PRIVACY NOTICE

The purpose of this Privacy Notice is to tell you what information The MCL Group (Int) Limited trading as MCL Resourcing (“MCL Resourcing”) collects from you, how and when it may be collected and what happens to it. For the purpose of this Privacy Notice, “we” and “us” refer to MCL Resourcing.

Personal Information is any personally identifiable information, such as your email address, name, home or work address, telephone number, bank details or tax codes, which can directly or indirectly identify you. We refer to it as “Personal Information” here.

For the purpose of the applicable data protection laws including the General Data Protection Regulation, we, The MCL Group (Int) Limited, trading as MCL Resourcing, are the data controller of your personal data.

By continuing to use our portals, access our websites, completing our forms or by otherwise providing us with your information, you warrant that any data provided by you to us is accurate.

INFORMATION WE COLLECT FROM YOU

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data from which an individual can no longer be identified (anonymous data).

Recording voice calls and video calls

To help improve efficiency and effectiveness of some of the services provided to you by phone or video call we may keep
a record of the call.

We may collect the following information:

• Personal and contact details (for example your name, email address, date of birth, gender and your choice of language with which you wish to interact with us).
• Personal and contact details you give us when subscribing to receive emails, newsletters or marketing information from us.
• During pre-assignment vetting we will request details from you including, your name, your work history, qualifications, contact details (such as email, telephone number and home address), your right to work documents, details required for equality and discrimination legislation checks and your personal preferences, choices and requirements specific to particular requests or services.
• Details of your education, employment history, bank details and national insurance number, references, right to work and other information you tell us about yourself (e.g. the information contained within your CV) when you engage with us for the provision of services.
• Information required for pre-assignment vetting, such as DBS checks and results of medical screenings.
• Information we collect via cookies or similar technology stored on your device (find out more about cookies and how we use them in our Cookies Policy: www.mclresourcing.co.uk/cookies-policy/
• Your IP address.
• Information from social media activity (such as likes, shares and tweets) when you interact with us on social media.
• Information you provide if you report a problem with our website or service.
• Additional information which you provide voluntarily and/or which we may ask from you to better understand you and your interests.

We may also collect sensitive Personal Information about you (including details of your physical or mental health, racial or ethnic origin, criminal allegations or offences, trade union membership and/or other sensitive Personal Information that you may choose to provide to us voluntarily from time to time).

We may collect your Personal Information when you apply for a role through us (or otherwise contact us from time to
time) by:

• Responding to an advert on a job board or other website.
• By directly contacting our business.
• By filling in an application form in a branch.
• When you speak to one of our consultants by telephone.
• Another agency or organisation passes your details to us
• We collect and use your Personal Information because it is necessary to obtain certain details including Personal Information from you in the work-searching process and it is in our legitimate interests in the course of operating our business, including:
• Responding to your queries.
• Providing work-finding services and/or information to you.
• Transmitting Personal Information between our offices or functions for internal administrative purposes.
• Setting you up on a work assignment with a client.
• Hosting and maintaining our websites.
• Ensuring network and information security.
• Carrying out direct marketing.

However we will only collect, use and handle your Personal Information when:

• It is necessary for our legitimate interests in connection with carrying out our business, as long as, in each case, these interests are in line with applicable law and your legal rights.
• Where you have agreed.
• Where this is necessary for legal obligations which apply to us.

USE OF YOUR INFORMATION

We will only use your personal data when and how the law allows us to. We undertake the following processing of your Personal Information on the legal basis that it is necessary to perform the contract with you and to provide the services we have agreed to provide to you. Where we have not entered into a contract with you, we may also carry out this processing because in that pre contractual stage where we consider it is necessary in our legitimate business interests in order to deal with requests, enquiries or comments you have made to us.

Submission of details to clients

If you register to apply for a particular role, request to be put forward for a role or if you have asked us to put you forward for suitable roles, we will share some of your personal details including your name, work history and qualifications with our clients offering potential roles which might be suitable for you.

On-boarding for a work-assignment

If you are offered and accept a work assignment through us, we will need further Personal Information from you such as NI number, bank details, emergency contact details and some medical information in order to fulfil our statutory and contractual obligations to both you and our client.

Reporting to clients and managing timesheets, payroll and work performance

We sometimes have to prepare reports for clients relating to the services provided by us for example reports on financial or administrative matters or compliance with legal requirements. Such reports may contain your Personal Information such as your name, hours worked and pay rate. In addition we may need to manage submission of timesheets, payroll services and other Human Resourcing services such as managing your statutory rights and work appraisals for our clients, all of which would require use of your Personal Information.

Other lawfully permitted processing

We may also use any Personal Information that you provide to us for example to other companies within the MCL Group or to employers or any other company who you ask us to approach on your behalf for work-searching purposes. If you choose not to provide Personal Information requested by us, we may not be able to provide you with the services and/or information you have requested or otherwise fulfil the purpose(s) for which we have asked for the Personal Information, including placing you in a work-assignment. We will where possible anonymise or aggregate such data for reporting purposes.

We undertake Pre-Assignment Vetting

We collect your Personal Information which you provide to us when applying for a role or registering for our job-finding services to comply with our (and clients’) legal obligations regarding your right to work and any necessary qualifications for roles. We may also process your Personal Information for this purpose where we consider it necessary for performance of the contract with you, or otherwise with your consent.

Marketing

It is your choice whether you receive information such as marketing from us. If you indicated that you are interested in receiving regular information about our activities, we may send you communications electronically or by post. We will not contact you for marketing purposes unless you have given your prior consent. If, at any time, you no longer wish to receive
this information, please send a written request to compliance@mclresourcing.co.uk

Also, all of our email marketing correspondence gives you the option to opt-out of receiving further marketing emails. Please note that you will still receive emails directly related to an enquiry you raised with us.

Website Cookies

We use cookies on our website. You can find out about the cookies we use and why we use them by viewing our Cookies Policy: www.mclresourcing.co.uk/cookies-policy/.

WHERE WE STORE YOUR INFORMATION

All information you provide to us is stored on secure servers inside the European Economic Area (“EAA”).

Due to the global nature of our services, the information that we collect from you may be accessed, via our servers, from outside of the EEA. Whenever we make your personal data available outside the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• We may make your personal data available in countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
• Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
• Where we use providers based in the US, we will ensure the relevant Transfer Risk Assessment has been completed and put in place an IDTA (International Data Transfer Agreement) if required.

Please contact us if you want further information on the specific mechanism used by us when making your personal data available outside the EEA.

DISCLOSURE OF YOUR INFORMATION

The information you provide to us will be treated as confidential. However, we may disclose your information to other third parties who act for us for the purposes set out in the notice or for purposes approved by you.

We may disclose your personal information to third parties, including:

• Appropriate providers and professionals;
• State bodies such as the Health and Safety Executive
• Any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006; analytics, search engine and service providers that assist us in the improvement and optimisation of our site and portals;
• Your employer or contracting company subject at all times to your wishes (please see above for further information);
• If we are under a duty to disclose or share your personal data in order to comply with any legal obligation or contract;
• To protect our rights and property, or our safety and our users’ safety;
• For the purposes of preventing, reporting or investigating criminal activity; and/or
• For the purposes of appropriately dealing with any complaints or issues with our site or the portals.

We require all third parties to respect the security of your personal data and to treat it in accordance with applicable data protection legislation. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

YOUR RIGHTS

Individual Rights

Under applicable data protection legislation, you have the right under certain circumstances to:

• Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check we are lawfully processing it;
• 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;
• 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);
• Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party). You also have the right to object where we are processing your personal information for direct marketing purposes;
• 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;
• Request the transfer of your personal information to another party; and
• Withdraw your consent to the processing of your personal information at any time.

If you would like to exercise any of your rights above, please contact us at Compliance@mclresourcing.co.uk

You also have the right to complain to the Information Commissioner’s Office in relation to our use of your information.

DATA RETENTION

We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

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
requirements.

In some circumstances we may anonymise your personal information so that it can no longer be associated with you, in
which case we may use such information without further notice to you.

OUR WEBSITE

Security

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 or portals. Any transmission is at your own risk. We are committed to ensuring that your information is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect online.

Your data may be stored by third parties on our behalf. We, and our third party contractors, employ security measures to protect your information from access by unauthorised persons and against unlawful processing, accidental loss, destruction or damage.

Links to other websites

Our site and portals contains links to other websites of interest. If you use these links, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information you provide whilst visiting such sites and such sites are not governed by this Notice. You should exercise caution and check the terms and conditions and privacy policies which apply to third party websites.

CHANGES TO YOUR INFORMATION

Please help us keep our records updated by informing us of any changes to your information.

CHANGES TO OUR PRIVACY NOTICE

We may amend this notice from time to time. If we make any substantial changes, including changes to the purposes for which we use your personal information, we will notify you by posting a prominent notice on our site and portals and, where appropriate, notify you by email.

CONTACT US

If you have any questions in relation to this Privacy Notice, or if you would like to contact us to exercise your rights as stated in this Privacy Notice, you may contact us at: Compliance@mclresourcing.co.uk

RES-OP-023-03 – Privacy Policy – MCL Resourcing

Date of last change 12.04.23