THE DETAIL

Huntress Search Ltd trading as Birchrose Associates

Huntress Search Ltd ("Huntress") is registered as a data controller in the United Kingdom
for the purposes of Data Protection legislation. Huntress' website and online services
are designed to protect the privacy of all users. We ensure that the data you supply to us is
processed fairly and lawfully, and with skill and care. This Data Protection Privacy Notice
governs our processing of all personal data provided to us, in all forms. Our purpose is to
provide you with work- finding services. By registering your details with us and using our website,
you consent to us collecting and processing personal data supplied by you and disclosing this
information to prospective employers and clients in connection with the recruitment process.

Introduction

This Privacy Notice provides you with clear information as to how we process your personal data.
We are obliged to use your information in line with all applicable laws. We do so in a manner that is
fair by using your information in a way that you would reasonably expect when providing our work-finding
services or recruiting personnel for you, and being transparent so that you know how it will be used.

This Privacy Notice sets out: the types of personal data that we collect about you; how and why we use
it; how long we will keep it for; when, why and with whom we will share it; the legal basis for us using your
personal data; and your rights in relation to us storing and processing your personal data. It also explains
how we may contact you and how you can contact us.

Part of the recruitment process will involve sharing your personal data with our clients (independent data controllers)
who have potential work opportunities that may be suitable for you. These third parties will have their own privacy
policies and will also need to comply with all applicable laws. We encourage you to contact them directly if you
have any concerns or questions about how they process your data.

Who we are

Huntress Search Limited (registration number 4041477) is an employment business and agency that also
includes specialist brands. We provide both temporary and permanent recruitment services to clients looking
to recruit personnel for their business and provide work-finding services to candidates looking for job opportunities.

We are registered as a data controller with the ICO in the United Kingdom for the purposes of the Data Protection
legislation and General Data Protection Regulation (GDPR). Our registered office address is Aviation House,
125 Kingsway, London WC2B 6NH and you can contact us at dataprotection@huntress.co.uk if you have any queries
relating to data protection.

Legal basis for processing your data

The lawful basis we rely on to process your personal data is Article 6(f) of the UK GDPR. We may also rely on
Article 6(a), (b) and (c) in certain situations.

For prospective candidates, contractors, referees and clients, our processing is necessary for our legitimate
interests in that we need the information in order to be able to assess suitability for potential roles, to find
potential candidates and to contact clients and referees.

We do not consider our legitimate interests to be overridden by your interests or fundamental rights and freedoms.
We take into consideration the reasonable expectations of individuals who are actively applying for jobs or making
their personal information publicly accessible on professional networking sites.

If you are submitted as a candidate or requested for interview, then this may involve the processing of more detailed
personal data including sensitive data such as health information or any unspent criminal convictions that you or
others provide about you. We will ask for your consent before undertaking such processing if we are required to do so.

For clients, it may also be necessary for us to process your data in order to perform a contract for
you if one is in place, for example in contacting you.

What information will we collect about you?

We need your personal data in order to find you suitable opportunities and further information may be
needed to assess your eligibility through the different stages of the recruitment process. We collect
and process personal data only as far as is necessary to facilitate the recruitment process and
provide you with work-finding services.

The information we collect may include your name, email address, telephone number, CV, identification
and right to work documents, educational records, work history, employment, and references.

In general, we will not ask you about sensitive personal data but there may be times when it is necessary
for information to be disclosed to us and for us to share it with potential employers. We will only share the
information where you have provided your explicit consent.

We are also under an obligation to our clients to provide suitable candidates. Part of the assessment process
will include asking you about any unspent criminal convictions you may have. We consider this to be highly
confidential information and will only share this where you have provided your explicit consent.

Who will share your information with?

In order to provide work-finding services to you, it is necessary for us to share your personal data with
our clients (independent data controllers) who have potential work opportunities that may be suitable
for you. Once your data has been shared with them, they will determine how they use, store and
process your data and will have their own privacy policy.

There may also be circumstances where disclosure is required or permitted by law (such as to
government bodies and law enforcement bodies). As an example, we are under an obligation to
report pay details of all workers we place with clients to HMRC.

Generally, we will process your information within Huntress. There may be occasions where we use
third parties to process your information on our behalf. In such situations these third parties will be
under strict instructions and they will not be permitted to use your information for their own business purposes.

Where does the information we collect about you come from?

The data we collect about you is obtained from the following sources:

  • Directly from you. This may be via our registration process, information requests
    and applications via our website.
  • An agent or third party acting on your behalf. This may be where you are
    consulting via a Limited Company.
  • Publicly available sources. We may also obtain your information from professional
    networking sites or job boards, where you have actively published or submitted your information.
  • Reference or word of mouth. You may be recommended by a friend, former employer or colleague.

How will we use the information collected about you?

We will use your information in such ways to facilitate the recruitment process and provide you with
work-finding services, including but not limited to:

• Using your details to match your skills, experience and education with a role that suits your requirements
(we use technology in ways to help identify the most suitable candidates for a specific role but this does
not constitute automated decision making);
• Making you aware of current opportunities that may suit your requirements;
• Contacting and updating you about applications you have made or roles you have been submitted for;
• Sharing your details with clients with the aim of securing a potential role (our client may be the
company you will provide your services to or an intermediary company that directly supplies to the
company you will provide your services to).

If you are selected by the client for an interview or the next stage of the recruitment process, we will
need further information from you. This is likely to come directly from you but may also be from third
parties such as a referee for example.

We may also analyse the data internally so that we can offer a more relevant service, for marketing and
strategic development purposes or for research purposes to improve our service.

How and when will we contact you?

We may contact you by phone, email or social media. Some examples of when we will contact you are:

  • Upon receipt of a CV or your personal data, it will be reviewed to determine whether we are likely to be
    able to provide you with work-finding services and we will notify you if you are added to our database.
  • When one of our consultants considers you for a suitable job opportunity or to find out more about the
    type of role you are looking for.
  • Before we put you forward for a role.
  • During and following an assignment we have placed you in.
  • In relation to any correspondence we receive from you.
  • To update you on any material changes to our policies and practices.

Will we transfer your data outside the EEA?

Huntress is based in the UK and our back-up systems are stored in the EEA. We do not generally transfer
your data out of the EEA.

In the event that we do need to make transfers to countries outside the EEA, we will ensure the appropriate
safeguards are in place.

Clients and Hirers who we share your information with in connection with work finding services will have their
own privacy policies and procedures. Some of these companies may be international and process your data
in different ways. We encourage you to contact them directly if you have any concerns or questions about
your data.

How long will we keep your personal information?

Huntress will only retain information for as long as necessary for the relevant activity. This may be determined by
legislation or a decision as to what we consider necessary for the business based on a number of factors.

  • If you have not registered with us, your data will be retained for 12 months from when it was added to our
    database or from when you were last contacted. You can request to have your record deleted (see below).
  • If you do register with us, your data will be retained for 3 years from the last contact or activity on
    your record. You can request to have your record deleted (see below).
  • If we place you in a temporary assignment or permanent role we will be required to keep certain
    information for specific lengths of time up to a maximum of 6 years. The purpose of keeping this information
    is to comply with our legal obligations.
  • Client contact details are retained for 3 years from the last contact or activity on your record. You can
    request to have your record deleted (see below).

Will we process special categories of personal data and criminal convictions?

We avoid processing special categories of data (these are sensitive personal data that reveal racial or ethnic origin,
political opinions, religious or philosophical beliefs, or trade union membership) and the processing of genetic data,
biometric data for the purpose of uniquely identifying a natural person, data concerning health, or data concerning a
natural person’s sex life or sexual orientation. However, by taking copies of passports or ID it may be that racial or
ethnic origin can be revealed.

Processing this data is necessary for us to comply with employment law obligations and the data is only used for
this specific purpose.

We are under an obligation to ensure that the candidates we submit to clients are suitable. As part of our registration
process we require individuals to disclose any unspent convictions and may need to make further enquiries if necessary.

Will we contact you for marketing purposes?

We will only send you direct marketing emails that promote our company or services if you have opted in to this.
You will have the option to opt in when you are provided with a copy of our Privacy Notice. You can also manage
your direct marketing preferences by contacting a Huntress consultant, updating your preferences or clicking the
unsubscribe link on an email.

To clarify, contacting you about specific job opportunities is not marketing because we are not advertising or
marketing our services.

Can you refuse to provide your data to us or request that we delete your data?

If you do not provide the personal data requested or use your right to withdraw your consent for the processing
of your sensitive personal data, we may not be able to match you with available job opportunities.

You have the right to object to us processing your data based on legitimate interest. If you have not been placed
then we will be able to delete your data. You will have the option to delete your data when you are provided with a
copy of our Privacy Notice by following the link on the transparency notice email or you can do so by
emailing dataprotection@huntress.co.uk.

If you have been successfully placed, then we will be under certain legal obligations to retain information for specified
periods (up to 6 years). This includes, but is not limited to, ensuring you have the right to work in the UK and allowing
us to comply with HMRC reporting requirements regarding payroll information. In such situations you do not have the
right to object to us processing your data.

You do also have the right to restrict processing which means that we will stop further use of your data but still
store it. However, if we stop processing your data, it will mean that any assignment you may currently be on will
be terminated immediately or in line with any notice period.

Please note that we may require you to provide us with proof of your identity and answer security questions
before processing your request and if your data is deleted, we will have no record and you may be contacted
again in the future.

Can you find out what data we hold about you?

You have the right to be informed about, and access a copy of, the information comprised in your personal data.
This is a right to the personal data and is not a right to access documents, emails or calls. If any of the data we
hold is inaccurate, you have the right to rectify it. You can contact us at dataprotection@huntress.co.uk or your
consultant directly to update your data.

You can make a request to find out what personal data we hold about you. You may exercise this right by making a
written subject access request (SAR) to dataprotection@huntress.co.uk. We require you to provide us with proof
of your identity and answer security questions before processing your request.

We usually act on such requests and provide information free of charge, but may charge a reasonable fee to
cover our administrative costs of providing the information for:

  • baseless or excessive/repeated requests, or
  • further copies of the same information.

Alternatively, we may be entitled to refuse to act on the request.

Please consider your request responsibly before submitting it and if you are looking for something specific, please
state what this is. Generally, you will receive a response within one month from when we receive your request and
your identification documents, but it is possible to extend this to three months if necessary. If this applies, we will
let you know.

Do you have the right to data portability?

The GDPR includes a right to data portability. The right to data portability only applies when:

  • your lawful basis for processing this information is consent or for the performance of a
    contract; and
  • you are carrying out the processing by automated means (ie excluding paper files).

As we rely on the legal basis of legitimate interests and the data is not processed by automated means,
this right will not apply to the data we hold about you.

Cookies & External Websites

To provide better service to you on our websites, we use cookies to collect your personal data when
you browse. See our cookie policy on our website here for more details.

Some external links appear on our website, to websites owned and operated by third parties. These websites
have their own privacy policies and we encourage you to review them. We accept no responsibility or liability
for the privacy practices of such third parties and you use them at your own risk.

Changes to this Privacy Notice

We reserve the right to change our Privacy Notice at any time. Changes to our Privacy Notice will be displayed on our website.

Complaints

If you have any issues or concerns then we ask that in the first instance you set this out in writing and
send this to dataprotection@huntress.co.uk.

If we are unable to satisfactorily deal with your complaint you can complain to the ICO which is the UK
supervisory authority. You have the right to claim compensation for damages caused by a breach of data
protection legislation.