PRIVACY POLICY

OVERVIEW

1.1 This privacy policy explains how we collect, process and protect your personal data, including any information you submit to our online recruitment software and any information gathered on this website.

1.2 By using this site, you are agreeing to your data will be held, stored and processed according to the policy detailed below. We comply with the UK General Data Protection Regulations (UKGDPR) and Data Protection Act 2018 (DPA) and as such your data is securely stored and only accessed by relevant and authorised personnel.

1.3 The purpose of the collection of personal data and the type of data requested is decided by the Data Controller.

1.4 The Data Controller uses a Data Processor in order to collect, store and securely transfer your data.

Data Controller	Data Processor
eurochange Ltd	Talos360 Ltd
Essex House, Rutherford Close, Stevenage, SG1 2EF	4 Webster Court, Carina Park, Warrington, WA5 8WD
Data Protection Officer: data.controller@eurochange.co.uk	Data Protection Officer: dpo@talos360.co.uk

DATA SECURITY

2.1 The technology that we use has been designed with your security in mind. Our Data Processor’s servers are based in the United Kingdom and European Union, deploying both technological and operational security measures, along with internal policies specifically implemented to protect your data.

LAWFUL BASIS

3.1 Our lawful basis for requesting and processing your data is our duty under legislation (listed below) and must use the information you supply to process your job application and provide you with information that may be of use

1. - Immigration, Asylum and Nationality Act 2006
  - Equality Act 2010
  - Part V of the Protection of Freedoms Act 2012
  - Rehabilitation of Offenders Act 1974
  - Money Laundering and Terrorist Financing (Amendment) Regulations 2019
  - UKGDPR and DPA

3.2 The purpose of our data collection is to assess your suitability for the specific job role that you have applied for. We may also use this information to contact you about other similar job opportunities and may also statistically analyse your data.

3.3 We may also need to request and process your data, if it is necessary for the performance of a contract, or if we have a lawful basis for doing so. This may include the data that you need to supply to us, in order to satisfy the offer of a term of employment.

3.4 If we require your explicit consent to process any data as specified by the UK GDPR, we will inform you of this requirement and request your explicit “opt-in” at the point of data entry.

WHAT DATA DO WE COLLECT?

4.1 The personally identifiable information that we collect, store, and process from you on this site includes (but not limited to):

Your CV
Personal information such as your name, email address, and phone number
Date of birth, country of birth, passport details
Cover letters
Details entered into any application form
Answers to questions regarding your recruitment preferences
Supporting information to expand your candidate profile, such as special category data, in all instances, you are given the option to decline to share with eurochange Ltd:
- - racial or ethnic origin;
  - religius or philosophical beliefs;
  - data concerning health or sex life and sexual orientation;
  - criminal data (convictions and offenses)

YOUR DATA ACCESS RIGHTS

5.1 When it comes to your personal data you have the right to:

Your right of access – You have the right to ask us for copies of your personal information – a Data Subject Access Request (DSAR) can be raised, to obtain copies of the personal information held in recognisable filing systems
Your right to rectification – You have the right to ask us to rectify personal information you think is inaccurate. You also have the right to ask us to complete information that you beleive is incomplete
Your right to erasure (to be forgotten) – You have the right to ask us to erase your personal information in certain circumstances
Your right to restriction of processing – You have the right to object to the processing of your personal information in certain circumstances
Your right to object to processing – You have the right to object to the processing of your personal information in certain circumstances
Your right to data portability – You have the right to ask that we transfer the personal information you gave us to another organisation, or to you, in certain circumstances
Your right to withdraw your consent – You can make changes to your consent for the obtaining and processing of your personal data
Your right to lodge a complaint – If you have concerns about the use of your personal information, you can make a complaint to the data controller by writing to:

Data Protection Officer
Eurochange Ltd
PO Box 435
STEVENAGE
Hertfordshire
SG1 9GA

You can also complain to the UK’s Information Commissioner’s Office (ICO) if you are unhappy with how we have used you data

Information Commissioner’s Office
Wycliffe House
Water Lane
WILMSLOW
Cheshire
SK9 5AF

Helpline number 0303 123 1113

ICO website: https://www.ico.org.uk

AUTOMATED DECISION MAKING

6.1 We currently use some automation within the application process, which is prompted by responses to key questions. In all cases, you will be notified that you can discuss the decision with a member of eurochange’s People Services team, if you wish to understand the reasons for the decision. We will ensure that any automated decision is always reviewed by the business and arbitrated with human intervention.

PROFILING

7.1 Profiling’ is the use of personal information to predict an individual’s behaviour, such as their Personal preferences, interests, location, or use of this system etc.

7.2 Your information may be used for statistical analysis e.g., the use of our sites and apps to understand how applicants use the system and where you use it. We look at what you have viewed on our sites and apps, to better understand what your interests and preferences are, and to improve our communications with you, by making it more relevant to you

SHARING DATA

8.1 The data that you submit to this site will be:

Made available to the Data Controller
Made available to the Data Processor
Used to communicate with you about your application
Used to communicate with you regarding recruitment
Used to supply you with relevant (optional) job alerts
Added to a searchable candidate database
Analysed for our internal statistics to improve processes

8.2 Sometimes information may be processed on our behalf by relevant third parties; this includes but is not limited to: video interviewing companies, payroll software, and HR software.

8.3 We will not collect your information for unrelated purposes without first requesting your consent.

8.4 In some cases, we may be compelled or permitted by law, an official authority, or regulatory requirements to process your personal information without your consent or knowledge, even after you have exercised your right to withdraw, be forgotten, or object to processing. If this happens, we will only process the limited personal data required under these specific circumstances.

BACKGROUND SCREENING

9.1 As part of the background screening process, eurochange Ltd may carry out a background check to determine any criminal history relating to yourself and your Right-to-Work in the UK.

9.2 eurochange Ltd utilises Certn (formally Credence) to process and collect criminal records information, to validate addresses, conduct credit and Fit and Proper (FCA) checks.

9.3 eurochange Ltd utilises Yoti to process digital right to work in the UK checks.

9.4 Your personal information may be used to gather information regarding:

Cautions
Conditional cautions
Reprimands
Spent conviction
Unspent convictions
Warning
Any other relevant information from the local police force

9.5 When eurochange Ltd requests Certn to supply information which they source from the UK’s Disclosure & Barring Service (“DBS”), Disclosure Scotland (“DS”) and/or AccessNI (“ANI”), eurochange Ltd warrants that it will:

Observe and fully comply with the DBS / DS / ANI Code of Practice
Only request the standard, enhanced or Protecting Vulnerable Groups (PVG) checks for roles that meet the appropriate legislation
Make all Candidates aware of the DBS / DS / ANI Code of Practice at the start of the recruitment process and make a copy available to any Candidate on request
Include a statement on its application forms or accompanying documentation that DBS / DS / ANI information on the Candidate will be requested in the event of the Candidate being offered a position
Comply with its legal requirements for the secure storage, handling, retention and disposal of information which Certn sources from the DBS / DS / ANI
Ensure that identity validation of Candidates is undertaken in accordance with DBS / DS / ANI guidelines
Confirm that Certn plays no part in the recruitment decision

LENGTH OF DATA STORAGE

10.1 If there is no activity on your candidate account for 1 year, it will be deactivated. You can also request to withdraw your details at any time and thereafter your data will be fully anonymised for further protection.

PRIVACY POLICY CHANGES

11.1 We reserve the right to update this privacy notice at any time, and we will provide you with a new privacy notice when we make any substantial changes. We may also notify you in other ways from time to time about the processing of your personal data.

COOKIES

Cookies are used to store small amounts of information on your computer, which allows certain information from your web browser to be collected.

Cookies are widely used on the internet and do not identify the individual using the computer, just the computer being used. Cookies and other similar technology, make it easier for you to log on to, and use our websites, during future visits, and some are essential to facilitate our online applicant tracking system.

By using and browsing our websites, you consent to cookies (where appropriate) being used in accordance with eurochange Ltd’s Cookies Notice. If you do not consent, you can disable cookies, or stop using the website/system. You can disable cookies through browser settings
When you use affiliate sites, we will track your details to enable us to meet our contractual obligations to our service providers and to assess your response to advertising campaigns
To ensure that you are provided with the relevant information, to make an informed decision, we will use a third party system (Cookiebot), to give details of what Cookies categories, have been designated and how to manage your consent for their use

What Type of Cookies We Use

This website only uses strictly necessary cookies to help make a website usable by enabling basic functions. The website cannot function properly without these cookies and are therefore designated as necessary by default:

Name	Provider	Purpose	Expiry	Type
ARRAffinity	Microsoft	This cookie is used for load balancing to ensure our servers do not become overloaded by requests by distributing workload	When your session ends	Affinity
ARRAffinitySameSite	Microsoft	This cookie is used for load balancing to make sure the visitor page requests are routed to the same server in any browsing session	When your session ends	Affinity