Cookies and Privacy Policy
Date of last revision: 30 April 2018
NAKAMA Group plc and its subsidiaries are committed to protecting and respecting your privacy. We want to provide a safe and secure user experience. We will ensure that the information you submit to us via our website or through any of our locations is only used for the purposes set out in this policy.
Data controller and owner
NAKAMA Group plc, 33/45 Quadrant House, Croydon Road, Caterham, Surrey CR3 6PB
Owner contact email: GDPR@nakamaglobal.com
What are my rights?
You are entitled to request access to any personal data concerning you which is held by NAKAMA Group plc. To do this, you should make a request either written or via email known as a “subject access request” to the Data Protection Officer. We will aim to provide you with or give access to the information within 30 days of the request. There may however be circumstances in which we cannot release information, for example, where it contains personal data about another employee or third party.
Under the GDPR (General Data Protection Regulation), data subjects have the following rights:
• The right to be informed about our collection and use of personal data;
• The right of access to the personal data we hold about you;
• The right to rectification if any personal data we hold about you is inaccurate or incomplete;
• The right to be forgotten – i.e. the right to ask us to delete any personal data we hold about you;
• The right to restrict (i.e. prevent) the processing of your personal data;
• The right to data portability (obtaining a copy of your personal data to re-use with another service or organisation);
• The right to object to us using your personal data for particular purposes;
• Rights with respect to automated decision making and profiling; and
• Make a complaint to a supervisory authority, which is the Information Commissioner’s Office in the UK
What if I do not agree with this Privacy Policy?
If you do not agree to our processing of your data in the manner outlined in the Policy, please do not submit any personal data to us.
Who is the controller of the data that you provide to us?
NAKAMA Group plc is registered as a data controller in the United Kingdom for the purposes of the Data Protection Act 1998. We ensure that the data you supply to us is processed fairly and lawfully and with skill and care and used only for the purposes set out in this policy.
What information will we collect and how will we use it?
We will collect data about you, both personal data (such as your name and contact details) and also sensitive personal data (such as information in your CV and/or cover letter). The personal data and sensitive personal data will be stored, processed, used and disclosed by us in the following ways:
• To provide our recruitment services to you and to facilitate the recruitment process;
• To assess data about you against vacancies which we judge may be suitable for you;
• To send your information to clients in order to apply for jobs or to assess your eligibility for jobs;
• To enable you to submit your CV, apply online for jobs or to subscribe to alerts about jobs we think may be of interest to you;
• To market our full range of recruitment services to you (permanent, contract and recruitment process outsourcing services);
• To enable us to develop and market other products and services and where you have consented to being contacted for such purposes;
• To improve our customer service and to make our services more valuable to you (including tailoring our website and our group companies websites when you log on to enrich your personal online experience);
• To send you details of reports, promotions, offers, networking and client events and general information about the industry sectors which we think might be of interest to you where you have consented to being contacted for such purposes;
• To answer your questions and queries;
• To third parties where we have retained them to provide services that we, you or our client have requested including references, qualifications and criminal reference checking services, verification of the details you have provided from third party source, psychometric evaluation or skill test;
• To third parties, regulatory or law enforcement agencies if we believe in good faith that we are required by law to disclose it relation to the detection of crime, the collection of taxes or duties, in order to comply with any applicable law or order of a court of competent jurisdiction, or in connection with legal proceedings;
• To use your information on an anonymised basis to monitor compliance with our equal opportunities policy; and
• To carry out our obligations arising from any contracts entered into between you and us
Occasionally we may ask for your consent to process, use or disclose your information for other purposes not listed above.
We reserve the right to transfer your information to a third party in the event of a sale, merger, liquidation, receivership or transfer of all or substantially all of the assets of our company provided that the third party agrees to adhere to the terms of this Privacy Policy and provided that the third party only uses your Personal Data for the purposes that you provided it to us. You will be notified in the event of any such transfer and you will be afforded an opportunity to opt-out.
What types of data are collected?
The types of data collected from users can vary from personal to non-personal data.
The types of data we collect are:
• Forename;
• Surname;
• Age/date of birth;
• Birth number;
• Sex/gender;
• Photograph;
• Marital status;
• Contact details including email address;
• Education details;
• Employment history;
• Emergency contacts and details of any dependents;
• Referee details;
• Immigration status including a valid work permit;
• Nationality/citizenship/place of birth;
• A copy of your driving licence and/or passport/identity card;
• Financial information (where we need to carry out financial background checks);
• National insurance number (or equivalent in your country) and any other tax-related information;
• Diversity information including racial or ethnic origin, religious or other similar beliefs, and physical or mental health, including disability-related information;
• Details of any criminal convictions if this is required for a role that you are interested in applying for;
• Details about your current remuneration, pensions and benefits arrangements;
• Information on your interests and needs regarding future employment, both collected directly and inferred, for example from jobs viewed or articles read on our website;
• Extra information that you choose to tell us;
• Extra information that your referees chooses to tell us about you;
• Extra information that our Clients may tell us about you, or that we find from other third party sources such as job sites;
• IP address; and
• The dates, times and frequency with which you access our services
Please note this list is non-exhaustive.
Where will my information be held and where will it be accessible from?
The personal information that you provide to us (including sensitive personal information) may be accessible by other NAKAMA Group plc subsidiaries located in the United Kingdom, Hong Kong, Singapore, Sydney and Melbourne, clients and the third parties specified above. Some of these NAKAMA Group plc companies, clients and third parties are located outside of the European Economic Area (EEA). Accordingly your personal information will be sent to or be capable of being accessed from outside the European Economic Area. When we transfer your personal information outside the European Economic Area we will take steps with the aim of ensuring that your privacy rights continue to be protected as outlined in this Privacy Policy.
How do I find out what information you hold? Can I amend, modify or require my information to be deleted? Can I unsubscribe to your services?
You may request us to confirm what information we hold about you at any time and may request us to modify, update or delete such information. We may ask you to verify your identity and for more information about your request. Where we are legally permitted to do so, we may refuse your request and will give you reasons for doing so. We will seek to act on your request in the timescale required by applicable data protection laws.
You may request to unsubscribe from job alerts and marketing material at any time. If you wish to contact us in regard your personal data, please email us at GDPR@nakamaglobal.com.
How long will you hold my information for?
We are required by law to hold your information for as long as is necessary to comply with our statutory and contractual obligations and in accordance with our legitimate interests as a data controller. The information will be held for as long as is necessary for its purpose and after a maximum of 6 years from our last reasonable contact it will be destroyed entirely whatever its format. We will use reasonable endeavours to ensure that your Personal Data is maintained and up to date. However, you are under a duty to inform us of any and all changes to your Personal Data to ensure that it is up to date and we will update or delete your Personal Data accordingly.
NAKAMA Group plc is obliged to keep candidate and contractor information for a maximum of 6 years from the date of last reasonable contact.
Sending us information over the internet
Your information is held on servers hosted by us or our Internet Services Provider. 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.
How we collect and aggregate information about visitors to our websites
We also collect information about the way job seekers and visitors use this website in order to improve our services. We do not use information gained in this manner in a way that any individual can be identified, and will use it to understand our users better, and to determine aggregate trends, most popular pages, etc, for all the website’s users. We may share this kind of aggregate data with selected third parties to assist with these purposes where you have consented to this. We may also undertake marketing profiling to help us identify services or jobs which may be of interest to you.
Cookies
1. What are cookies?
A "cookie" is a piece of information that is stored on your computer's hard drive and which records your navigation of a website so that, when you revisit that website, it can present tailored options to you based upon the stored information about your last visit. You can normally alter the settings of your browser to prevent acceptance of cookies.
Cookies are used by nearly all websites and do not harm your system.
2. How do we use cookies?
We use "cookies" to:
(1) monitor site user traffic patterns and site usage. This helps us to understand how our users use our websites so that we can develop and improve the design, layout and functionality of the sites; and
(2) to help us to advertise to you jobs we think you will be interested in.
There are different kinds of cookies with different functions:
Session cookies: these are only stored on your computer during your web session. They are automatically deleted when the browser is closed. They usually store an anonymous session ID allowing you to browse a website without having to log in to each page. They do not collect any information from your computer.
Persistent cookies: a persistent cookie is one stored as a file on your computer, and it remains there when you close your web browser. The cookie can be read by the website that created it when you visit that website again. We use persistent cookies for Google Analytics (see section 6 on Google Analytics) and for personalisation cookies. The cookies we use are explained below: 3. Strictly necessary cookies
These cookies are essential to enable you to use the site effectively such as applying for a job and therefore cannot be turned off. Without these cookies, the services available to you on our site cannot be provided. These cookies do not gather information about you that could be used for marketing or remembering where you have been on the internet.
4. Performance cookies
These cookies enable us to monitor and improve the performance of our site. For example they allow us to count visits, identify traffic sources and see which parts of the site are most popular. We use Google analytics for this purpose and all information these cookies collect is aggregated and therefore remains anonymous. These cookies do not collect information that identifies a visitor, as all information these cookies collect is anonymous and is only used to improve how our site works.
5. Functionality cookies
These cookies allow our website to remember choices you make (such as your user name, language or the region you are in) and provide enhanced features. For instance, a website may be able to provide you with news or updates relevant to the policies you buy. These cookies can also be used to remember changes you have made to text size, font and other parts of web pages that you can customise. They may also be used to provide services you have requested such as viewing a video or commenting on a blog. The information these cookies collect is usually anonymised.
6. Google Analytics
This website uses Google Analytics, a web analytics service provided by Google, Inc. (“Google”). Google Analytics uses cookies to help the website analyse how users use the site. The information generated by the cookie about your use of the website (including your IP address) will be transmitted to and stored by Google on servers in the United States. Google will use this information for the purpose of evaluating your use of the website, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google's behalf. Google will not associate your IP address with any other data held by Google. Google uses the __utma cookie. This is a persistent cookie that expires in two years. With each new visit, the expiration date is refreshed. By using this website, you consent to the processing of data about you by Google in the manner and for the purposes set out above.
7. Personalisation cookies
This website uses personalisation cookies which help us to advertise to you jobs that we think may be of interest. These cookies are persistent and mean that when you log in or return to the website you may see advertising for jobs that are similar to jobs that you have previously browsed.
For information on how to reject these personalisation cookies, see section 8 below.
8. How to reject cookies
Note that most web browsers will accept cookies, but if you would rather that we did not collect data in this way you can choose to accept all or some or reject cookies in your browser's privacy settings. Rejecting all cookies means that certain features cannot then be provided to you and accordingly you may not be able to take full advantage of all our website's features. Each browser is different, so check the "Help" menu of your browser to learn how to change your cookie preferences. For more information generally on cookies, including how to disable them, please refer to aboutcookies.org (http://www.allaboutcookies.org/). You will also find details on how to delete cookies from your computer.
9. Hotjar
This website uses services provided by Hotjar Ltd. Hotjar provides services including Heatmaps, Visitor recordings, Funnels and Form Analysis, Feedback Polls, Surveys and Recruiters. The information generated by the tracking code and cookie about your use of the website will be transmitted to and stored by Hotjar on servers in Ireland. Through the Hotjar tracking code the information collected includes:
Device-specific data
The following information may be collected through your device and browser:
o your device's IP address (collected and stored in an anonymized format);
o your email address including first name and surname;
o device screen size;
o device type (unique device identifiers) and browser information;
o geographic location (country only);
o preferred language used to display the webpage.
Log data
Our servers automatically record information which is created upon using Hotjar. Data includes:
o referring domain;
o pages visited;
o geographic location (country only);
o preferred language used to display the webpage;
o date and time when website pages were accessed;
Hotjar will use this information for the purpose of evaluating your use of the website, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage. Hotjar uses a variety of services hosted by third parties, such as Google Analytics and Optimizely. These services may collect information sent by your browser as part of a web page request, such as cookies or your IP request. For information on how Google Analytics and Optimizely collect and use your information, please refer to their privacy policies. By continuing to use this website, you consent to the processing of the above data by Hotjar and by the third parties used by Hotjar in accordance with their respective privacy policies. The cookies used by Hotjar have differing durations; some are 365 days, some persist for the session only.
To opt out please go to the following link:
https://www.hotjar.com/opt-out
10. Drift
This website uses services provided by Drift.com, Inc. (“Drift”). Drift provides services including a Conversational Marketing platform.
Through the Drift integration code, the information collected includes:
Personal Information that may include, but is not limited to, your name, postal address, email address and employer.
Log data
Drift may collect information that your browser sends whenever you visit our website or use our Service (“Log Data”). This Log Data may include information such as your computer’s Internet Protocol (“IP”) address, browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages and other statistics. In addition, Drift may use third party services such as Google Analytics that collect, monitor and analyse this type of information in order to increase their Service’s functionality. These third-party service providers have their own privacy policies addressing how they use such information. When you access the Service by or through a mobile device, we may collect certain information automatically, including, but not limited to, the type of mobile device you use, your mobile device’s unique device ID, the IP address of your mobile device, your mobile operating system, the type of mobile Internet browser you use, your location information and other statistics. Please see the section regarding Location Information below regarding the use of your location information and your options.
Location Information
Drift may use and store information about your location depending on the permissions you have set on your device. They use this information to provide features of our Service and to improve and customise their Service. You can enable or disable location services when you use their Service at any time, through your mobile device settings.
Do Not Track Disclosure
Drift does not support Do Not Track (“DNT”). Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked. You can enable or disable Do Not Track by visiting the “Preferences” or “Settings” page of your web browser.
Links to other websites
Please note that clicking on links and banner advertisements and RSS feeds may result in your transfer to another website, where data privacy practices may be different to this Privacy Policy. It is your responsibility to check other website privacy policies to ensure that you are happy for your personal information to be used in accordance with those third parties privacy policies. We accept no responsibility for and have no control over third party websites, links, adverts or RSS feeds or information that is submitted or collected by third parties.
Changes to our Privacy Policy
We reserve the right to amend this Privacy Policy and any changes will be posted on this website so you are always aware of what information we collect, how we use it and under what circumstances, if any, we disclose it. If at any time we decide to use Personal Data in a manner significantly different from that stated in this Privacy Policy, or otherwise disclosed to you at the time it was collected, we will notify you by email, and you will have a choice as to whether we use your information in the new manner.
Additional information
For further information on your rights and GDPR, please visit the website of the UK supervisory authority; the Information Commissioner’s Office (“ICO”): https://ico.org.uk/
You can get in contact with the Information Commissioner’s Office via the following:
Telephone: 0303 123 1113
Email: casework@ico.org.uk
Live chat
Post: Information Commissioner's Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF