Privacy policy

This policy describes how we use your personal data when you use our website or when we provide services to you. We have provided this policy to ensure that you understand what personal data we may collect and hold about you, what we may use it for and how we keep it safe. You have legal rights to access the personal data that we hold about you and to control how we use it, which are also explained.

You can read, print and save this whole policy or click on the links below to see to help you see specific information about:

• Who we are and how you can contact us
• Our GDPR Owners
• What personal data we collect about you
• What we use your personal data for
• Cookies
• When we need your consent to use your personal data
• Personal data you are legally obliged to provide
• Your rights to know what personal data we hold and to control how we use it
• Automated decision making and profiling
• When we will share your personal data with others
• How we keep your personal data safe
• How we use your personal data for marketing
• When we will send your personal data to other countries
• How long we keep your personal data
• How you can make a complaint
• How we keep this policy up to date

Who we are and how you can contact us

Migrate is part of the Sanctuary Personnel Group.

We are a division of Sanctuary Personnel Limited, a private company limited by shares with company number 05972910. Our registered office address is 15 Friars Street, Ipswich, Suffolk IP1 1TD.

You can contact us at the above address or by e-mailing info@sanctuarypersonnel.com. If you would like to speak to us call us on 0333 7000 020.

Please refer to the sections on Data Protection Representatives, your rights to know what personal data we hold and to control how we use it and How to make a complaint for further contact information.

Our GDPR owners

We have appointed Data Protection Representatives who oversee our handling of personal data.

You can contact our Data Protection Representatives at 15 Friars Street, Ipswich, Suffolk IP1 1TD or by email at gdpr@sanctuarypersonnel.com or by calling 0333 7000 020.

Cookies

Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and allows us to improve our website. For detailed information on the cookies we use and the purposes for which we use them see our Cookie policy.

What personal data we collect about you

We collect:

• Personal data that you provide to us. There are lots of ways in which you may share your personal data with us, for example, you may register on our website or the App, post on social media sites that we run, or contact us in connection with services that you would like to receive, or have already received, from us. The personal data that you provide to us may include your name, address, e-mail address and phone number, financial and credit card information. In connection with an application for work with us, we will collect, store and use the following information; age/date of birth, sex/gender, marital status, education details, employment history, emergency contacts, referee details, immigration status (whether you need a work permit), nationality/citizenship/place of birth, copies of photographic ID documents (driving licence, passport, identity card), social security number (or equivalent) and tax-related information, diversity information (including racial or ethnic origin, religious or other beliefs, physical or mental health, details of any disabilities), details of any criminal convictions (if required by the role for which you apply), information related to your interests and needs regarding future employment and additional information that you choose to tell us, whether in a curriculum vitae and accompanying correspondence, or in any form you complete, information about skills, qualifications, employment history, expectations and current roles, languages spoken, any information you provide to us or potential recruiters using the App, including any communication or chat functions.
• Personal data that we receive from third parties. If we work with other businesses or use sub-contractors these parties may collect personal data about you which they will share with us. These will include organisations for whom you have provided services on an agency or other basis after we have put you in touch with such organisations. For example, we may receive details of your credit history from credit reference agencies or obtain your name and contact details from job boards that refer you to us so that we can provide you with our services or receive feedback from a sub-contractor for whom you have worked on an agency basis.
• We may also collect personal data from recruitment agencies, background check providers, the Disclosure and Barring Service in respect of criminal convictions (where we are lawfully allowed to use the service), and your named referees.
• Personal data about your use of our website and App. This is technical information and includes details such as your IP address, your login information, browser type and version, time zone setting and browser plug-in types and versions, operating system and platform, as well as details of how you navigated to our website and what pages or services you viewed or searched for, page response times, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and any phone number used to call our customer service number.

What we use your personal data for

We use your personal data in the following ways:

• personal data that you provide to us is used to:

  • provide you with the information, products and services that you request from us on our website or the App;
  • provide you with marketing information in accordance with your marketing preferences (see How we use your personal data for marketing);
  • manage and administer our business;
  • review and improve our service; and,
  • (in the case of a job application via our website), assess your skills, qualifications and suitability for the work, to carry out background checks, to communicate with you about the recruitment process, to keep records relating to our hiring process and to comply with legal or regulatory requirements; and
  • register you as a new App user, and to process your activities using the App by providing the necessary functionality.

• personal data that we receive from third parties is combined with the personal data that you provide to us and used for the purposes described above.

• personal data about your use of our website and the App is used to:

  • administer our website and the App and for internal operations including troubleshooting, data analysis, testing, research, statistical and survey purposes;
  • to improve our website and the App to ensure that content is presented in the most effective manner for you and for your computer or mobile device;
  • 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 and App safe and secure;
  • to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you; and
  • to make suggestions and recommendations to you and other users of our site and the App about services that may interest you or them.

When we need your consent to use your personal data

Whilst we always want you to be aware of how we are using your personal data, this does not necessarily mean that we are required to ask for your consent before we can use it. In the day to day running of our business, we may use your personal data without asking for your consent because:

We are entering into and carrying out our obligations under a contract with you; and we need to use your personal data for our own legitimate purposes (such as the administration and management of our business or for the improvement of our services or deciding whether to enter into a contract of employment with you) and our doing so will not interfere with your privacy rights.

In exceptional circumstances, we may wish to use your personal data for a different purpose which does require your consent. In these circumstances, we will contact you to explain how we wish to use your data and to ask for your consent. You are not required to give consent just because we ask for it. If you do give consent you can change your mind and withdraw it later.

Please refer to the section on How we use your personal data for marketing to read about marketing consents.

Personal data you are legally obliged to provide

You are not under a legal obligation to provide us with any of your personal data but please note that if you elect not to provide us with your personal data we may be unable to provide our services to you or to process your application successfully.

Your rights

You have a legal right to know what personal data we hold about you - this is called the right of subject access. You can exercise this right by completing this form, by sending us a written request at any time or by calling us on 0333 7000 020. Please mark your correspondence "Subject Access Request" and send it to our GDPR Owners (see the section on Our GDPR Owners for contact details).

You also have rights to:

• prevent your personal data being used for marketing purposes (see How we use your personal data for marketing for further details);
• have inaccurate personal data corrected, blocked or erased;
• object to decisions being made about you by automated means or to your personal data being used for profiling purposes;
• object to our using your personal data in ways that are likely to cause you damage or distress;
• in certain circumstances you may have the right to restrict our use of your personal data;
• require that we delete your personal data; and
• require that we provide you, or anyone that you nominate, with a copy of any personal data you have given us in a structured electronic form such as a CSV file.
• You can find full details of your personal data rights on the Information Commissioner’s Office website at www.ico.org.uk.

Automated decision making and profiling

Automated decision-making is when an electronic system uses personal information to make a decision without human intervention. We are allowed to use automated decision-making where it is necessary to perform the contract with you and appropriate measures are in place to safeguard your rights. We use recruitment data (such as qualifications, experience job hunting status, location and languages spoken (if relevant)) in automated decision making to match candidates with roles on the App, although we do not use special categories of data for this purpose. The App does not match candidates with roles using traditional means involving Migrate personnel. The App’s platform, pricing and business model are based on that approach. Therefore it is necessary for our contract with candidates to apply automated decision making in matching candidates with potential recruiters. If we make an automated decision on the basis of any special categories of personal information, we must have either your explicit written consent or it must be justified in the public interest, and we must also put in place appropriate measures to safeguard your rights. We do not currently use special categories of data as part of our automated decision making processes.

When we will share your personal data with others

We share your data with the following people in the day-to-day running of our business:

• other companies that are part of the Sanctuary group;
• any business partners, suppliers and sub-contractors we work with to provide you with goods or services that you have requested from us;
• individuals and organisations who hold information related to your reference or application to work with us, such as current, past or prospective employers, educators and examining bodies and employment and recruitment agencies;
• tax, audit, or other authorities, when we believe in good faith that the law or other regulation requires us to share this data (for example, because of a request by a tax authority or in connection with any anticipated litigation);
• third party service providers who perform functions on our behalf (including external consultants, business associates and professional advisers such as lawyers, auditors and accountants, technical support functions and IT consultants carrying out testing and development work on our business technology systems);
• third party outsourced IT and document storage providers where we have an appropriate processing agreement (or similar protections) in place;
• individuals and organisations who hold information related to your reference or application to work with us, such as current, past or prospective employers and recruitment agencies;
• potential employers and other recruitment agencies and organisations to increase your chances of finding employment;
• third party partners, job boards and job aggregators where we consider this will improve your chances of finding employment;
• third parties who we have retained to provide services such as reference, qualification and criminal convictions checks, to the extent that these checks are appropriate and in accordance with local laws;
• advertisers and advertising networks (see How we use your personal data for marketing for more information);
• analytics and search engine providers that assist us in the improvement and optimisation of our site; and
• credit reference agencies for the purpose of assessing your credit score where this is a condition of us entering into a contract with you.

If you have an account with us, we may share the information submitted under your account among all of our services in order to provide you with a seamless experience and to improve the quality of our services. We will not disclose your account information to other non-affiliated persons except in the limited circumstances authorised in this policy, or with your consent.

We may also share your personal information with third parties on a one-off basis, for example, if:

• we sell or buy any business or assets (including our own), in which case we will disclose your personal data to the prospective seller or buyer of such business or assets; or
• 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 website terms of use or our terms and conditions of supply and other agreements; or to protect the rights, property, or safety of our customers, ourselves or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

How we keep your personal data safe

We take every care to ensure that your personal data is kept secure. The security measures we take include:

• only storing your personal data on our secure servers and third-party systems that meet our security recommendations;
• encrypting any payment transactions made through our website using SSL technology;
• ensuring that our staff receive regular data security awareness training;
• keeping paper records to a minimum and ensuring that those we do have are stored in locked filing cabinets on our office premises;
• maintaining up to date firewalls and anti-virus software to minimise the risk of unauthorised access to our systems; and,
• enforcing a strict policy on the use of mobile devices and out of office working.

Please remember that you are responsible for keeping your passwords secure. If we have given you (or you have chosen) a password which enables you to access certain parts of our website or the App, you are responsible for keeping this password confidential. Please do not share your passwords with anyone.
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Unfortunately, sending 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 personal data sent to our website; you send us personal data at your own risk. Once we have received your personal data, we will use strict procedures and security features (some of which are described above) to try to prevent unauthorised access.

How we use your personal data for marketing

We will add your details to our marketing database if:

• you make an enquiry about our services; or
• you buy our services; or
• you have told a third party that you would like them to pass us your contact details so that we can send you updates about our services; or
• you have registered an account on our website or the App and have indicated during the sign-up process that you are happy to receive marketing communications.

We may send you marketing communications by e-mail, telephone, or text message.

You can ask us to only send you marketing communications by particular methods (for example, you may be happy to receive e-mails from us but not telephone calls), about specific subjects (for example social care) or you may ask us not to send you any marketing communications at all.

We may ask you to indicate your marketing preferences when you first register an account on our website or the App. You can check and update your current marketing preferences at any time by logging into your account on our website or calling or e-mailing us using the details set out in the Who we are and how you can contact us section above.

We never share your personal data with third parties for marketing purposes.

When we will send your personal data to other countries

Your personal data may be transferred to, and stored at, a destination outside the European Economic Area ("EEA") by us or by our sub-contractors. Where we, or our sub-contractors, use IT systems or software that is provided by non-UK companies, your personal data may be stored on the servers of these non-UK companies outside the EEA. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy.

How long we keep your personal data

We only keep your personal data for as long as we actually need it. In practice this means that we will keep:

• We will delete your personal data from our systems if we have not had any meaningful contact with you (or, where appropriate, the company you are working for or with) for two years (or for such longer period as we believe in good faith that the law or relevant regulators require us to preserve your data). After this period, it is likely your data will no longer be relevant for the purposes for which it was collected.
• For those candidates whose services are provided via a third-party company or other entity, "meaningful contact" with you means meaningful contact with the company or entity which supplies your services. Where we are notified by such company or entity that it no longer has that relationship with you, we will retain your data for no longer than two years from that point or, if later, for the period of two years from the point we subsequently have meaningful contact directly with you.
• When we refer to "meaningful contact", we mean, for example, communication between us (either verbal or written), or where you are actively engaging with our online services. If you are a candidate, we will consider there to be meaningful contact with you if you submit your updated CV onto our website or the App or take part in any of our online training. We will also consider it meaningful contact if you communicate with us about potential roles, either by verbal or written communication or click through from any of our marketing communications. Your receipt, opening or reading of an email or other digital message from us will not count as meaningful contact – this will only occur in cases where you click-through or reply directly.

Please note that we may anonymise your personal data or use it for statistical purposes. We keep anonymised and statistical data indefinitely, but we take care to ensure that such data can no longer identify or be connected to any individual.

How you can make a complaint

If you are unhappy with the way we have used your personal data, please contact our GDPR Owners to discuss this using the contact details set out in the Who we are and how you can contact us section above.

You are also entitled to make a complaint to the Information Commissioner’s Office which you can do by visiting www.ico.org.uk. Whilst you are not required to do so, we encourage you to contact us directly to discuss any concerns that you may have and to allow us an opportunity to address these before you contact the Information Commissioner’s Office

How we keep this policy up to date

We will review and update this policy from time to time. This may be to reflect a change in the services we offer or to our internal procedures or it may be to reflect a change in the law.

The easiest way to check for updates is by looking for the latest version of this policy on our website (http://migratehr.com) or you can contact us (see Who we are and how to contact us) to ask us to send you the latest version of our policy.

Each time we update our policy we will update the policy version number shown in the footer and at the end of the policy and the date on which that version of the policy came into force.

This is policy version 2 which came into effect on 27 August 2021.