Bridging Global Talent
Novi Ventures Limited t/a Kapia is a “data controller”. This means that we are responsible for deciding how we hold and use personal information about you. You are being sent a copy of this privacy notice because you are applying for work with us (whether as an employee, worker or contractor), through us in our capacity as a recruitment business or you have done so previously. It makes you aware of how and why your personal data will be used, namely for the purposes of the recruitment exercise and future recruitment exercises, and how long it will usually be retained for. It provides you with certain information that must be provided under the General Data Protection Regulation ((EU) 2016/679) (GDPR).
DATA PROTECTION PRINCIPLES
We will comply with data protection law and principles, which means that your data will be:
Used lawfully, fairly and in a transparent way.
Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
Relevant to the purposes we have told you about and limited only to those purposes.
Accurate and kept up to date.
Kept only as long as necessary for the purposes we have told you about.
Kept securely.
THE KIND OF INFORMATION WE HOLD ABOUT YOU
In connection with your application for work, we will collect, store, and use the following categories of personal information about you:
The information you have provided in your curriculum vitae and any covering letter.
The information you have provided on any application or application form, including name, title, address, telephone number, personal email address, date of birth, gender, employment history and qualifications
Documentation you provide to prove an entitlement to work in the UK
Any information you provide during an interview.
We may also collect, store and use the following “special categories” of more sensitive personal information:
Information about your race or ethnicity, religious beliefs, sexual orientation and political opinions.
Information about your health, including any medical condition, health and sickness records.
Information about criminal convictions and offences.
HOW IS YOUR PERSONAL INFORMATION COLLECTED?
We may collect personal information about candidates from the following sources:
You, the candidate.
Recruitment agency job boards, from which we collect the following categories of data: your CV and the information set out above.
A background check provider and a credit reference agency, from which we collect the following categories of data: details of any adverse credit transactions for example County Court Judgments, IVA’s or Bankruptcy orders.
Disclosure and Barring Service in respect of criminal convictions.
Your named referees.
HOW WE WILL USE INFORMATION ABOUT YOU
We will use the personal information we collect about you to:
Assess your skills, qualifications, and suitability for the role
Carry out background and reference checks, where applicable.
Communicate with you about the recruitment process.
Keep records related to the hiring processes.
Seek to place you in employment with potential employers.
Comply with legal or regulatory requirements.
It is in our legitimate interests to decide whether to appoint or recommend you to a role since it would be beneficial to our business or our client’s business to appoint someone to that role.
We also need to process your personal information to decide whether to enter into a contract of employment with you and/or to provide information to our clients who wish to decide whether to enter into a contract of employment with you.
Having received your CV or covering letter or your application form and the results of any test which you took we will then process that information to decide whether you meet the basic requirements to be shortlisted for the role. If you do, we will decide whether your application is strong enough for you to be invited for an interview. If you are called for an interview, the information you provided at the interview may be used to decide whether to offer you the role. If you are offered the role, we may then take up references.
Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground, we are relying on to process your personal data where more than one ground has been set out in the table below.
Purpose/Activity
Type of data
Lawful basis for processing including basis of legitimate interest
To register you as a new customer
(a) Identity
(b) Contact
Performance of a contract with you
To process and deliver your order including:
(a) Manage payments, fees and charges
(b) Collect and recover money owed to us
(a) Identity
(b) Contact
(c) Financial
(d) Transaction
(e) Marketing and Communications
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to recover debts due to us)
To manage our relationship with you which will include:
(a) Notifying you about changes to our terms or privacy policy
(b) Asking you to leave a review or take a survey
(a) Identity
(b) Contact
(c) Profile
(d) Marketing and Communications
(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
To enable you to partake in a prize draw, competition or complete a survey
(a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and Communications
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
(a) Identity
(b) Contact
(c) Technical
(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
(b) Necessary to comply with a legal obligation
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you
(a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and Communications
(f) Technical
Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences
(a) Technical
(b) Usage
Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about goods or services that may be of interest to you
(a) Identity
(b) Contact
(c) Technical
(d) Usage
(e) Profile
(f) Marketing and Communications
Necessary for our legitimate interests (to develop our products/services and grow our business)
Marketing
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
Promotional offers from us
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have requested information from us or purchased services from us and you have not opted out of receiving that marketing.
Third-party marketing
We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
Opting out
You can ask us or third parties to stop sending you marketing messages at any time by contacting us at any time.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of service purchase, warranty registration, service experience or other transactions.
Cookies
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookie Policy.
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
Disclosures of your personal data
We may share your personal data with the parties set out below for the purposes set out in the table above.
Internal Third Parties.
External Third Parties
Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
International transfers
Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data.
Where we use certain service providers, we may use specific contracts approved for use in the UK which give personal data the same protection it has in the UK. Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.
If you fail to provide personal information
If you fail to provide information when requested, which is necessary for us to consider your application (such as evidence of qualifications or work history), we will not be able to process your application successfully. For example, if we require a credit check or references for this role and you fail to provide us with relevant details, we will not be able to take your application further.
HOW WE USE PARTICULARLY SENSITIVE PERSONAL INFORMATION
We will use your particularly sensitive personal information in the following ways:
We will use information about your disability status to consider whether we need to provide appropriate adjustments during the recruitment process, for example whether adjustments need to be made during a test or interview.
We will use information about your race or national or ethnic origin, religious, philosophical or moral beliefs, or your sexual life or sexual orientation, to ensure meaningful equal opportunity monitoring and reporting.
INFORMATION ABOUT CRIMINAL CONVICTIONS
We do not envisage that we will process information about criminal convictions.
AUTOMATED DECISION-MAKING
You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making.
DATA SHARING
Why might you share my personal information with third parties?
We share your personal information with prospective employers for the purposes of processing your application. All prospective employers, third-party service providers and any other entities in the group are required to take appropriate security measures to protect your personal information in line with our policies. We do not allow our third-party service providers to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions.
DATA SECURITY
We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need-to-know. They will only process your personal information on our instructions, and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.
DATA RETENTION
How long will you use my information for?
We will retain your personal information for a period of 6 years after we have communicated to you the decision about whether you will be appointed to a role. We retain your personal information for that period so that we can show, in the event of a legal claim, that we have not discriminated against candidates on prohibited grounds, that we have conducted the recruitment process in a fair and transparent way and for accounting and financial purposes. After this period, we will securely destroy your personal information.
We may also wish to retain your personal information on file, on the basis that a further opportunity may arise in future and we may wish to consider you for that. We do this because of the nature of our business, i.e. that we are a recruitment consultancy and our relationship with you is one where we are aiming to seek employment on your behalf, therefore this is justified and a legitimate interest of our business.
RIGHTS OF ACCESS, CORRECTION, ERASURE, AND RESTRICTION
Your rights in connection with personal information
Under certain circumstances, by law you have the right to:
Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.
Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
Request the transfer of your personal information to another party.
If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact us in writing.
RIGHT TO WITHDRAW CONSENT
Consent is one of 6 lawful ways in which we can process your personal information. We do not require your consent to process your personal information. However, if we have obtained consent from you, then you have the right to withdraw your consent for processing for that purpose at any time. To withdraw your consent, please contact Lis Betteridge. Once we have received notification that you have withdrawn your consent, we will no longer process your application and, subject to our retention policy, we will dispose of your personal data securely.
DATA PROTECTION OFFICER
We have not appointed a data protection officer (DPO). If you have any questions about this privacy notice or how we handle your personal information, please contact Lis Betteridge. You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues.