This Privacy Policy applies to how we collect, use and process personal information (i.e. personal data under applicable data privacy laws) relating to:
Reference to Montreal Associates includes our affiliates (details below) unless a separate or affiliate privacy policy applies, or the context otherwise requires.
Montreal Associates is committed to abiding by this Privacy Policy, as well as the requirements of applicable laws, in the operation of its business.
Please read this policy carefully as it explains the kinds of personal information we collect about you and how it is handled.
The data controller (or "controller" as defined in the General Data Protection Regulation) is us, Montreal Associates (Systems) Ltd (registered in England Wales under company number 1449046 with its registered office at 2nd Floor, 4 Thomas More Square, London E1W 1YW ("Montreal Associates") together with our affiliates Montreal Associates (Systems) S.L. (registered address Avenida Diagonal 409, 1 planta, 08008 Barcelona in Spain) and Montreal Associates GmbH (registered address An der Welle 4, 60322 Frankfurt am Main in Germany). Recipients of your data will in the first instance be Montreal Associates and/or our affiliates, and our group's employees, agents and subcontractors. Other recipients of your data are as set out in this Privacy Policy. As data controller we decide on how we collect and process personal information about you.
If you have queries on this Privacy Policy or how we process your personal information please contact us using the contact details in Section 13 below.
We are also bound by the applicable terms of the Employment Agencies Act 1973 (“1973 Act”) and the Conduct of Employment Agencies and Employment Businesses Regulations (“Regulations”), as amended from time to time.
Montreal Associates and its affiliates ("group") are in a number of cases joint controllers of personal data with appropriate data sharing arrangements in place and the arrangements within the group are reflected in this privacy policy which applies to each group entity as a data controller. In particular Montreal Associates operates a common group IT policy and systems and applies common data protection policies (including this privacy policy) across the group and has published this policy for the benefit of the group. The group also has a common point of contact for privacy queries – see Section 13 below,
We require personal data from you in order to be able to provide information, products and services to you and to fulfill any contractual obligations we may have with you and any legal obligations and as otherwise described in this Privacy Policy. If you fail to provide any personal data requested we may not be able to enter into and/or perform our contract with you or provide products, information or services to you as intended, and we may not be able to perform a legal obligation.
We may collect, store, and use the following categories of personal information about you:
Candidate Data
In order to provide the best possible employment or business opportunities that are tailored to you, we need to process certain information about you. We only ask for details that will genuinely help us to help you and this will also depend on what stage you are at in any recruitment process, as this will affect what information about you we may need to process.
Depending on the relevant circumstances and applicable local laws and requirements, we may collect information to enable us to offer you potential employment opportunities which are tailored to your circumstances and your interests. This information may include:
We may also collect, store and use the following “special categories” of more sensitive personal information where lawful and we will inform you of any additional policies and procedures relating to this data where the law requires us to do so:
Client Data
The data we collect about Clients is actually very limited. We generally only need to have your contact details or the details of individual contacts at your organisation (such as their names, telephone numbers and email addresses) to enable us to provide our services to you and to ensure that our relationship runs smoothly. We may obtain this information from you, from your employer (our Client) or from public sources and this includes:
Supplier Data
We need a small amount of information from our Suppliers to ensure that things run smoothly. We need contact details of relevant individuals at your organisation so that we can communicate with you. We also need other information such as your bank details so that we can pay for the services you provide (if this is part of the contractual arrangements between us). We may obtain this information from you, from your employer (our Supplier) or from public sources and this includes:
People whose data we receive from candidates and staff, such as referees and emergency contacts
In order to provide candidates with suitable employment opportunities safely and securely and to provide for every eventuality for them and our staff, we need some basic background information. Emergency contact details give us somebody to call on in an emergency – where you are the candidate please ensure you obtain their consent for this. To ask for a reference, we'll obviously need the referee's contact details (such as name, email address and telephone number). We'll also need these details if our candidate or a member of our staff has put you down as their emergency contact so that we can contact you in the event of an accident or an emergency.
Information we collect about you automatically each time you visit our website:
We collect personal information about you through different methods:
We will collect additional personal information in the course of a contract for services we may have or put in place should our business relationship lead to a commercial agreement.
We may obtain information about your general internet usage by using a cookie file which is stored on your browser or the hard drive of your computer. They help us to improve our site and to deliver a better and more personalised service. Some of the cookies we use are essential for the site to operate.
You may choose to accept or block cookies by activating various settings on your browser. However, if you use your browser settings to block all cookies (including essential cookies) you may not be to access all or parts of our site. Unless you have adjusted your browser settings to refuse cookies, our system will issue cookies as soon you visit our site.
If you register with us, or if you continue to use our site, you agree to our use of cookies.
Please note that our advertisers may also use cookies, over which we have no control.
We use information held about you in the following ways:
The core service we offer to our candidates and clients is the introduction of candidates to our clients for the purpose of temporary or permanent engagement. However, our service expands to supporting individuals throughout their career and to supporting businesses’ resourcing needs and strategies.
Our primary legal basis for the processing of personal data is our legitimate interest, described in more detail below, although we will also rely on contract, legal obligation and consent for specific uses of data as described below.
We will rely on our legitimate interests and contract if we are negotiating or have entered into a placement agreement with you or your organisation or any other contract to provide services to you or receive services from you or your organisation.
We will rely on a legal obligation if we are legally required to process information on to you to fulfil our legal obligations.
We will in some circumstances rely on consent for particular uses of your data and you will be asked for your express consent, if legally required. Examples of when consent may be the lawful basis for processing include permission to introduce you to a client (if you are a candidate).
Our Legitimate Interest
Our legitimate interests in collecting and retaining and otherwise processing your personal data are described below:
As a recruitment business and recruitment agency, we introduce candidates to clients for permanent employment, temporary worker placements or independent professional contracts. The exchange of personal data of our candidates and our client contacts is a fundamental, essential part of this process.
In order to support our candidates’ career aspirations and our clients’ resourcing needs, we require a database of candidate and client personal data containing historical information as well as current resourcing requirements.
To maintain, expand and develop our business we also need to record the personal data of prospective candidates and client contacts.
Marketing activities
Solely in accordance with your marketing preferences (therefore with your express consent), we will send you emails and promotional communications about Montreal Associates group such as:
You have the ability to opt-in to receive such communications through our preference centre via the following link https://r1.dotmailer-surveys.com/e743ae66-4330rpfe.
We consider all other email communications with you such as job alerts, project updates, timesheet and invoices emails to be transactional emails rather than a marketing activity and these are covered by our legitimate interests.
Situations in which we will use your personal information and the purposes for which we use it
If you're a job seeker or job applicant:
If you have been placed by Montreal Associates:
If you are the representative of a prospective customer/client:
If you are the representative of a current or ex-customer/client or current or ex-supplier:
Other uses we will make of your data
To ensure that content from our site is presented in the most effective manner for you and for your computer.
We will use your personal information:
We do not undertake automated decision making or profiling. We do use our computer systems to search and identify personal data in accordance with parameters set by a person. A person will always be involved in the decision-making process.
We do not envisage that we will collect and hold sensitive personal data about you, such as details of any criminal convictions and any special category data. However, there may be cases where we may process information relating to criminal convictions and special category data where this is lawful. Where we are required to have additional policies and procedures in place in relation to this data we will let you know.
Should we process special category data we will rely both on our legitimate interests and on consent (unless the data is made public by you, to protect your vital interests, in relation to legal claims or we are permitted to do so under employment law in which case these other special category grounds shall apply as applicable). We only process criminal conviction data where the law allows us to do so.
We will share your personal information with:
All entities in our group as part of our global recruitment activities, regular reporting activities on company performance, for system maintenance support and hosting of data.
Selected third parties including:
We may also disclose your personal information to third parties:
We have put in place measures to protect the security of your information. Details of these measures are available upon request using the contact details at the bottom of this form. Third parties we use as processors will only process your personal information on our instructions and where they have agreed to treat the information confidentially and to keep it secure.
We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.
However, while these measures provide security against unauthorised access, loss, theft or manipulation from third parties, the internet is not a fully secure domain. As such, we cannot guarantee the security of personal data that is sent to us via our website and sending such information is done at your own risk.
We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.
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 contacting you with suitable business or employment opportunities and satisfying any legal, accounting, or reporting requirements.
Details of retention periods for different aspects of your personal information are available in our retention notice upon request using the contact details at the bottom of this form. Once the retention period over, we will retain and securely destroy your personal information. 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.
One of the GDPR's main objectives is to protect and clarify the rights of individuals with regards to data privacy. This means that you have various rights in respect of your data. These are summarised below. For more information on your rights please refer to the guidance available from the Information Commissioner's Office (ICO).
To get in touch about these rights, please contact us using the contact details at section 13 below. Please note that we may keep a record of your communications to help us resolve any issues which you raise.
It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during the period for which we hold your data.
Your rights in connection with personal information
Under certain circumstances and subject to certain conditions, by law you have the right to:
Removal of your data from our website
If you've registered on our website, you can de-activate your account and remove all of your data at anytime by following this link: https://www.montrealassociates.com/member/login.aspx.
No fee usually required
You will not normally have to pay a fee to us to access your personal information (or to exercise any of the other rights). However, we may charge a fee in the limited circumstances this is lawful.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.
Montreal Associates is a global organisation – this is what enables us to offer the level of services that we do. In order for us to continue operating in this way, we may have to transfer or store your data internationally. The data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area ("EEA"). It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers or our clients as well as by our service providers where they are outside the EEA.
In order to provide you with the best service and to carry out the purposes described in this Privacy Policy, your data may be transferred to persons/entities outside the EEA including:
Where we transfer your personal data outside of the EEA we will only do so where permitted to do so by law e.g. the country in question is subject to an adequacy decision or where there are appropriate safeguards required by law (typically these will be standard data protection clauses adopted by the European Commission). Please contact us if you require further details of the countries to whom we may transfer your data and safeguards we use by contacting us as set out in Section 13 below.
We reserve the right to update this privacy notice at any time, and we will provide you with or make available on our website a new privacy notice when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal information.
We have appointed a Data Compliance Manager (DCM) to oversee compliance with this privacy notice. If you have any questions about this privacy notice or how we handle your personal information, please contact the DCM. You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues or where applicable to the relevant supervisory authorities in Germany and Spain.
To exercise all relevant rights, and for queries please in the first instance contact our Data Compliance Manager:
By Post
Montreal Associates (Systems) Ltd
2nd Floor,
4 Thomas More Square
London E1W 1YW
By email
dp@montrealassociates.com
UK
Information Commissioners Office
Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF
Tel: 0303 123 1113
Email https://ico.org.uk/global/contact-us/email/
Germany
Die Bundesbeauftragte für den Datenschutz und die Informationsfreiheit
Husarenstraße 30
53117 Bonn
Tel. +49 228 997799 0; +49 228 81995 0 Fax +49 228 997799 550; +49 228 81995 550
e-mail: poststelle@bfdi.bund.de
Website: http://www.bfdi.bund.de/
Spain
Agencia de Protección de Datos
C/Jorge Juan, 6
28001 Madrid
Tel. +34 91399 6200
Fax +34 91455 5699
e-mail: internacional@agpd.es
Website: https://www.agpd.es/
