Privacy Policy

This Data Processing Notice applies to you if (1) you are looking for a job (permanent or contractor role) and (2) if you reside within the European Union.

It is meant to help you understand what personal data we collect, why we collect it and what we do with it. Furthermore, it will briefly outline your rights. This is important, and we hope you will take the time to read it carefully.

We have issued this Data Processing Notice in accordance with the General Data Protection Regulation (EU) 2016/679 (‘GDPR’) and any associated legislation e.g. the Data Protection, Privacy and Electronic Communications (Amendments etc) (EU Exit) Regulations 2019 and the 2018 UK Data Protection Act. In this Data Processing Notice, any references to GDPR also relate to associated legislation.

This Data Processing Notice will outline:

1. What do we do with your personal data?
2. What personal data do we collect?
3. How do we collect your personal data?
4. Why do we process your personal data?
5. Will I be receiving marketing emails, and can I opt out of this?
6. Will your personal data go outside the EEA?
7. How long will we store your personal data for?
8. What are your rights?
9. Will my personal data be used to make automated decisions?
10. How can I lodge a complaint?
11. Changes to this Data Processing Notice
12. Contact details of the Data Protection Officer

If you are hired by our client as a contractor, please also read the Data Processing Notice for Contractors.

1. What do we do with your personal data?

We have offices worldwide and all our entities are connected to Jobscience, our internal CRM system. All our entities act as data controller as they determine the purpose and means by which personal data is processed.

Our legal entities are listed below:

Your personal data will be stored on Jobscience and can be accessed by all our recruitment consultants. All the Salt offices (including our offices overseas), are obliged to comply with GDPR when processing your personal data, provided that you reside in the European Union.

Your personal data may also be shared with our client(s) for the purpose of introducing you and arranging interviews with them. We will always ask you for permission before introducing you to our client and we will be transparent on the exact details that will be forwarded.

Furthermore, we may disclose your personal information to third parties in the event that we sell or buy any business or assets, in which case we will have to disclose your personal data to the prospective seller or buyer of such business or assets.

We may also be under a duty to disclose or share your personal data in order to comply with any legal obligation, to defend our business against a legal claim, to enforce or apply our standard terms of business or other agreements or to protect the rights, property or safety of Salt, our customers or other parties.

2. What personal data do we collect?

We collect the following personal data:

⦁ Your full name
⦁ Your registered address
⦁ Your date of birth
⦁ Your email addresses
⦁ Your (mobile) telephone number
⦁ Your website
⦁ Professional profiles available in the public domain, e.g. LinkedIn, Twitter or Facebook
⦁ Your CV
⦁ Skillset (if not already covered in your CV)
⦁ Job preferences (if not already covered in your CV)
⦁ Current employer/client
⦁ Your right to work, when requested by our client
⦁ Current salary/employment conditions
⦁ Desired salary/employment conditions
⦁ Other documentation, if requested by our clients (e.g. references)

If you are contacted by our Dubai office for relevant opportunities in Dubai, for statutory reasons, you will be asked to provide us with the following personal data:

⦁ Gender
⦁ Marital status
⦁ Children

3. How do we collect your personal data?

We collect your personal data in the following ways:

1. You apply for a job in response to a job ad on welovesalt.com
2. You upload your CV on welovesalt.com
3. You complete a ‘Contact us’ form or register with us on our website
4. Our recruitment consultants get in contact with you because they located your profile on a database/ job board you have subscribed to or registered your CV with
5. We have received your details from another third party. For example, a business contact, a client or professional advisors.
6. You applied for a job ad posted by Salt on an external job board, e.g. Monster, Jobsite or LinkedIn.
7. You have spoken with a recruitment consultant and you have provided us with your CV/application.

When we receive your details, we save your application and information on our CRM system. You will receive a notification when this happens, and our recruitment consultant can confirm how they found your profile or CV. If this information is not provided, please let us know and we will clarify how we located your details.

4. Why do we process your personal data?

We collect your information to carry out our core business activities. We are a recruitment business and want to help you in finding the right job that matches your skillset.

More specifically, we process your personal data for the following purposes:

⦁ Introducing you to (potential) clients;
⦁ Keeping your personal data on file for current and future opportunities that may arise;
⦁ Evaluating your experience with Salt and our recruitment process;
⦁ Verifying your identity and/ or the right to work.

The following legal basis for processing your personal data applies if we have been in touch with you in the last three years:
We will process your data as we are of the view that we have legitimate interests to do so.

We have carried out a three-part test (a so-called legitimate interest’s assessment). We have outlined a summary of this test below. More information about this test can be requested from GDPR@welovesalt.com.

As a recruitment business, we introduce candidates to clients for permanent employment and temporary worker placements (if you work as a contractor through Salt). We need to satisfy our client’s resourcing needs and therefore require an up-to-date database of candidate data. We will only use your personal data to introduce you to our client and do not share more data with our client than reasonably necessary. We usually process data that is already available online (e.g. a CV downloaded from a job board) and ask for additional information that is relevant to your application. Thus, to maintain, expand and develop our business we need to record the personal data of candidates who have been in touch with Salt over the last three years. We have chosen this three-year period for the following reasons:

(1) It is likely that there is a(n) ongoing relationship between you and Salt
(2) You may still be looking for opportunities
(3) The quality of your data still enables us to match your profile with a new career opportunity
(4) We are of the view that this timeframe reflects industry standards

The following legal basis applies for processing your data if you are employed by one of our clients:
If you have been successfully hired by one of our clients as an employee or contractor, we have a legal obligation to keep some of your data on file. We may have to evidence any transactions to auditors or the authorities. We may also have to keep your personal data to defend ourselves against legal claims.

5. Will I be receiving marketing emails, and can I opt-out of this?

We may process your personal data for marketing purposes. This is optional, not compulsory.

The legal basis for collecting and processing personal data for marketing purposes is ‘consent’ which means that we will only send you marketing communication if you ticked a box indicating that you are happy for us to send you marketing updates.

If you have opted in to marketing updates, we may use your data to personalise your experience and provide you with relevant service announcements and updates. We will moreover be able to match your profile with relevant job opportunities. Our marketing team will analyse your profile and provide you with additional information which helps you to better position yourself in the job market, i.e. with invitations to networking events in your city, news and updates relevant for your area of expertise, or job alerts tailored to your preferences.

You are entitled to withdraw consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal. To opt-out of any data processing and/ or marketing communications from Salt, please click the ‘unsubscribe’ link in the footer of the respective email or use the Preference Centre to update your settings.

6. Will your personal data go outside the EEA?

Your personal information will be stored and processed in any country where we have offices and therefore your personal data will be processed outside the EEA. All Salt entities, however, operate under Standard Contractual Clauses providing protection and safeguards for cross-border transfers outside the EU. We take all steps reasonably necessary to ensure that your data is treated securely and in accordance with relevant data privacy laws. You can request a copy of these Standard Contractual Clauses by emailing GDPR@welovesalt.com.

We have also entered into valid data processing agreements with third parties if we store your data on systems that are managed by these third parties.

We may also transfer your personal data to our clients and this data may be transferred outside the EEA if our client is based outside the EEA. We take all steps reasonably necessary to ensure that your data is treated securely and in accordance with data privacy laws. However, please note that if the client uses your personal data, they are also responsible for processing it safely and legitimately.

7. How long will we store your data for?

Your personal data will be stored in our system for three consecutive years. As long as you are working with our recruitment consultants on your next career step, we will keep your data on file so we are able to match your profile with new opportunities.

Your data will be removed from our systems if

a) we have not heard from you during this three- year period, or
b) you want your data to be removed
Different retention periods apply if:
a) you work as a contractor through Salt (see Data Processing Notice for Contractors) or
b) there is a direct statutory requirement (that comes into force) under which we are obligated to keep your data stored in our internal databases for a longer period of time.

This applies for example if you are hired by one of our clients, in which case we need to keep records of the relevant transaction. The current limitation period is six years from the date of the transaction (this may be changed from time to time).
Also, under the Conduct of Employment Agencies and Employment Businesses Regulations 2003, we must retain evidence of an introduction or supply for at least one year from the last activity e.g. interview, introduction or engagement.

8. What are your rights?

You are entitled to various rights:

• You can request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected. This means when working with our recruitment consultants, ensure that you notify us of any changes or update your information like email, phone number etc. when they change.

• You can request the erasure of your personal information. This enables you to ask us to delete or remove personal information 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 information where you have exercised your right to object to processing (see below).

• You can object to the processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes. This means we will only send you marketing communication if you have opted in. You can opt-out at any time by clicking the ‘unsubscribe’ link in the footer of the email in question so you will be removed from the Salt marketing mailing list. You can also use the Salt Preference Centre to opt-in and out of other communication from Salt.

• You can request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example, if you want us to establish its accuracy or the reason for processing it.

• You can request the transfer of your personal information to another party in certain formats, if practicable.

The fact that you lodge a request does not necessarily mean that we will grant your request in every instance especially if Salt has a legitimate interest in keeping your data. We will always give reasons if we decline your request.

We will, however, provide information without undue delay and in any event within one month (this can be extended to 2 months in exceptional circumstances) of the receipt of the request. However, where requests are manifestly unfounded or excessive in particular because of its repetitive character, we may refuse to act upon your request. If this happens then we will inform you within one month of the request about the possibility of lodging a complaint with a supervisory authority (in the UK this will be the ICO) or seeking a judicial remedy.

9. Will my personal data be used to make automated decisions?

We will not conduct any forms of automated processing of your personal data consisting of the use of personal data to evaluate certain personal aspects relating to you. We will not analyse or predict aspects concerning your performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements. Furthermore, we will not make decisions that are based solely on automated processing which produces legal effects or similarly significantly affects your rights.

10. How can I lodge a complaint?

If you feel that your rights have been violated, you are entitled to lodge a complaint with the supervisory authority of your country of residence. If you are based in the UK you can contact the Information Commissioner’s Office. Alternatively, you can seek a legal remedy. However, before escalating the case to the competent authorities, we strongly encourage you to contact us by emailing GDPR@welovesalt.com. We will then review your complaint at our earliest convenience.

11. Changes to this Data Processing Notice

Any changes we make to our Data Processing Notice in the future will be posted on this website and where appropriate (if we make any significant changes that may affect your rights as a data subject), notified to you by email. Please check back frequently to see any updates or changes to this Data Processing Notice.

12. Contact details of the Data Protection Officer

If you have any questions, comments or requests regarding your personal data or this Data Processing Notice, please address them to our Compliance team via GDPR@welovesalt.com.

Last updated on 13 March 2020

The Salt Group is committed to protecting and respecting your privacy. The Salt Group entails our ultimate holding company, subsidiaries and associated companies.

This Data Processing Notice complements the Data Processing Notice to Candidates and applies to you if you are a candidate who is confirmed for temporary work with our client, provided you reside in the European Union. Please note this Data Processing Notice does not apply if you are considered for a direct engagement with our client in which case you will only have to read the Data Processing Notice to Candidates.

This Data Processing Notice is meant to help you understand what personal data we collect, why we collect it, and what we do with it. This is important, and we hope you will take the time to read it carefully.

We have issued this Data Processing Notice in accordance with the General Data Protection Regulation (EU) 2016/679 (‘GDPR’) and any associated legislation e.g. the Data Protection, Privacy and Electronic Communications (Amendments etc) (EU Exit) Regulations 2019 and the 2018 UK Data Protection Act. In this Data Processing Notice, any references to GDPR also relate to associated legislation.

See below what is covered in this Data Processing Notice:

1. What personal data do we collect?
2. Why do we hold your personal data?
3. Will your personal data go outside the EEA?
4. How long will we store your personal data for?
5. Changes to this Data Processing Notice
6. Contact details of the Data Protection Officer

Please read the Data Processing Notice to Candidates if you have questions about the following topics:

 Will I be receiving marketing emails, and can I opt-out of this?
 What are my rights?
 Will my personal data be used to make automated decisions?
 How can I lodge a complaint?

1. What personal data do we collect?

If you are confirmed for temporary work, your personal data will be stored on our CRM system.

You may have to provide us with the following personal data:

⦁ A copy of your passport/ visa
⦁ National Insurance Number
⦁ P45, P46 or equivalent document
⦁ Professional references (only when requested by our client)
⦁ Clearance documents, criminal checks or a credit check (when applicable)
⦁ Company documents (see explanation below)
⦁ Full background checks

For enhanced screening or compliance purposes, we may also ask you to provide us with additional details. If this is the case, then we will tell you which documents we need.

We may also have to collect other documents which relate to your company (this can be your own company or a nominated umbrella company) e.g. a certificate of incorporation, VAT certificate (when applicable), bank statement (usually not a personal bank account) and insurance documents.

We will process data about your assignment(s) and relevant payments to your business in connection with your assignment(s). You may also be engaged as Agency Worker on a PAYE basis meaning that you will be paid as individual and that you will receive a monthly payslip. If you will be working as Agency Worker we will also process data regarding holiday pay, salary and pension contributions.

We are sometimes instructed by our client to conduct a background check. A “background check” is a verification of your antecedents by making use of the services of an agency which specialises in performing background checks. The details to be verified in this background check would typically include, but are not limited to:

(a) The authenticity of your residential address;
(b) The veracity of your claims in relation to educational qualifications and work/job experience; and
(c) An enquiry into your character, including but not limited to your criminal history

This information (e.g. a criminal check, a credit check or a full background screening report) will only be processed by our Compliance Team and/or your recruitment consultant. We do not share these personal data with any other employees in our business.

If background checks apply, we will tell you what is expected of you when initiating or conducting a background check. Unless we inform you otherwise, we will not share the outcome of the background check with any other party other than the client, and this will only be communicated to people with a ‘need to know’. Some clients (especially in the financial services industry) may require a copy of the background check as they need to abide by internal or external compliance standards.

If you decide to work through one of our approved umbrella companies (feel free to email contract@welovesalt.com to get an up-to-date list of approved umbrella companies) or if you wish to take out insurance via one of our insurance partner(s), we may provide these business partners with your name, email address and phone number. We will only do this if you have indicated that you are happy for us to do so.

We will furthermore process your assignment details (including the agreed rates) and may provide you with a Key Information Document to give you visibility on how your take-home pay is calculated.

If you work as a contractor in the UK from 6 April 2021 onwards, the end client may have to make a determination on your tax status (‘IR35 status’). We will endeavour to communicate your IR35 status before the start of your assignment. If your assignment is inside IR35, we may have to ask you to select an approved umbrella company who will deduct PAYE from your pay rate. If your assignment is outside IR35, no PAYE deductions will be made. For legal reasons, we will keep a copy on file of both the IR 35 determination and the reasons for that determination. You can request more info by emailing the IR35 team: IR35@welovesalt.com. More info can also be found on the Salt website.

2. Why do we hold your personal data?

We may collect your personal data for various purposes. First, we will need to enter into a contract with you as an individual, your company or umbrella company in which we outline the details of your assignment and the relevant terms and conditions. We moreover need to process some of your data as this is necessary for complying with legal obligations under various recruitment, fiscal, social security and immigration laws. For instance, we need to keep a copy of your passport to comply with the requirements from the Home Office as we need to verify your right to work in the UK or any other territory you will be working in. We also need your National Insurance number to satisfy quarterly HMRC (UK Tax Authorities) reporting requirements and we may need to process your IR35 status in order to determine if any PAYE deductions apply when determining your pay rate. If you are engaged as Agency Worker on a PAYE basis, we also need to receive your personal bank details and store a P45, P46 or equivalent document for payroll purposes.

Furthermore, as we are a recruitment agency, we have legitimate interests to screen our candidates so we can assess their suitability for the job and for that reason we may have to check your references in order to verify your job history. In some cases, this is a client requirement. Please note that unless stated otherwise, we would only ask the referee to confirm dates and job title(s).

Additionally, some clients require us to do more stringent vetting to ensure that you are the right candidate for the job, for example, if you are going to work for the government or a financial services institution. In that case, we will tell you exactly which documents are required to initiate the background checks.

3. Will my personal data go outside the EEA?

If you work for a client who is based outside the EEA, then your data may also be processed outside the EEA. Salt will use all reasonable endeavours to ensure adequate safeguards are in place when transferring data to our clients. However please note that if the client uses your data, they qualify as a data controller. This means that they determine the purpose and means of processing your personal data. Therefore, legally they are also responsible for safely and legitimately processing your data.

4. How long will your data be stored for?

Your personal data will be stored in our systems for the duration of your assignment and six years thereafter unless there is a direct statutory requirement (that comes into force) under which we are obliged to keep your data stored in our databases for a longer period of time. We have decided to apply this retention period as we will have to keep your data on file for a significant period of time in order to comply with our tax obligations and we may have to use it for the defence of legal claims.

Upon expiry of this retention period, we will only process your data if you stay in touch with us regarding job opportunities. Your personal data will be stored in our systems for three consecutive years. As long as you are working with Salt’s Recruitment Consultants on your next career step, we will keep your data on file to be able to contact you should a new opportunity arise.

Your data will be removed from our systems if

a) We have not heard from you during this three year period, or
b) If you request for your data to be removed

Background check reports will be kept on file for the duration of your assignment and two years thereafter. This document will be deleted upon expiry of this retention period provided our clients have indicated they are happy for us to delete these data.

5. Changes to this Data Processing Notice

Any changes we make to our Data Processing Notice in the future will be posted on this website (if we make any significant changes that may affect your rights as a data subject) and where appropriate, notified to you by email. Please check back frequently to see any updates or changes to this Data Processing Notice.

6. Contact details

If you have any questions, comments, and requests regarding your personal data or this Data Processing Notice, please address them to our Compliance team via GDPR@welovesalt.com.

Last updated on 29 April 2020

The Salt Group is committed to protecting and respecting your privacy. The Salt Group entails our ultimate holding company, subsidiaries and associated companies.

This Data Processing Notice applies to you if you (1) are a representative of any of our clients or suppliers and if (2) you reside within the European Union.

It is meant to help you understand what personal data we collect, why we collect it and what we do with it. Furthermore, it will briefly outline your rights. This is important, and we hope you will take the time to read it carefully.

We have issued this Data Processing Notice in accordance with the General Data Protection Regulation (EU) 2016/679 (‘GDPR’) and any associated legislation like for instance the Data Protection, Privacy and Electronic Communications (Amendments etc) (EU Exit) Regulations 2019 and the 2018 UK Data Protection Act. In this Data Processing Notice, any references to GDPR also relate to associated legislation.

This Data Processing Notice will outline:

1. We are a data controller
2. What personal data do we collect?
3. Why do we hold your data?
4. Optional Marketing communication
5. We transfer your personal data outside the EEA
6. How long will we store your data for?
7. What are your rights?
8. Automated decision making
9. Lodging a complaint
10. Changes to this Data Processing Notice
11. Contact details of the Data Protection Officer

1. We are a data controller

We have offices worldwide and all our entities use the same internal CRM system. All our legal entities act as a data controller as we determine the purposes for which and the means by which personal data is processed.

Our legal entities are listed below:

Your personal data will be stored on our CRM database. Your personal data can, therefore, be accessed by our employees who are based in various international offices. All the Salt offices, including our overseas ones, will comply with GDPR when processing your personal data.

Furthermore, we may disclose your personal information to third parties in the event that we sell or buy any business or assets, in which case we will have to disclose your personal data to the prospective seller or buyer of such business or assets.

We may moreover be under a duty to disclose or share your personal data in order to comply with any legal obligation, to defend our business against a legal claim or in order to enforce or apply our standard terms of business or other agreements or to protect the rights, property or safety of Salt, our customers or other parties.

2. What personal data do we collect?

We will typically collect the following personal data:

⦁ Your full name
⦁ Job title
⦁ Job function
⦁ LinkedIn profile
⦁ Your email addresses
⦁ Your (mobile) telephone number
⦁ Your company details (location, department)
You may provide us with this information, but we may also acquire your details from other sources e.g. through job boards, your company website or candidate referrals. Our recruitment consultants will be happy to explain how they located your personal data.

3. Why do we hold your data?

We will collect your information to carry out our core business activities. Specifically, we may process your personal data for the following purposes:

⦁ Providing you with information about (potential) candidates;
⦁ Communicating with you to identify opportunities for your business;
⦁ Contacting you in relation to the performance of a contract with your organisation;
⦁ Evaluating your experience with Salt and our recruitment process;
⦁ Keeping your business updated on how we can better support you to find the right candidate for the job.

We have a legitimate interest to process your data as we need to build and maintain relationships with our clients and suppliers. We also need your details to provide the best possible services to your business, candidates, suppliers and other stakeholders who are involved in the hiring process.

Furthermore, to support our candidate’s career aspirations and our client’s resourcing needs we require a database of client and supplier data which contains historical information as well as up-to-date contact details. We will only collect information that is necessary to satisfy our legitimate business interests.

Furthermore, we may need to use your details in order to enter into a contract and/ or successfully perform our contractual obligations with your business.

4. Optional Marketing communication

Salt may hold your personal data for marketing purposes. Salt may send you marketing communication however you can opt-out. Examples are invitations to networking events in your city or emails to keep your business updated on the latest trends and developments in the market. You are entitled to opt-out of any data processing and/ or marketing communications. If you want to opt-out, please click the ‘unsubscribe’ link in the footer of the respective email or use the Preference Centre to update your settings.

5. We transfer your personal data outside the EEA

Your personal information may be stored and processed in any country where we have offices and therefore your personal data may be processed in countries outside of your country of residence, including the United States, which may have rules in place that are different from the laws in your country.

All Salt entities, however, operate under Standard Contractual Clauses providing protections and safeguards for cross-border transfers outside the EU. We take all steps reasonably necessary to ensure that your data is treated securely and in accordance with relevant data privacy laws. You can request a copy of these Standard Contractual Clauses by emailing GDPR@welovesalt.com.

Furthermore, we may have to transfer your personal data to relevant stakeholders like candidates or other third parties (outside the EEA). These data transfers are however necessary for pre-contractual steps taken in order to provide services to your business or for the performance of an existing contract. Please note that if another business processes your personal data, they will also be responsible for safely and legitimately processing your data.

6. How long will we store your data for?

In principle, your personal data will be stored in our systems for as long as we engage with your organisation. If we enter into an agreement with your organisation we need to keep your personal data on file for the duration of the business relationship and six years thereafter unless there is a direct statutory requirement (that comes into force) under which we are under an obligation to keep your personal data stored in our database for a longer period of time.

We may also need to hold your personal data on file for the purposes of executing an agreement to which your organisation is a party, to comply with our legal obligations or to defend ourselves against a legal claim.

If however, we have never completed a transaction with your organisation then we will remove your details from our database if we have not been in touch with you for a period of at least 6 years or if it appears that you have left your organisation.

7. What are your rights?

You are entitled to various rights:

• You can request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected. This means when working with our recruitment consultants, make sure that you notify us of any changes or update your information like email, phone number etc. when they change.

• You can request the erasure of your personal information. This enables you to ask us to delete or remove personal information 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 information where you have exercised your right to object to processing (see below). This means should you wish to be removed from Salt’s database, please email GDPR@welovesalt.com.

• You can object to the processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes. This means we will only send you marketing communication if you have opted in. You can opt-out at any time by clicking the ‘unsubscribe’ link in the footer of the email in question so you will be removed from the Salt marketing mailing list. You can also use the Salt Preference Centre to opt-in and out of other communication from Salt.

• You can request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example, if you want us to establish its accuracy or the reason for processing it.

• You can request the transfer of your personal information to another party in certain formats, if practicable.

All such requests need to be addressed to GDPR@welovesalt.com.

The fact that you lodge a request does not necessarily mean that we will grant your request in every instance especially if Salt has a legitimate interest in keeping your data. We will always give reasons if we decline your request.

Salt will, however, provide information without undue delay and in any event within one month (this can be extended to 2 months in exceptional circumstances) of the receipt of the request, however where requests are manifestly unfounded or excessive in particular because of its repetitive character, Salt may refuse to act upon your request. In that case, we will inform you within one month of the request of the possibility of lodging a complaint with a supervisory authority (in the UK this will be the Information Commissioner’s Office) or seeking a judicial remedy.

8. Existence of automated decision-making

We will not conduct any forms of automated processing of your personal data consisting of the use of personal data to evaluate certain personal aspects relating to you. We will not analyse or predict aspects concerning your performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements. Furthermore, we will not make decisions that are based solely on automated processing which produces legal effects or similarly significantly affects your rights.

9. Lodging a complaint

If you feel that your rights have been violated, you are entitled to lodge a complaint with the supervisory authority of your country of residence. If you are based in the UK you can contact the Information Commissioner’s Office. Alternatively, you can seek a legal remedy. However, before escalating the case to the competent authorities, we strongly encourage you to contact us by emailing GDPR@welovesalt.com. We will then review your complaint at our earliest convenience.

10. Changes to this Data Processing Notice

Any changes we make to our Data Processing Notice will be posted on this website and where appropriate, communicated to you by email. Please check back frequently to see any updates or changes to this Data Processing Notice.

11. Contact details of the Data Protection Officer

All queries regarding this Data Processing Notice should be addressed to our Compliance team via GDPR@welovesalt.com.

Last updated on 13 March 2020

The Salt Group is committed to protecting and respecting your privacy. The Salt Group entails our ultimate holding company, subsidiaries and associated companies.

This Data Processing Notice applies to you if you are a referee (you are a referee if you are asked to provide us with an employment reference) and if you reside within the European Union.

This Data Processing Notice is meant to help you understand what personal data we collect, why we collect it and what we do with it. Furthermore, it will briefly outline your legal rights. This is important, and we hope you will take the time to read it carefully.

We have issued this Data Processing Notice in accordance with the General Data Protection Regulation (EU) 2016/679 (‘GDPR’) and any associated legislation like for example the Data Protection, Privacy and Electronic Communications (Amendments etc) (EU Exit) Regulations 2019 and the 2018 UK Data Protection Act. In this Data Processing Notice, any references to GDPR also relate to associated legislation.

This Data Processing Notice will outline:

1. We are a data controller
2. What personal data do we collect?
3. Why do we process your personal data?
4. We may transfer your data outside the EEA
5. How long will we store your data for?
6. What are your rights?
7. Automated decision-making
8. Lodging a complaint
9. Changes to this Data Processing Notice
10. Contact details of the Data Protection Officer

1. We are a data controller

The Salt Group entails our ultimate holding company and our subsidiaries. We have offices worldwide and all our entities are connected via the same internal CRM system. All our entities act as a data controller as we determine the purposes for which and the means by which personal data is processed.

Our offices are listed below:

Your personal data will be stored on our servers and specifically processed on our global CRM system Jobscience. Your data may therefore be accessed by our members of staff who are based in various international offices across the globe.

All our Salt offices, including our overseas ones, need to comply with GDPR when processing your personal data, provided you reside in the European Union. We may share your details with our clients. This is usually limited to your job title and contact details.

We may furthermore disclose your personal information to third parties in the event that we sell or buy any business or assets in which case we will have to disclose your personal data to the potential seller or buyer of such business or assets.

Furthermore, we may be under a duty to disclose or share your personal data in order to comply with any legal obligation, to defend our business against a legal claim or in order to enforce our standard terms of business or other agreements.

2. What personal data do we collect?

Salt may collect the following personal data:

⦁ Your full name
⦁ Your job title
⦁ Your email addresses
⦁ Your (mobile) telephone number

We will receive this information from our candidate if our client wants us to investigate the employment history of the relevant candidate. We will then ask you to provide us with a reference.

3. Why do we process your personal data?

Salt will collect your personal data for the following purposes:

⦁ Contacting you in order to request a reference for our candidate who has nominated you as one of their referees;
⦁ Showing proof to our clients that we have verified the employment history of the candidate.

The legal basis under the current laws for collecting and processing your personal data is a legitimate interest. As we are a recruitment company, our clients may expect us to verify the employment history of the candidate in order to assess their suitability for the role.

4. We may transfer your data outside the EEA

Your personal information may be stored and processed outside the EEA.

All Salt entities operate under Standard Contractual Clauses providing protections and safeguards for cross-border transfers outside the EU. We take all steps reasonably necessary to ensure that your data is processed securely and in accordance with the relevant data privacy laws. You can request a copy of these Standard Contractual Clauses by emailing GDPR@welovesalt.com.

Please also note that your personal data may be transferred outside the EEA if we share your data with our clients. Salt will use all reasonable endeavours to ensure a safe data transfer outside the EEA. However, if our client receives your details, they are also responsible for safely and legitimately processing your data.

5. How long will we store your data for?

Your personal data will be stored in our systems for the duration of the candidate’s assignment and for six years thereafter (and will be deleted thereafter) unless Salt needs to use this information for the defence of legal claims or if there is a direct statutory requirement that comes into force under which Salt is obliged to keep your data stored for a longer period of time.

6. What are your rights?

You are entitled to various rights:

• You can request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.

• You can request erasure of your personal information. This enables you to ask us to delete or remove personal information 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 information where you have exercised your right to object to processing (see below).

• You can object to processing of your personal information 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.

• You can request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.

All such requests need to be addressed to GDPR@welovesalt.com.

The fact that you lodge a request does not necessarily mean that we will grant your request at all times especially if Salt has legitimate interest in keeping your data. We will always give reasons if we decline your request.

Salt will however provide information without undue delay and in any event within one month (this can be extended to 2 months in exceptional circumstances) of the receipt of the request, however where requests are manifestly unfounded or excessive in particular because of is repetitive character, Salt may refuse to act upon your request. In that case we will inform you of the possibility of lodging a complaint with the supervisory authority (in the UK this will be the ICO) or seeking a judicial remedy.

7. Automated decision-making

Salt will not conduct any forms of automated processing of your personal data to evaluate certain personal aspects relating to you, in particular to analyse or predicts aspects concerning your performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements. We will furthermore not make decisions that are based solely on automated processing which produces legal effects or similarly significantly affects you as a data subject.

8. Lodging a complaint

If you feel that your rights have been violated, you are entitled to lodge a complaint with the supervisory authority of your country of residence. If you are based in the UK you can contact the Information Commissioner’s Office. Alternatively, you can seek a legal remedy. However, before escalating the case to the competent authorities, we strongly encourage you to contact us by emailing GDPR@welovesalt.com. We will then review your complaint at our earliest convenience.

9. Changes to this Data Processing Notice

Any changes we make to our Data Processing Notice will be posted on this website and where appropriate (if significantly amended), communicated to you by email. Please check back frequently to see any updates or changes to this Data Processing Notice.

10. Contact details of our Data Protection Officer

All queries regarding this Data Processing Notice should be addressed to our Compliance team via GDPR@welovesalt.com.

Last updated on 13 March 2020

The Salt Group is committed to protecting and respecting your privacy. The Salt Group entails our ultimate holding company, subsidiaries and associated companies.
This Data Processing Notice applies to you if you are considered for employment at Salt and reside in the EU.

This Data Processing Notice is meant to help you understand what personal data we collect, why we collect it and what we do with it. Furthermore, it will briefly outline your legal rights. This is important, and we hope you will take the time to read it carefully.

We have issued this Data Processing Notice in accordance with the General Data Protection Regulation (EU) 2016/679 (‘GDPR’) and any associated legislation like for instance the Data Protection, Privacy and Electronic Communications (Amendments etc) (EU Exit) Regulations 2019 and the 2018 UK Data Protection Act. In this Data Processing Notice, any references to GDPR also relate to associated legislation.

This Data Processing Notice outlines:

1. We are a Data Controller
2. What personal data do we collect?
3. Why do we process your data?
4. We may transfer data outside the EEA
5. How long do we store your data for?
6. What are your rights?
7. Lodging a complaint
8. Changes to this Data Processing Notice
9. Contact details of the Data Protection Officer

1. We are a Data Controller

The following legal entity will act as a data controller if you are considered for employment at Salt:

Salt Recruitment Group Limited
9 Wootton Street
SE1 8TG London
United Kingdom

A data controller determines the purposes for which and the means by which personal data is processed.

Your personal data will only be processed by employees who will review your application. This is limited to a few authorised individuals only, for instance, the Head of Internal Recruitment, the HR manager or the hiring manager. All applications are treated confidentially.

In the event that we sell or buy any business or assets, we will have to disclose your personal data to the prospective seller or buyer of such business or assets. We may also be under a duty to disclose or share your personal data in order to comply with any legal obligation, to defend our business against a legal claim or in order to enforce or apply our standard terms of business or other agreements or to protect the rights, property or safety of Salt, our customers or other parties.

2. What personal data do we collect?

If you are considered for employment at Salt, then we will typically need the following personal data:

• Personal details
• CV
• Payslip(s) (if you are considered for a Sales role)

3. Why do we process your data?

We need to assess your suitability for a job at Salt. The legal basis for this is the prospect of signing an employment agreement with Salt. Please note that we do not in any way subject your personal data to automated decision-making or profiling.

4. We may transfer data outside the EEA

We may transfer your data outside the EEA. All Salt entities operate under Standard Contractual Clauses providing protections and safeguards for cross-border transfers. We take all steps reasonably necessary to ensure that your data is treated securely and in accordance with relevant data privacy laws. A copy of these Standard Contractual Clauses can be made available upon written request by emailing GDPR@welovesalt.com.

5. How long do we store your data for?

If you apply for a job at Salt but subsequently do not get hired, we keep your data on file. However, if we do not stay in touch with you for a subsequent period of two years then we will remove your data from our systems.

6. What are your rights?

You are entitled to various rights. Your rights are outlined in more detail below:

• You can request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.

• You can request the erasure of your personal information. This enables you to ask us to delete or remove personal information 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 information where you have exercised your right to object to processing (see below).

• You can object to the processing of your personal information 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. You also have the right to object where we are processing your personal information for direct marketing purposes.

• You can request the restriction of the processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example, if you want us to establish its accuracy or the reason for processing it.

• You can request the transfer of your personal information to another party in certain formats, if practicable.

All such requests need to be addressed to GDPR@welovesalt.com.

The fact that you can lodge a request does not necessarily mean that we will grant your request at any given time, especially if Salt has a legitimate interest in keeping your data. We will always give reasons if we decline your request.

Salt will provide information without undue delay and in any event within one month (this can be extended to 2 months in exceptional circumstances) of the receipt of your request. However, where requests are manifestly unfounded or excessive, in particular, because of its repetitive character, we may refuse to act upon your request. In that case, we will inform you of the possibility of lodging a complaint with a supervisory authority (in the UK this will be the ICO) or seeking a judicial remedy.

7. Lodging a complaint

If you feel that your rights have been violated, you are entitled to lodge a complaint with the supervisory authority of your country of residence. If you are based in the UK you can contact the Information Commissioner’s Office. Alternatively, you can seek a legal remedy. However, before escalating the case to the competent authorities, we strongly encourage you to contact us by emailing GDPR@welovesalt.com. We will then review your complaint at our earliest convenience.

8. Changes to this Data Processing Notice

Any changes we make to this policy will be posted on this website and where appropriate (if we make any significant changes that may affect your rights), communicated to you by email. Please check back frequently to see any updates or changes.

9. Contact details of the Data Protection Officer

All queries regarding this Data Processing Notice should be addressed to our Compliance team via GDPR@welovesalt.com.

Last updated on 13 March 2020