that we may continue to process such personal data if we have legitimate legal grounds for doing so).

If you want to exercise any of these rights, please contact us. 

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

LAWFUL BASIS

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

YOUR LEGAL RIGHTS

You have the right to:

• Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
• Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
• Request deletion of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request to delete your personal data for specific legal reasons which we will tell you at the time of your request.
• Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
• Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
  • If you want us to establish the data’s accuracy.
  • Where our use of the data is unlawful but you do not want us to erase it.
  • Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
  • You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
• Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use. 
• Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain services to you. We will advise you if this is the case at the time you withdraw your consent.