Privacy Policy

Montreal Associates ("MA") is committed to protecting the privacy and security of your personal information under applicable data privacy laws including the GDPR.

This Privacy Policy applies to how we collect, use and process personal information (i.e. personal data under applicable data privacy laws) relating to:

  • job applicants, job seekers, IT contractors and others placed by Montreal Associates and other individuals in our search and any related databases (who in this Privacy Policy we refer to as "Candidates") in the context of our activity of employment business and employment agency.
  • the personnel of our clients and suppliers, past and present and certain other persons listed in this Privacy Policy. 

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.

1. WHO ARE WE AND HOW TO CONTACT US?

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,

2. WHY WE NEED YOUR PERSONAL INFORMATION AND THE CONSEQUENCES OF NOT SUPPLYING PERSONAL INFORMATION WE MAY REQUEST

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.

3. WHAT KIND OF PERSONAL DATA DO WE COLLECT?

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:

  • Personal contact details such as name, title, addresses, telephone numbers, personal and work email addresses, Skype or other web ID;
  • Sex/Gender;
  • Nationality;
  • A copy of your driving license and/or passport/identity card;
  • Photograph;
  • Date of birth;
  • Languages;
  • Education/qualifications;
  • Recruitment information (including copies of the right to work documentation, references, referee details and other information included in a CV, resume or cover letter);
  • Immigration status (whether you need a work permit);
  • Social security number (or equivalent in your country) and any other tax-related information;
  • Details of any criminal convictions if this is required for a role that you are interested in applying for;
  • Employer and/or work history including applicable notice periods;
  • History of jobs applied for / placement history;
  • Financial compensation history such as salary or rate;
  • Marital status and dependants;
  • Next of kin and emergency contact information;
  • National Insurance number or country equivalent;
  • Limited company information, their representative’s information and payment and financial information and certificates included but not limited to certificate of incorporation, certificate of professional insurance;
  • Bank account details of yourself or your company;
  • Location of employment or workplace;
  • Phone records of conversations with MA representatives;
  • Extra information that our clients may tell us about you / Performance information
  • Extra information that you choose to tell us;
  • Extra information that your referees choose to tell us about you.

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:

  • Information about your health, including any medical condition, health, and sickness records;
  • Information about criminal convictions and offenses.

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:

  • Company information available on local company registrars;
  • Personal contact details of company employees we are in contact with such as name, title, work addresses, telephone numbers, work email addresses, languages and skills;
  • Phone records of conversations with MA representatives;

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:

  • Company information available on local company registrars and financial and payment information;
  • Personal contact details of company employees we are in contact with such as name, title, work addresses, telephone numbers, work email addresses, languages and skills;
  • Contractual details, signed contract copies and client policies and annexes;
  • Phone records of conversations with MA representatives.

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:

  • technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information if applicable, geographical location, domain name from which you access the internet, browser type, and version;
  • information about your visit, including the full Uniform Resource Locators (URL), clickstream to, through and from our site (including date and time), pages you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs).

4. HOW DO WE COLLECT YOUR PERSONAL INFORMATION?

We collect personal information about you through different methods:

  • Through the application and recruitment process, either directly from you or from a third party such as but not limited to a job board, a referral or a reference;
  • Through search or qualification of job requirements process, prospective calls and participation in tender processes, either directly from you or from a third party such as but not limited to a job board, online portal or referral;
  • Through information gathered via interaction with the Montreal Associates website, such as your IP (Internet Protocol) address, domain name from which you access the internet, referring URL, browser type, geographical location and the time and date of your visit;
  • • Through information that you provide to the company for the purpose of subscribing to email messaging services such as job alerts and/or newsletters.
  • We may receive or acquire information about our visitors, job seekers, customers and suppliers from third-party partners (such as background or credit check providers) or other third party sources (such as information from publicly available sites (like LinkedIn, Xing, Viadeo, Freelance-info.fr and other similar professional networking sites and job boards)), or a job seeker's third party reference.

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.

PRIVACY AND COOKIE POLICY

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.

5. HOW DO WE USE YOUR PERSONAL INFORMATION, FOR WHAT PURPOSES AND WHAT LEGAL BASIS ARE WE RELYING ON?

We use information held about you in the following ways:

  • To carry out our obligations arising from any contracts we intend to enter into or have entered into between you and us and to provide you with the information, products, and services that you request from us or we think will be of interest to you because it is relevant to your career or to your organisation;
  • To provide your information to our clients in connection with an actual or potential engagement you have/may have with them:
  • To provide you with information about other services we offer that are similar to those that you have already purchased, been provided with or enquired about;

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:

  • Monthly Runners Email
  • Mailshots candidates and clients
  • Event Emails
  • Monthly Newsletters
  • Annual round-up email
  • Welcome campaigns
  • Re-engagement emails

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:

  • To facilitate the recruitment process, by matching your details to job opportunities.
  • To allow details of your skills and experience, to be viewed by our clients whom we feel may be interested in engaging your services. Please be assured that your personal details will only be provided to our clients if you have given permission to us to do so.
  • To allow you to subscribe to our "Jobs by Email" service. This service will allow you to receive details of latest jobs via e-mail which are relevant to your sector and professional experience. Where you are sent details of a job via the "Jobs by Email" service, you will be able to unsubscribe from such updates at any time. Please see below "Access to your Personal Information" for further details.
  • To keep you informed of job opportunities and contract assignments which we think may be of interest to you via email and telephone.
  • From time to time, we may also use your information to contact you for market research purposes. We may contact you by email, phone, fax or mail.  .
  • To preserve our business relationship with you as a user of our website.
  • To notify you about changes to our service.
  • To provide information other than your skills and experience requested by our clients (with your consent where this is required by law).

If you have been placed by Montreal Associates:

  • To facilitate the recruitment process, by matching your details to job opportunities.
  • To allow details of your skills and experience, to be viewed by our clients whom we feel may be interested in engaging your services. 
  • To allow you to subscribe to our "Jobs by Email" service. This service will allow you to receive details of latest jobs via e-mail which are relevant to your sector and professional experience. Where you are sent details of a job via the "Jobs by Email" service, you will be able to unsubscribe from such updates at any time. Please see below "Access to your Personal Information" for further details.
  • To keep you informed of job opportunities and contract assignments which we think may be of interest to you via email and telephone.
  • To carry out our obligations arising from any contracts entered into between you and us. As a result, your information will be accessible to and processed by our recruitment consultants, responsible management, human resources, accounting, audit, compliance, information technology, legal and other corporate staff and selected third party service providers and suppliers, only if they have a legitimate business need to do so;
  • From time to time, we may also use your information to contact you for market research purposes. We may contact you by email, phone, fax or mail. 
  • To preserve our business relationship with you as a user of our website.
  • To notify you about changes to our service.
  • To provide to clients information other than your skills and experience required by our clients (with your consent where this is required by law).

If you are the representative of a prospective customer/client:

  • To contact you with a view to offer our recruitment services to your company;
  • To keep you informed via email or phone of expert IT profiles which could be of interest to your company and match the skills required for your job opportunities.
  • To allow you to subscribe to our newsletter service. This service will allow you to receive details of news and events relevant to you. Where you are sent our newsletter, you will be able to unsubscribe from such updates at any time.
  • To keep you updated about services provided by our third-party business partners which are relevant to your sector. You can opt out at any time from such e-mails.
  • To preserve our business relationship with you as a user of our website.
  • To notify you about changes to our service.
  • To exercise any legal rights (including under contract) we may have against you or your company.

If you are the representative of a current or ex-customer/client or current or ex-supplier:

  • To contact you with a view to offer our recruitment services to your company;
  • To keep you informed via email or phone of expert IT profiles which could be of interest to your company and match the skills required for your job opportunities.
  • To allow you to subscribe to our newsletter service. Where you are sent our newsletter, you will be able to unsubscribe from such updates at any time.
  • To keep you updated about services provided by our third-party business partners which are relevant to your sector. You can opt out at any time from such emails.
  • To carry out our obligations arising from any contracts entered into between your company and us. As a result, your information will be accessible to and processed by our recruitment consultants, responsible management, human resources, accounting, audit, compliance, information technology, legal and other corporate staff and selected third party service providers and suppliers, only if they have a legitimate business need to do so;
  • From time to time, we may also use your information to contact you for market research purposes. We may contact you by email, phone, fax or mail.  You can opt out of this.
  • To preserve our business relationship with you as a user of our website.
  • To notify you about changes to our service.
  • To exercise any legal rights (including under contract) we may have against you or your company.

Other uses we will make of your data

  • Use of our website;
  • To notify you about changes to our service;

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:

  • to administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
  • to improve our site to ensure that content is presented in the most effective manner for you and for your computer;
  • to allow you to participate in interactive features of our service when you choose to do so;
  • as part of our efforts to keep our site safe and secure;
  • to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you;
  • to make suggestions and recommendations to you and other users of our site about goods or services that may interest you or them.

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.

6. HOW DO WE USE PARTICULARLY SENSITIVE PERSONAL INFORMATION?

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.

7. WHO DO WE SHARE YOUR PERSONAL INFORMATION WITH?

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:

  • (where you are a candidate) clients for the purpose of introducing candidates to them and providing information during the recruitment process;
  • (where you are a client) candidates for the purpose of arranging interviews and engagements;
  • clients, business partners, suppliers and sub-contractors for the performance and compliance with obligations of any contract we enter into with them or you;
  • subcontractors and other service providers including email marketing specialists, event organisers, payment and other financial service providers;
  • analytics and search engine providers that assist us in the improvement and optimisation of our site;
  • credit reference agencies, our insurance broker, compliance partners and other sub-contractors for the purpose of assessing your suitability for a role where this is a condition of us entering into a contract with you.

We may also disclose your personal information to third parties:

  • In the event that we sell or buy any business or assets, in which case we will disclose your personal data to the prospective seller or buyer of such business or assets;
  • If a Montreal Associates group entity or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets;
  • If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms of use and other agreements; or to protect the rights, property, or safety of Montreal Associates, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

8. HOW DO WE SAFEGUARD YOUR PERSONAL DATA?

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. 

9. HOW LONG DO WE KEEP YOUR PERSONAL DATA FOR?

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. 

10. HOW CAN YOU ACCESS, AMEND, OR "TAKE BACK" THE PERSONAL INFORMATION THAT YOU HAVE GIVEN US AND WHAT ARE YOUR RIGHTS?

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:

  • Right to object (including where we are relying on legitimate interests or in relation to direct marketing): this right enables you to object to us processing your personal data including where we do so for (i) our legitimate interests, or (ii) for direct marketing purposes.
     
  • Right to withdraw consent: Where we have obtained your consent to process your personal data for certain activities (for example, for our marketing arrangements), you may withdraw this consent at any time and we will cease to carry out the particular activity that you previously consented to unless  there is an alternative lawful reason to permit our continued processing of your data for this purpose in which case we will inform you of this reason

    If your interests or requirements change, you can unsubscribe from part or all of our marketing content (for example Monthly Runners email or our monthly newsletters) by clicking the unsubscribe link in the email, or by updating your preferences through our preference centre via the following link https://r1.dotmailer-surveys.com/e743ae66-4330rpfe.
     
  • Data Subject Access Request:  You may require us to confirm what information about you we are processing and have access to such information.
     
  • Right to rectification: You also have the right to require that we rectify any inaccurate personal data that we hold about you.
     
  • Right to erasure: You have the right to require that we erase your personal data in certain circumstances.
  • Right to restrict processing: You have the right to require that we restrict our processing of your personal data in certain circumstances.
     
  • Right of data portability: If you wish, you have the right in certain circumstances to receive your personal data in a structured, commonly used and machine-readable format and have the right to transmit the data to another controller without hindrance from us.
     

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.
 

11. HOW DO WE STORE AND TRANSFER YOUR DATA INTERNATIONALLY?

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:

  •  between and within Montreal Associates entities (although none are currently outside the EEA);
  • to third parties;
  • to overseas clients – as a candidate, you are always informed via your contract for services of the identity of the client you are providing services to;
  • to clients within your country who may, in turn, transfer your data internationally;
  • to a cloud-based storage provider.

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.

12. WHAT ABOUT THE FUTURE CHANGES TO THIS PRIVACY POLICY?

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.

13. HOW TO CONTACT US ABOUT 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/