Nash Squared, including all Nash Squared subsidiary companies together, (which includes Harvey Nash, Spinks (We Are Spinks), NashTech, PAT Management, Talent-IT, Team4Talent, Talent2Test, Pro-Cured, eMenKa NV), referred to here as ‘Nash Squared’ is a leading global recruitment consultancy and outsourcing company working on an annual basis with thousands of candidates and clients worldwide.
This website offers you a platform to upload your CV and other personal data to improve your user experience, and to use functions such as job alerts, CV registration and job applications. You are responsible for the accuracy of the personal data inputted. If you use functions on the website which access data from external sources, such as LinkedIn, please be aware that the website will access your personal data from these sources.
Our reputation as a recruiter is reliant on the trust of people we work with, and consequently the effective and professional use of the information you provide us is paramount.
Your privacy is important to us, and we are committed to protecting and safeguarding your data privacy rights.
This privacy notice explains what we do with your personal data, whether as part of helping you find a job, developing your career, providing you with a service that may be of interest, or simply as a result of you visiting our website.
We respect your right to privacy.
Our overall aim is to ensure that our collection and use of personal information is appropriate to the provision of services to you and is in accordance with applicable data protection laws.
Important definitions in this policy
What does Nash Squared do?
Where does Nash Squared collect data from?
What information do we collect on Candidates?
What information do we collect on Client contacts?
What is our lawful basis for processing your personal data?
How do we share your personal information and who do we share it with?
Personal information, cookies and websites
How we safeguard your personal data
Your rights, complaints, questions and suggestions
Profiling, Anonymous data & Third party sites
"You" are a candidate, potential candidate, consultant, client contact or contact at any other organisation involved in the introduction and/or supply of a candidate's services, such as a contact at a recruitment process outsourcing company, personal service company or umbrella company.
References in this notice to:
Specifically, this privacy notice provides you with details about the personal information we collect and hold about you, how we use your personal information and your rights regarding your personal information.
It does not cover any use of your personal information by:
The core of what we do is twofold.
Firstly, it is to provide services to help candidates develop their careers. We do this through assessing and matching people with potential job opportunities, as well as providing wider services to help them in their careers, such as invitations to networking events and opportunities to take part in research.
Secondly, we work with clients to provide recruitment, consultancy and outsourcing services to help them solve recruitment, talent, technology and other related challenges.
This privacy notice applies to the collection, storage and use of personal information collected by Nash Squared ("we" or "us"):
Candidates: the personal information we collect about you where "you" are a candidate or placed consultant.
Harvey Nash aims to collect the minimum data it needs to perform its role.
Typically, this is name, address, job title and contact details. In addition, if you are a candidate being considered for a role it may also include your CV / resume as well as other details about your skills and experience.
We may also collect other personally identifiable data, for instance we may be engaged in equal opportunity monitoring or need information to complete a contract for you or our client.
This data can include age, identity card number, passport number, driver license number, address, email address, user ID and passwords, gender, date of birth, marital status, occupation, income range, bank account details, financial information, contact information such as telephone, mobile, nationality, personal website or social media links or other data which may be required by local regulations.
Referees and emergency contacts: we collect basic contact details (such as name, title, address, email and tel) so that we can contact you for a reference or as an emergency contact for one of our candidates/or contractors.
Client contacts: the personal information we collect about you where "you" are a contact at one of our clients or at an MSP, umbrella company or personal service company involved in the supply of a person's services to a hirer.
We need to collect information about you as an essential part of providing our Services.
We may collect personal information about you when:
We use the data we gather to perform a number of tasks, including:
- placement of a candidate into a particular employment role as defined by our clients;
or the provision of resourcing, outsourcing or consultancy maintaining our records of our candidates, clients and contacts;
- conducting marketing, profiling and business development activities as well as market research and statistical analysis regarding our products and/or services;
- complying with any legal or regulatory requirements and to make the necessary disclosure under the requirements of any applicable law, regulation, direction, court order, guideline, circular or code which are applicable to us for the prevention of crime.
Reporting requirements to clients where we offer Managed Services (RPO / MSP)
Client contacts: We use the information collected from clients to ensure that we provide business services to you. This will involve identifying candidates that will meet your requirements or providing other business services from our portfolio.
Suppliers: we use the data collected to ensure the business arrangements between us run smoothly.
Referees and emergency contacts: we use the data collected to contact you for a reference or to contact you as a candidate's emergency contact in the event of an accident or other emergency.
We consider that it is necessary for our legitimate interests as a recruitment business to process your personal data.
At different stages in the recruitment processes we also have other lawful grounds for processing your data such as compliance with our legal obligations and where it is necessary for the performance of contracts related to the recruitment process.
We think you will have an expectation that if you are looking for employment or have posted your CV or other professional information on a job board or professional networking site, that you are happy for us to collect and use your personal data to provide our recruitment services to you and to share that information with prospective employers.
During the recruitment process the client may want additional information (such as the results from psychometric evaluations or skills tests) or to confirm your references, qualifications and criminal record, where appropriate and in accordance with local laws.
We may also need to use your personal information for internal administrative purposes, such as contract administration, payroll and invoicing.
We also have our own obligations under law, and we may be required to share your data in connection with those legal requirements. Where we are required by law to obtain your consent to the processing of your personal data, we will obtain it.
Client contacts and other third parties involved in the supply of resourcing services (e.g. umbrella companies and personal service companies)
We collect, store and use your name and contact details for our legitimate interests, so that we can: send you the details of candidates and consultants and contact you about our Services; and maintain our business relationship with you.
This allows you to be contacted to receive and administer any Services which you or your organisation has requested.
The exchange of personal data of our candidates and client contacts is an essential part of what we do as a recruitment business and, as such, it is in our legitimate interests to process your data for such purpose.
In the case of contacts at umbrella companies and personal service companies this allows you to be contacted to receive, on behalf of your employer, details of current and future assignments, related timesheet data and payment details. We do not believe that this storage and use of your personal information will unduly prejudice your rights or freedoms.
All users of the Site and our Services
We collect, store and use your personal information for the following purposes:to make the Site available to you; and to provide any Services that you request.
Sometimes, our use of your personal information is for purposes which are ancillary to the provision of the Site and then Services, or which are desirable to make them to operate more effectively.
In those circumstances, we believe we have a legitimate interest in handling your personal information, and do not believe that this storage and use of your personal information will unduly prejudice your rights or freedoms.
Your personal data provided to us is processed by Nash Squared.
We will ensure that:
- access to your personal data is restricted to staff who are required to process such data as part of their job;
- only necessary information is released to the relevant employees;
- we seek your consent before sharing your details with any prospective employer or user of your services.
Referees: unless you specify otherwise, we may share your information with any of our group companies and client(s) in relation to whose vacancy your reference was given.
We will disclose information under the following circumstances:
Service and Site usage information: When we share anonymous information generated by our Services with our clients.
Third-party service providers: When we share information with third-party service companies for them to facilitate and support us in the provision of the Services.
- IT support service providers;
- providers of credit reference, vetting and screening services;
- payment processors and software providers;
These organisations are appointed by Nash Squared as data processors and authorised to use your personal information only as necessary to provide the relevant services to us. These organisations are required to process such information based on our instructions and in accordance with this privacy notice. They do not have any independent right to share this information.
Group companies: We provide your personal information to our subsidiaries or affiliated companies for the purpose of processing personal information on our behalf to provide the Site and the Services. These parties are required to process such information based on our instructions and in accordance with this privacy notice. They do not have any independent right to share this information.
Merger or acquisition: When we need to transfer information about you if we are acquired by or merged with another company. If we are involved in a merger, acquisition, or sale of all or a portion of its assets, you will be notified by email and/or a prominent notice on our Site of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information.
Recruitment and resourcing services: When we are using your personal information in the context of our recruitment and resourcing services, then we may share your personal information with clients where we believe that you may be appropriate for a particular role or vacancy with that client.
Umbrella companies and personal service companies: When you inform us that you are supplying or intend to supply your services via Nash Squared to a client through an umbrella company or personal service company.
Recruitment Process Outsourcing and Managed Service Providers: In certain cases, there may be an organisation such as a managed service provider acting as a gateway for the supply of Services made via Nash Squared to the hirer.
Where this is the case, we will share your information with such organisations to the extent that it is necessary for the purposes of the supply.
Where personal information is shared with clients, hirers, umbrella companies, personal services companies or managed service providers in the circumstances described above, then those organisations will handle your personal information in line with their own privacy policies.
We want to make sure that your data is stored and transferred in a way which is secure. We will only transfer data outside of the UK or European Economic Area where the recipient is compliant with the data protection legislation and the means of transfer provides appropriate safeguards.
These will include UK or EU approved standard contractual clauses according to Article 46(2)(c) GDPR, or where the country concerned has been found adequate by the UK Secretary of State or European Commission (as applicable) in respect to the levels of data protection, according to Article 45 GDPR.
Please note that where a derogation to the above applies under Article 49 GDPR, you will be informed of this prior to the transfer taking place and will have the opportunity to object to that transfer.
Nash Squared is a global company and to effectively provide the best service to our clients we may utilise a business processing outsourcing (BPO) service in both India and Vietnam to help identify candidates for potential roles.
This service helps us to respond more quickly to client services by identifying potential candidates and sending this information back to the responsible consultant. The BPO service we use is provided by Harvey Nash India and Harvey Nash Vietnam, both of which are subsidiaries of the Nash Squared.
A data transfer risk assessment has been carried out, and both data processing agreements and standard contractual clauses are in place to govern the secure processing of UK and EU personal data in these instances.
We may send your information between Nash Squared entities which may exist outside of Europe, to overseas clients or to clients within your country who may in turn transfer your data internationally. Appropriate safeguards and legal requirements will always be in place to govern the secure processing of your personal data.
The data may also be stored on cloud-based storage for parts of our overall business process. Please be aware that countries which are outside the European Economic Area may not offer the same level of legal protection for your personal information as under EU/UK law, although any collection, storage and use
Our website may offer you the opportunity to pass your personal information to us in relation to a particular role which is of interest to you. This information may be routed through one of our 3rd party suppliers before it is delivered electronically to us.
All our 3rd party suppliers have been vetted to ensure that they will meet our own privacy and security standards in the collection and processing of your personal information.
Our website may also link or direct you to other websites or external content which are not within our control. Links to other websites may be provided for your convenience and information.
While we will use our best endeavour to ensure that we link or direct you only to websites that share our privacy and security standards, we are not in the position to guarantee the same and we will not be responsible for the protection and privacy of any personal data which you provide on those websites.
Technologies such as cookies, beacons, tags and scripts are used by us and our affiliates, or analytics or service providers.
These technologies are used in analysing trends, administering the Site, tracking users’ movements around the Site and to gather demographic information about our user base as a whole. We may receive reports based on the use of these technologies by these companies on an individual as well as aggregated basis.
Nash Squared is passionate about protecting your information. To this end we have put in place appropriate measures that are designed to prevent unauthorised access to and misuse of your personal data.
These include measures to deal with any suspected data breach. If you suspect any misuse or loss of or unauthorised access to your personal information, please let us know immediately by emailing DPO@harveynash.com.
Your information is held on servers hosted by us or our Internet Services Provider. The transmission of information via the internet is not completely secure.
Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk.
The period for which data is retained in each circumstance is determined by the balanced interests of the company and the data subjects concerned. If personal data needs to be retained to fulfil the documented business interests of the company, and that interest would align with the interests of the data subject, then we will continue to retain for a reasonable period.
However, we do not keep data for any longer than is necessary. For most people where we have limited contact it will be for a maximum of two years from the date of last contact with us. Where we have engaged with you more extensively, for instance we have worked with you as client, or interviewed / placed you as a candidate, we may retain data longer.
We will delete personal data at the end of the legal retention period except where we need to keep any personal information to comply with our contractual (i.e. reporting requirements) or other legal obligations, resolve disputes, or enforce our agreements.
We have legal obligations to retain emails as we operate across a number of jurisdictions including the United States.
We use a Mimecast archiving system to archive emails 13 months from the date sent or received, for up to 10 years.
Psychometric Testing Candidates
If you have signed up to carry out a test as part of a recruitment process, our staff may provide you with additional information where we have clients who require the retention of personal data for longer periods for management intelligence purposes. This period can be up to 15 years, depending on the specific contractual obligations we have. We will ask for your consent to retain this information and you will have the opportunity to withdraw that consent easily at any time. This will be explained in detail to you at the point the data is first obtained.
For more information on our data retention policy please contact DPO@harveynash.com.
You have certain rights in relation to your personal information. If you would like further information in relation to these or would like to exercise any of them, please contact us via email at DPO@harveynash.com at any time.
See Appendix 5 for further information.
Nash Squared tries to meet the highest standards when collecting and using personal information. We take any complaints we receive about this very seriously. We encourage people to bring it to our attention if they think that our collection or use of information is unfair, misleading or inappropriate. If you wish to complain about our policies or procedures, please contact our Data Protection Officer via DPO@harveynash.com.
You can also seek a remedy through local courts if you believe your rights have been affected.
EU Supervisory Authorities
You may make a complaint to any supervisory authority for data protection matters in the EU. Nash Squared is registered as a data controller with the Information Commissioner's Office in the UK, but also operates across the EU where other supervisory authorities operate.In preparation for the UK exiting the EU, we have designated a legal entity as a representative for data protection matters in the EU. This entity is Harvey Nash BV, (Netherlands).
To contact this entity about your rights or any concerns you have about processing being carried out in the EU, please email EU-DPO@harveynash.com.
Where we have previously engaged with you (for example where you have submitted an application or CV to us) or where you have posted your details on a job board, we may have obtained your email address and retained it according to our legitimate business interests as explained above.
Having obtained your email address during an aforementioned recent course of business, we may periodically send you related information that we think you will find interesting or to ask for your expertise in completing a survey.
We may also send you relevant information to market our full range of services, or send you details of networking and client events and information about the industry sectors we think may be of interest to you.
If you do not wish to receive these communications you can unsubscribe by clicking on the relevant link on marketing emails, or contact firstname.lastname@example.org requesting to be opted-out of receiving marketing communications.
Not withstanding the above, your rights as a data subject under the GDPR provide that you can ask for all your personal data to be removed (as explained above) at any time.
Nash Squared does not utilise any form of automated profiling currently. All our recruitment activities involve human decision-making during the process. This may change in the future if we implement automated technologies or machine learning, but we will only do so where appropriate and in accordance with local laws and regulations. Any changes to this notice will be notified as set out below.
Nash Squared utilises psychometric testing providers to conduct tests for our clients. Candidates sign into the testing provider and carry out this test. Specialists within Nash Squared will review the results of the tests and conduct what may be described in the GDPR as profiling on the personal data. You have the right to object to profiling and can do this by refusing or withdrawing your consent to processing in the testing process at any time.
We collect anonymised details about visitors to our website for the purposes of aggregate statistics or reporting purposes. However, no single individual will be identifiable from the anonymised details we collect for these purposes.
Third party sites:
Changes to this Privacy Notice
This privacy notice was updated in January 2020.
We will publish changes to this privacy notice from time to time. If significant changes are made to our processing activities, we will take reasonable measures to notify data subjects accordingly.
We may collect personal data when:
- you access and browse the Site (including when you submit personal information to us through data entry fields on the Site);
- or you respond to an advert posted by us whether via a job board, LinkedIn or other social networking site;
- or we download details uploaded by you onto a job board, LinkedIn or other social networking site in relation to a vacancy we are seeking to fill for one of our clients;
- or we download details uploaded by you onto a job board, LinkedIn or other social networking site in connection with our internal market research;
- or you contact us by phone, email or otherwise;
- or we provide Services to you or to an actual or a potential hirer of your services;
- or we contact you with a view to providing Services to you;
- or we provide on-boarding services to a hirer of your services, we may collect the following information from or about you: your name; your postal address; your phone and e-mail details; your bank details a copy of your passport details including your passport photograph; your current and previous employment/work details, including job title and employer; recruitment-specific details such as any professional certifications, education and qualifications, skills, career history, salary range, right to work status, citizenship, referee details and any other information relevant or required by law to enable us to provide the Services;
- any other information which you include in your CV or a completed application form;
- any information which has been published or made available on a social media profile or job board (whether by you or a third party), or in any news media;
- details of your umbrella company or personal service company;
- the contract for services we hold with your umbrella company or personal service company relating to the work you do or will do for our client, including timesheet data and charge rates relating to the work you perform under that contract;
- details of your referees and emergency contacts references from third parties such as previous employers and nominated referees;
- the results of pre-employment screening or vetting checks which we are asked or required to undertake in relation to you (including the results of any Disclosure and Barring checks and any information you provide relating to current and/or spent criminal convictions carried out on behalf of the hirer during the on boarding process);
- any e mail communications, including attachments, which you send to us the results of right to work checks.
You can update your CV or personal data at any time by forwarding a copy to email@example.com
We collect, store and use information that we obtain in relation to you for our legitimate interests:
- so that we can contact you (via email, SMS or phone) about opportunities and assignments that we believe you may be interested in;
- to help us to provide suitable candidates and consultants for our clients who engage us to assist them fulfil their recruitment and resourcing requirements;
- to provide a channel through which you may submit your CV for general applications, to apply for specific jobs or to subscribe to our job alerts;
- to match your details with vacancies, to assist us in finding a position that is most suitable for you and to send your information to clients for potential jobs.
Please note that we will always obtain verbal or written consent before presenting your personal details to a client.
- to enter into contracts which are necessary for your service to be supplied or made available to a hirer;
- to provide recruitment-related support; to carry out market research for our internal use;
- to develop an industry-relevant database of candidates and clients to help meet our clients' resourcing requirements and connect candidates with work opportunities; for internal record keeping purposes;
- to carry out services that we, you or our client have requested including work-related references, qualifications and criminal references checking services, verification of the details you have provided from third party sources, psychometric evaluations or skills tests.
This storage and use of your personal information allows you to be contacted about roles which may be of interest to you, now or in the future, and we do not believe that this storage and use will unduly prejudice your rights or freedoms.
We will store and use your personal information in order to comply with relevant legal obligations to which Nash Squared is subject, including carrying out:
- verification of your identity to comply with The Conduct of Employment Agencies and Employment Businesses Regulations 2003;
- right to work checks to comply with relevant immigration legislation;In other, relatively limited circumstances, we will carry out further relevant background checks as may be requested by our client.
Where you are successful in securing temporary assignment work with one of our clients we will store and use your personal information for the purposes of completing and administering contracts with your chosen personal service company or umbrella company and for processing payment to such company in respect of services you have performed for our client.
Such processing will be for our legitimate interests so that we can provide Services to you and our client.
We do not believe that this storage and use of your personal information will unduly prejudice your rights or freedoms. Such processing will also be necessary for the performance of a contract to which you are party (i.e. your contract with the umbrella company or your personal service company relating to the supply of assignment services) and/or in order to take steps prior to you entering into such contract.
If our client requires us to collect, store and use your health data and/or any Disclosure and Barring Checks we will, on our client's behalf, seek your consent to processing such data.
You can withdraw your consent at any stage, but this may prevent us from being able to deliver our recruitment services to you.
The relevant circumstances are:
- detecting and preventing fraud;
- keeping our Site, apps, products and IT systems secure;
- ensuring that our own processes, procedures and systems are as efficient as possible; analysing and enhancing the information that we collect;
- determining the effectiveness of our promotional campaigns and advertising; and contacting you with products and services which we think may interest you.
In some, relatively limited, circumstances we need to handle your personal information in a certain way to be able to comply with our legal obligations.
For example, if we:
- are requested to disclose your personal information to regulatory bodies;
- need to demonstrate our compliance with applicable law;
- are subject to any enquiry from the Employment Agencies Standards Inspectorate or HMRC.
Cookies (small text files that store information on your hard drive) may be used in the processing of your personal data.
A copy of this text file is sent to your computer and/or device whenever it communicates with our server. Cookies help us to understand which sections of our websites are frequently visited. With this information we can adapt our website to suit your demands and provide you with a more customised and personalised user experience.
We may collect the following information during your visit to our website and/or the fully qualified domain name from which you accessed our site, or alternatively, your IP address: the date and time you access each page of our website the URL of any web page from which you accessed our site (the referrer) the web browser that you are using and the pages you accessed.
Some webpages may require you to provide a limited amount of personal information in order to enjoy certain services on a website (system login credentials, email addresses and contact information). This personal information will only be used for its intended purpose, i.e. to respond to your message or deliver the requested services.
You may configure your browser to accept all cookies, reject all cookies, or notify you when a cookie is sent.
You have the right to request that we:
- provide access to any personal information we hold about you;
- update any of your personal information which is out of date or incorrect; delete any personal information which we are holding about you;
- restrict the way that we process your personal information;
- prevent the processing of your personal information for direct-marketing purposes;
- provide your personal information to a third-party provider of services;
- provide you with a copy of any personal information which we hold about you;
- or consider any valid objections which you have to our use of your personal information: and/or Do not conduct profiling on your personal data, if you have consented to undergoing testing with our third-party providers, by refusing or withdrawing your consent at any time.
We will consider all such requests and provide our response within a reasonable period (and in any event within any time period required by applicable law).
Please note, however, that certain personal information may be exempt from such requests in certain circumstances.
If an exception applies, we will tell you this when responding to your request. We may request you provide us with information necessary to confirm your identity before responding to any request you make. If you have made a request for erasure of your personal data records, we will usually retain a copy of your given email address on a ‘do not contact’ list to comply with our obligations under the GDPR.
For more information, please contact the Data Protection Officer.
You may request to unsubscribe from job alerts and marketing material at any time. If you wish to contact us with respect to the above matters, please email us at DPO@harveynash.com.