Sumo Creative Ltd (We/Us), and any of its subsidiaries/associated companies, are committed to protecting and respecting your privacy.
This notice sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us.
The General Data Protection Regulation (GDPR) (Regulation (EU) 2016/679) is a new regulation which replaces the Data Protection Regulation (Directive 95/46/EC) The Regulation aims to harmonise data protection legislation across EU member states, enhancing privacy rights for individuals and providing a strict framework within which commercial organisations can legally operate.
The UK has now withdrawn from the EU, and the UK Government has continued GDPR in the form of ‘UK GDPR’.
Your rights under GDPR/ UK GDPR are set out in this notice.
Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.
For the purposes of data protection legislation in force from time to time the data controller is Sumo Creative Ltd, Contingent Works, 3 Broadway Buildings, Elmfield Road, Bromley, England, BR1 1LW.
Our nominated representative is Georgie Robe.
Our Contact Details: firstname.lastname@example.org
Who We Are And What We Do
Sumo Creative Ltd is a recruitment agency & recruitment business as defined by the Employment Agencies and Employment Businesses Regulations 2003. We collect the personal data of the following types of people to allow us to undertake our business;
- Prospective and placed candidates for permanent, fixed term and/or temporary roles;
- Prospective, live and previous clients and clients contacts;
- Employees, consultants, temporary workers;
- Supplier contacts (to support our service(s));
- Partner contacts
We collect information about you to carry out our core business and ancillary activities.
Information You Give to Us or We Collect About You
This is information about you that you give us by filling in forms on our site www.sumo.london (our site) or by corresponding with us by e-mail, phone, social networks or otherwise. It includes information you provide to us when you register using our site, to enter our database, subscribe to our services, attend our events, converse with us on social media, enter any competitions we may run, promotions or surveys, and when you report a problem with our site or social media platforms/profiles.
The information you give us or we collect about you may include your name, address, private and business e-mail address, private and business phone number, financial information, employment history and associated dates, compliance information, compliance documentation, references, your qualifications, compensation history, a log of communications with you, links to your work portfolios, links to your professional social media profiles available in the public domain e.g. LinkedIn, Twitter, Facebook, Instagram, TikTok or corporate website.
Information We Obtain From Other Sources
This is information we obtain about you from other sources such as LinkedIn, corporate websites, job board websites, online CV libraries, your business card and personal recommendations. In this case we will inform you, by sending you this privacy notice, within a maximum of 30 days of collecting the data of the fact we hold personal data about you, the source the personal data originates from and whether it came from publicly accessible sources, and for what purpose we intend to retain and process your personal data.
We regularly work closely with third parties including business partners, professionals in technical, professional, payment and other services, advertising networks, search information providers, credit reference agencies, professional advisors, HMRC, legal advisors, previous employers, and background checks companies. We may receive information about you from them for the purposes of our recruitment services and ancillary support services including pre-employment screening.
Purposes Of The Processing And The Legal Basis For The Processing
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 you with information about other goods and 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 legal basis for the processing of personal data is our legitimate business interests, described in more detail below, although we will also rely on contract, legal obligation and consent for specific uses of data
- We will rely on 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 legal obligation if we are legally required to hold 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 Business Interests
Our legitimate interests in collecting and retaining your personal data is 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 need to record the personal data of prospective candidates and client contacts. Your personal data may be used for marketing purposes (email) to keep you informed about related industry articles and news, career advice, surveys, events, services and activities.
Should we want or need to rely on consent to lawfully process your data we will request your consent orally, by email or by an online process for the specific activity we require consent for and record your response on our system. Where consent is the lawful basis for our processing you have the right to withdraw your consent to this particular processing at any time.
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 this 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.
Disclosure Of Your Information Inside And Outside Of The EEA
We will share your personal information with:
Any employee of Sumo Creative Ltd both inside the EEA and outside of the EEA
Selected third parties, including:
- clients for the purpose of introducing candidates to them and arranging interviews;
- candidates for the purpose of arranging interviews and engagements;
- clients, business partners, suppliers and sub-contractors for the performance and compliance obligations of any contract we enter into with them or you;
- subcontractors including event organisers, payment and other financial service providers
- advertisers and advertising networks that may require the data to select and serve relevant adverts to you and others. We do not disclose information about identifiable individuals to our advertisers, but we will provide them with aggregate information about our users;
- 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 or our client;
- our CRM whose database is stored on a secure server with our CRM provider
We will 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 Sumo Creative Ltd 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 and other agreements; or to protect the rights, property, or safety of Sumo Creative Ltd, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
The lawful basis for the third party processing will include:
- Their own legitimate business interests in processing your personal data, in most cases to fulfil their internal resourcing needs;
- satisfaction of their contractual obligations to us as our data processor;
- for the purpose of a contract in place or in contemplation;
- to fulfil their legal obligations.
Where We Store And Process Your Personal Data
The data that we collect from you may/will be transferred to, and stored at, a destination outside the European Economic Area (”EEA”). It may be transferred to third parties outside of the EEA for the purpose of our recruitment services. It may/will also be processed by staff operating outside the EEA who work for us or for one of our suppliers. This includes staff engaged in, among other things, our recruitment services and the provision of support services. By submitting your personal data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy notice.
All information you provide to us is stored on our secure servers; any information that is stored on our CRM (Customer Relationship Management) software is also secured by a third party.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
Retention Of Your Data
We understand our legal duty to retain accurate data and only retain personal data for as long as we need it for our legitimate business interests and that you are happy for us to do so. We run data routines to remove data that we no longer have a legitimate business interest in maintaining.
We do the following to try to ensure our data is accurate:
- We are currently updating our CRM.
- Prior to making an introduction we check that we have accurate information about you.
- We keep in touch with you so you can let us know of changes to your personal data.
- We segregate our data so that we keep different types of data for different time periods. The criteria we use to determine whether we should retain your personal data includes:
- the nature of the personal data;
- its perceived accuracy;
- our legal obligations;
- whether an interview or placement has been arranged;
- whether we have been in recent contact with you; and
- our recruitment expertise and knowledge of the industry by country, sector and job role.
We may archive part or all of your personal data or retain it on our financial systems only, deleting all or part of it from our main Customer Relationship Manager (CRM) system. We may pseudonymise parts of your data, particularly following a request for suppression or deletion of your data, to ensure that we do not re-enter your personal data on to our database, unless requested to do so.
For your information, Pseudonymised Data is created by taking identifying fields within a database and replacing them with artificial identifiers, or pseudonyms.
You have the right to ask us not to process your personal data for marketing purposes. We will usually inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes and we will collect express consent from you if legally required prior to using your personal data for marketing purposes.
You can exercise your right to accept or prevent such processing by contacting us at email@example.com
Our site may, from time to time, contain links to and from the websites of our clients, partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
The GDPR provides you with the following rights:
- 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) 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.
- 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 in certain formats, if practicable.
- Make a complaint to a supervisory body which in the United Kingdom is the Information Commissioner’s Office. The ICO can be contacted through this link: https://ico.org.uk/concerns/
Right To Withdraw Consent
If you do grant consent, please note that you can withdraw your consent to all or any one of the above purposes at any time by emailing firstname.lastname@example.org
Please note that all processing of your personal data will cease once you have withdrawn consent but this will not affect any personal data that has already been processed prior to this point. Please allow 7 days to process.
Access To Information
The Data Protection Act and UK GDPR give you the right to access information held about you. We also encourage you to contact us to ensure your data is accurate and complete.
Your right of access can be exercised in accordance with the DPA/UK GDPR
A subject access request should be submitted to email@example.com
We may ask you to pay a small amount for photocopies and/or postage but will inform you of this. The information you receive will be within 20 working days, but we may contact you should we require more time to process your request.
Changes To Our Privacy Notice
Any changes we make to our privacy notice in the future will be posted on this page and, where appropriate, notified to you by email. Please check back regularly to see any updates or changes to our privacy notice.
Questions, comments, and requests regarding this privacy notice are welcome. Please get in touch on firstname.lastname@example.org