Privacy Policy
Blink Recruitment is a company registered in Guernsey under company number 26663. Registered with the Office of the Data Protection Authority in Guernsey (number 63888), Blink is classed as a Data Controller. This means that we are responsible for deciding how we obtain, hold and use your personal data. We are committed to protecting your privacy and confidentiality in accordance with this Privacy Policy and we would urge you to read it carefully. If you have any questions with regard to this Policy or in regards to any data we hold about you, please contact our data protection officer at office@blinkrecruitment.gg.
Blink processes your personal data in accordance with the provisions of the EU General Data Protection Regulation (“GDPR”), as implemented in Guernsey via the Data Protection (Bailiwick of Guernsey) Law, 2017.
By accessing, using and/or downloading materials from or sending or posting materials to, this Site, you agree on your own behalf and on behalf of each entity on whose behalf you act, to the terms of this Privacy Policy and to the practices for the collection, use or disclosure of your personal information as described here.
Please note that this Site is also governed by the Terms and Conditions of Use. We urge you to review the Terms and Conditions of Use before proceeding further on this Site.
What information do we collect? Anonymous browsing
You can visit this site without telling us who you are or revealing any information about yourself, including your email address. In this case, our Web server may collect the name, address, the IP address and domain you used to access this Site, the type and version of browser and operating system you are using, and the web site you came from and visit next. This information is used by us and our business partners to measure the number of visits, average time spent, page views, and other statistics about visitors to this Site in general. We may also use this data to monitor site performance for systems administration purposes, to make this Site easier and more convenient to use and to report information in aggregate form to our advisers (e.g. how many visitors log in to this Site).
What information do we collect? Client information
The personal data we process on Clients (ie individuals or organisations for whom we are seeking prospective candidates) may include the following:
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Name of organisation
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Job Titles and descriptions
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Notes from briefings, telephone calls and meetings specifically to enable us to identify suitable candidates for the specific roles
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Team structures and organisation charts
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Marketing preferences
We may collect personal data from:
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Staff from within your organisation
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Candidates or other Clients who have referred you to us
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Widely accessible internet searches and social media platforms
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Press coverage
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Interviews, briefings or meetings
We may use your personal data for the following reasons:
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Identifying suitable candidates for your open vacancies
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Record keeping of our business dealings with your organisation
What information do we collect? Candidate Information
We will collect some, or all of the data mentioned below directly from candidates in order to assist in securing a relevant employment opportunity:
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Personal contact details such as name, address, telephone numbers and email addresses
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Date of Birth
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Gender
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Marital Status and dependants
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Social Security Number, bank account details, payroll records and tax coding notices
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Residential status
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Current salary, benefits, pension and annual leave information
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Current employment details
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Certificates relating to Academic and / or Professional qualifications
Special Category Data
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Information about the candidate’s health including any medical condition, health and sickness history
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If included on a candidate’s cv - data revealing an individual’s ethnic origin, political opinion, philosophical belief or trade union membership
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Information about criminal convictions and offences
In some instances we will collect data from publicly available sources such as the internet or social media sites. In instances where we are required to share this special category data with one of our clients for the purposes of providing you with work finding services we will always ask for your express written consent to share.
Collection and use of personal data
a. Purpose of processing and legal basis
The Company will collect your personal data (which may include special category data) and will process your data for the purposes of providing you with work-finding services. The legal bases we rely upon to offer these services to you are:
• Consent
• Legitimate interest
• Legal obligation
• Contractual obligation
b. Legitimate interest
Where the Company has relied on a legitimate interest to process your personal data our legitimate interests is/are as follows:
• As a recruitment agency we retain a legitimate interest:
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To assess your skills, qualifications and experience to ascertain suitability for a particular role or area of work.
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To enable us to communicate with you regarding the recruitment process
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To carry out background and reference checks (where applicable)
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To comply with legal or regulatory requirements
c. Recipient/s of data
The Company will process your personal data and/or special category data with the following recipients:
• Agreed clients of Blink where suitable vacancies have been identified and then only with your prior express permission
d. Statutory/contractual requirement
Your personal data is required by law and/or a contractual requirement (e.g. our client may require this personal data), and/or a requirement necessary to enter into a contract. You are obliged to provide the personal data and if you do not the consequences of failure to provide the data are:
• The recruitment process cannot happen without providing this data to clients
Overseas Transfers
Blink may transfer the information you provide to us to countries outside the European Economic Area (‘EEA’) for the purposes of providing you with work-finding services. We will take steps to ensure adequate protections are in place to ensure the security of your information. The EEA comprises the EU member states plus Norway, Iceland and Liechtenstein. We will always inform you if we intend to transfer data overseas – and will only do so with your prior consent.
Data retention
The Company will retain your personal data only for as long as is necessary. Different laws require us to keep different data for different periods of time.
The Conduct of Employment Agencies and Employment Businesses Regulations 2003, require us to keep work-seeker records for at least one year from (a) the date of their creation or (b) after the date on which we last provide you with work-finding services.
We must also keep your payroll records, holiday pay, sick pay and pensions auto-enrolment records for as long as is legally required by the States of Guernsey Tax Authority and associated minimum wage, social security and tax legislation.
Where the Company has obtained your consent to process your personal data, we will do so in line with our retention policy. Upon expiry of that period the Company will seek further consent from you. Where consent is not granted the Company will cease to process your personal data
Cookies
Cookies are small pieces of data stored by your Internet browser on your computer's hard drive, which permits us to recognize you when you access this Site. If you are browsing, a cookie is used to help us measure the number of visits, average time spent, page views, and other statistics relating to your use of this Site. If you are searching, a cookie is used to carry the search request data from the request page to the results page. This cookie, by itself, doesn't tell us your email address or who you are. If you decide to register on-line with us, we may collect additional information to provide tailored job opportunities or other information to you (see Personal Information Collection below). In this case, we use cookies to recognize you on subsequent visits and make your on-line experience more convenient, unless prohibited by law. Please note portions of this Site will not function if you do not accept cookies.
Tracking user preferences also helps us serve you targeted advertising. Targeted advertisements are probably more interesting for you and are more productive for our advertisers.
Personal information collection, use and distribution to third parties generally
There are times when we may ask you for, or you may choose to provide, information about yourself or your business to assist us in meeting your various needs. This information may be used for the following purposes: answering your questions, providing you with services you have requested, giving producers and developers of our website information that is useful in determining appropriate new features, content and services, to provide advertisers with aggregate, not individual, information about our customers, or informing you of additional services or job opportunities provided by Blink or by our business partners, that may interest you.
To provide these services, we may need to ask you directly to provide, among other things, your name, mailing address, postal code, email address and phone number ("Registration Information"). You may also elect to apply online to a job posting.
At times, we also conduct online surveys to better understand the needs, profiles, and experiences of our visitors. You will be given the option to participate in such surveys. Unless you request to receive the results of the survey via email, no personal information is requested during such surveys and all information is used on an aggregated basis only. If during the registration process, you indicate you would like us to keep you updated on new site developments and information about our services or about offerings from Blink, we will send you these updates by email.
If you contact Blink, we may keep a record of that correspondence. We do not collect the email addresses of those who communicate with Blink via email. We use the information provided only so that we may respond to the email. We do not knowingly solicit information from children and we do not knowingly market our services to children.
When you provide personal information to us, we may communicate and disclose it to third parties for the purpose of fulfilling, servicing and completing your requests and the transactions related to it. These third parties may be in the UK or in other parts of the world. By registering with Blink, you agree that your information may be shared with third parties for the purpose of fulfilling, servicing and completing your requests and transactions related to it.
We may also aggregate statistics that we gather about the visitors to the Site, sales, traffic patterns, and services and provide these statistics to third parties; however, when we do, these statistics will not include any personal information that identifies individuals.
We may also use, disclose and communicate your personal information if required to do so by law including by an order of any court. Although we use all reasonable means to ensure that the information you provide to us is not used by third parties for purposes other than those described in this Privacy Policy, Blink is not responsible for any improper use of your personal information that is beyond our reasonable control.
CV collection
As part of the services we provide, we may ask you to provide us with your CV, to be viewed by our consultants and staff members who access this Website. In addition to the provisions of this Privacy Policy, the collection, use and distribution of your CV is governed by the Terms & Conditions of Use.
How do you access and update your personal information?
Your personal information is located on a server(s) operated by Purple Penguin Media Limited. Blink provides you with the means to access, update, edit or delete the Registration Information and other personal information you have provided to us at any time on your own by going to your user account and changing or deleting your Registration Information and other personal information as desired. If you decide at any time that you do not want to receive any updates you have subscribed for just send an email message to recruit@blinkrecruitment.gg indicating your preference not to receive updates. If you are unsure whether we have a record containing your personal information and would like to confirm whether or not we do, please send an email to recruit@blinkrecruitment.gg indicating all email addresses which you may have given us.
How is your personal information secured and protected?
Where Blink considers it appropriate, Blink uses encryption and/or authentication tools among other methods to protect certain web-based personal information. E-mails you send us are not necessarily secure when they are transmitted to us. If your communication is sensitive or includes confidential information such as a credit card number, you may want to provide it by post or via the telephone instead.
We instruct our employees with access to your personal information that it is to be used only in adherence with the principles set forth in this Privacy Policy and the laws applicable to each specific business. The only employees who have access to your personal information are administrative personnel. Employees who misuse customer personal information may be subject to disciplinary action.
By Law you have the following rights:
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Right to Information – you are entitled to know who we are and what exactly is going to happen with your personal data – this Privacy Policy is designed to provide you with this information
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Right of access- This entitles you to receive a copy of the personal information we hold about you by submitting a “subject access request”.
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Right to rectification– to rectify any inaccurate or incomplete personal data. We would ask that you contact is via email to recruit@blinkrecruitment.gg with any rectification requests
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Right to erasure – you may at any time withdraw your consent to the processing of your personal data and request the erasure of the personal data held by us by emailing recruit@blinkrecruitment.gg
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Right to object to processing(for direct marketing purposes) – you have the right to tell us to stop wherever we have used your personal data to market products or services to you. Please send an email to us at recruit@blinkrecruitment.gg and we must stop sending you material of this nature – you can also unsubscribe from the emails received using the unsubscribe link.
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Right to object to processing (on grounds of public interest) – if we are using your personal data believing it to be in our “legitimate interest” or we believe it to be in the public interest you may ask us to stop by emailing us at recruit@blinkrecruitment.gg This request can be refused if it can be proven that our legitimate interest outweighs the reasons for the objection. We can advise that we do not process personal data in this manner.
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Right to object to processing (for historical or scientific purposes) –Whilst Blink does not process personal data for these purposes, we recognise your right to request us to stop if you feel we are doing so.
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Restriction on processing– this enables you to request the suspension of processing of your personal data in various circumstances
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Right to data portability – in certain circumstances you may request that we transfer your personal data to a third party
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Right to lodge a complaint with the supervisory authority – whilst we would hope that any concerns regarding our use of your personal data can be resolved through communication with our offices, you may lodge a complaint directly with our regulator. Their details can be found at http://www.odpa.gg/exercising-your-rights/
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Right to withdraw consent – you have the right to withdraw consent to Blink at any time after registering with us for recruitment purposes. This consent may be withdrawn by unsubscribing from our website or by sending an email to recruit@blinkrecruitment.gg Once notification of the wish to withdraw is received, we will cease utilising your personal data and subject to any statutory regulations, will securely delete your personal data.
What if we change our privacy policy?
Blink reserves the right to modify or supplement this Privacy Policy statement at any time. If we make any material change to this Privacy Policy, we will update this Site to include such changes and post a notice on our home page, for a period of 30 days, with a link to the updated Privacy Policy. Please read any such notice and the new policy statement. If you return to this Site after a period of more than 30 days, please check this Privacy Policy to confirm that you are aware of the details of the most recent update. Please look at the top of this Privacy Policy to check the date that it was updated and to confirm that you are familiar with the terms of the most recent update. Your continued use of this site after we post such notice will constitute your acceptance of the new terms and their application to your use of this Site and the personal information disclosed for such use, including personal information previously furnished to us as if they were the initial terms, and your consent to the use of your personal information as described in this privacy policy and elsewhere at our Website. However, we will seek your consent if we want to use your personal information for purposes other than those you have agreed to previously.
Website Links
This Site may contain links to other sites, including those of our business partners, vendors and advertisers. While we try to link only to sites that share our high standards and respect for privacy, please understand that we are not responsible for the content of, or the privacy practices employed by, other sites.
Privacy Policy with respect to use of CVs
As part of the services Blink provides, you are able to post your CV on our website. This section of Blink’s general Privacy Policy applies to the use of your CV by Blink.
CVs are accessed by our consultants who seek to find you employment with third parties ("Third Parties"). Consultants are not permitted to disclose information outside our organization or beyond the Third Party, as applicable. Recruiters are also required to have entered into an agreement with Third Parties that requires such Third Parties to use your CV solely for the purpose of filling a job within the Third Party for which the information was provided and not disclosing your CV outside the organization. However, although Blink deals only with reputable organizations, we cannot guarantee that all Employers and Third Parties will adhere to the limitations we impose on them. If at any time you would like your CV removed from our Website, you may do so by using the "delete CV" function.
Some job postings which are posted on the Blink’s site allows you to follow links to where you can apply, and provide your CV, for a specific job posting. In some cases, such applications are still within the Blink's site and its control. If you are not asked to login using your Blink registration User ID and password, however, then both the application process, and your CV are outside the Blink site and Blink's control. In such cases you will be providing your CV directly to the Employer or Recruiter and your CV will be subject to their privacy policy. Blink is not responsible for the privacy practices of such Employer or Recruiter. In such cases, we encourage you to review the Employer or Recruiter's privacy policy.
Although we use all reasonable means to protect your personal information Blink is not responsible for any improper use of your personal information that is beyond our reasonable control.
Your CV when uploaded is converted in to various formats for our use only. These conversions are handled by an external data center server stack. Once conversion is complete your CV is then automatically deleted from that service. We are committed to ensuring that your information is secure. In order to prevent unauthorized access or disclosure, the data company have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information. We may disclose your information if necessary, to protect our legal rights or if the information relates to actual or threatened harmful conduct or potential threats to the physical safety of any person. Disclosure may be required by law or if we receive legal process. If these servers are breached, we are not responsible for this and cannot be held liable.
Account Removal
You can remove your account and all your data from our system, simply login.