Privacy

We take your trust in us SERIOUSLY...

Recruitment.bm is representative of Stephanie Brown, a Consultant employed by a Bermudian owned and operated company called O My Word Ltd., and who focuses on offering Recruitment related services.  We are committed to protecting your privacy and the privacy of information provided. We do not share your personal information with any third parties unless their involvement is critical to our services and expressed consent has been obtained.

 

We engage best practice security measures to protect information from unauthorized access.

 

Recruitment.bm is committed to processing data in accordance with its responsibilities under the applicable laws and regulations.

 

What does this Privacy Statement do?

This statement explains Recruitment.bm information processing practices. It applies to any personal information you provide to Recruitment.bm and any personal information we collect from other sources.

 

This is a statement of our practices and of your rights regarding your personal information.

 

Who is responsible for your personal information?

The Data Controller determines the purposes for which and the means by which personal data is processed. The Data Processor processes personal data only on behalf of the Data Controller.

 

This may also be explained in separate privacy notices made available when your personal information is first collected by Recruitment.bm (i.e. privacy notice may be provided when you or your employer engages Recruitment.bm to provide a service).

 

Definition of Controller and Processor

General Data Protection Regulation (“GDPR”) defines a controller as: the natural or legal person, public authority, agency or other body which, alone or jointly with other, determines the purposes and means of the processing of personal data.

 

‘Processor’ means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.

 

When and how do we collect your information?

Recruitment.bm collects personal information in numerous different ways, depending on the service engaged.

 

For Recruitment Services:

  1. When you use our website;

  2. When you attend an employment search event;

  3. When you reply to a recruitment advertisement;

  4. When you engage with us over social media;

  5. When you engage in an interview;

  6. When we engage in dialogue with your employment or character references;

  7. When engaging third parties offering independent verifications.

 

What information do we collect?

Information you provide to us

 

When you engage Recruitment.bm for services, we ask that you provide accurate and necessary information that enables us to respond to your service request. When you provide personal information to Recruitment.bm, I use it for the purposes for which it was provided as stated at the point of collection or as obvious from the context of collection.

In order to represent a candidate, we require the following information from you:

  1. Your contact information [full name including all past and present aliases, address(es), phone number(s), email address(es)];

  2. Your résumé/CV (and any updates thereof);

  3. Proof of Bermuda immigration status / nationality;

  4. Copies of any qualifications / certifications you claim to have obtained, either in your resume or in conversation;

  5. Reference contact details (name, business name, business address, business telephone number, your relationship with them and their position within the business). We assume that, before providing us with any contact details for your references, you have obtained their permission to do so;

 

In using our services, we may also ask you to provide the following additional information:

  1. Criminal / Credit background checks;

  2. Social insurance, payroll tax or health insurance related information;

  3. Bank account details (to receive payment for contract work);

Interview notes will also form part of the information we have on file about you.

 

Information we collect from clients or third parties

 

For Recruitment services, we may collect the following:

  1. Job descriptions;

  2. Information obtained through reference and background checks.

  3. Company documents like handbooks and onboarding material.

 

Information we collect over Recruitment.bm website

 

We may ask you for some or all the following types of information when you make an inquiry.

 

This includes, but is not limited to:

  1. Contact information such as name, e-mail address, postal address, telephone number(s);

  2. Immigration status;

  3. Work disciplines and industries of interest;

  4. Résumé;

 

How do we use your personal information?

The following is a summary of the purposes for which we use personal information.

 

Performing services for our clients

We process personal information which our clients provide in order to perform our professional services. This may impact you, for example, where you are the employee of our client. The precise purposes for which your personal information is processed will be determined by the scope of our client engagement. It is the obligation of our client to ensure that you understand that your personal information will be disclosed to Recruitment.bm.

  

We will use your personal information to assess your suitability for an employment opportunity based on:

  1. Your qualifications,

  2. Your work experience;

  3. Your assessment results;

  4. Your Bermuda immigration status / ability to be employed in the relevant jurisdiction;

  5. Work requirements, desires and other factors.

 

Administering our client engagements

We process personal information about our clients and the individual representatives of our clients in order to:

  1. Carry out client screening prior to commencing a new relationship;

  2. Carry out client communication, service, billing and administration;

  3. Deal with client service delivery matters.

 

Contacting and marketing our clients and prospective clients

We process personal information about our clients and the individual representatives of our clients to:

  1. Contact our clients in relation to current, future and proposed engagements;

  2. Invite our clients to events.

 

Legal basis

The processing of your personal information is supported by a lawful basis.

 

  1. If you are a job seeker, we will use your consent as the basis for processing your personal information;

  2. If you are a client that requires my services to fill an open position, I will use legitimate commercial interest delivery of my services in terms of a contract you may not be party to, as the basis for processing your personal information.

  

Before collecting and/or using any special categories of data, or criminal record data, we will establish a lawful exemption which will allow us to use that information. This exemption will typically be your explicit consent.

 

Do we collect information from children?

Our website is not directed to children and we do not knowingly collect personal information from children on our websites.

 

How long do we retain your personal information?

We may keep a record of your Personal Information, correspondence or comments in a file specific to you.  We will use, disclose or retain your Personal Information for as long as necessary to fulfill the purposes for which that Personal Information was collected, or as permitted or required by law.

 

Do we disclose your personal information?

We do not share your personal information with third parties except in the circumstances outlined below.

 

Authorized Service Providers

We may disclose your information to service providers we have engaged (as data processors) to perform services on our behalf. These service providers are contractually restricted from using or disclosing the information, except as necessary to perform services on our behalf or to comply with legal requirements.

 

These activities could include any of the processing activities that we carry out as described in the above section, ‘How we use your personal information.’

 

Examples include:

  1. IT service providers who manage our IT platform and telecommunications networks;

  2. Independent verification providers (i.e. credit check, police checks, background checks etc.).

 

These third parties appropriately safeguard your data, and their activities are limited to the  purposes for which your data was provided.

Legal Requirements

Recruitment.bm may disclose personal information in the following instances:

  1. If we are required to do so by law, regulation, or to respond to a subpoena, search warrant, or other legal request;

  2. In response to law enforcement authority or other government official requests;

  3. When we believe disclosure is necessary or appropriate to prevent physical harm or financial loss;

  4. In connection with an investigation of suspected or actual illegal activity.

 

Do we transfer your personal information across geographies?

Recruitment.bm currently operates in Bermuda, however may transfer personal information across geographical borders to group entities or authorized service providers in other countries working on our behalf.

 

We use legal mechanisms to ensure your rights and protections follow your personal information:

  1. We ensure transfers within Recruitment.bm are covered by agreements, which contractually place an obligation to ensure that personal information receives an adequate and consistent level of protection wherever it resides within Recruitment.bm;

  2. Where we transfer your personal information outside Recruitment.bm or to third parties we obtain contractual commitments from them to protect your personal information;

  3. Where we receive requests for information from law enforcement, regulators or government agencies, we work to validate such requests before any personal information is disclosed.

Countries where we transfer personal information may include, but are not limited to, Bermuda, the United States of America, Canada and the United Kingdom.

 

Do we have security measures in place to protect your information?

Recruitment.bm has implemented a range of internal controls to protect your personal information. These internal controls are supported by policies approved, implemented and monitored by Management.

 

We have implemented strong physical and logical access controls to prevent unauthorized access to your personal information. The computers and server equipment on which your personal information is stored are kept in a secure environment.

 

When we collect sensitive information, this information is encrypted and transmitted to us in a secure way using our encrypted portal or encrypted email. Requests for sensitive information by your employer are also directed through the encrypted portal or encrypted email.

 

How can you update your communication preferences?

We take reasonable steps to provide you with communication about your information. You can update your communication preferences in the following ways.

 

E-mail

Contact us by e-mail as noted below. Please include your current contact information, the information you are interested in accessing and your requested changes. If we do not provide you with access, we will provide you with the reason for refusal and inform you of any exceptions relied upon.

 

Rights relating to your data

 

Right to Access, Rectification, Restriction and Objection

Upon request, you shall be informed of the existence, use and disclosure of your personal data, and shall be given access to it. You may verify the accuracy and completeness of your personal data, and may request that it be amended, if appropriate. Should you believe that your information is being used for purposes other than in the carrying out of recruitment services, you have the right to request the restriction of such processing.

 

Contact us at the email address disclosed at the end of this Privacy Notice.

Summary information is available on request and we will attempt to respond to the request within 30 days of receipt. More detailed requests which require archive or other retrieval costs may be subject to my normal professional and disbursement fees and may take longer to respond to.
 

Right to Withdraw Consent

Your knowledge and consent are required for the collection, use or disclosure of your personal data, except where inappropriate or permitted by law. Depending on the sensitivity of the information, this consent can be implied or expressed; however, wherever commercially feasible Recuitment.bm shall attempt to obtain express consent. Consent to our use of personal data can be withdrawn at any time by contacting the Data Privacy Officer in writing and following the directions at the end of this Privacy Notice.

  

Right to be Forgotten

You have the right under certain circumstances to have your personal information erased. Your information can only be erased if your data is no longer necessary for the purpose for which it was collected, and we have no other legal ground for processing the data.

  

Right to Data Portability

You have the right to data portability, which requires us to provide personal information to you or another controller in a commonly used, machine readable format, but only where the processing of that information is based on (i) consent; or (ii) the performance of a contract to which you are a party.

 

Right to Lodge a Complaint

We hope that we can resolve any query or concern that you may have raised about our use of your information.

 

The General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred.

 

The supervisory authority in the UK is the Information Commissioner who may be contacted at https://ico.org.uk/make-a-complaint.

The supervisory authority in Bermuda is the Privacy Commissioner who may be contacted at privcom@privacy.bm

  

International Transfers

As noted above, you can ask to obtain a copy of, or reference to, the safeguards under which your personal information is transferred outside of the European Union.

How policy changes will be communicated

Our policy notice will be posted on our website at www.recruitment.bm  We will notify you of changes by posting the revised policy on the aforementioned webpages. Any policy revisions are effective immediately upon posting on the webpage.

 

We have the right to make changes to this policy at any time and advise that you regularly review this policy. If you object to any changes, please direct your comments your local privacy authority (refer “Right to Lodge a Complaint” section).

How to address concerns with respect to use of personal data

Should you have any questions or concerns about this policy or any concerns over misuse of personal data, please contact us:

Email: steph@recruitment.bm

Data Privacy Officer: Steph Brown

 

This statement was last updated on 13 July, 2020.