Privacy Policy – Orbition Talent Services

Overview

Orbition Group takes your data privacy very seriously. This Privacy Policy is designed to tell you about how we operate regarding the collection, use and disclosure of personal information which may be collected in person from you, obtained via our websites or collected through other means such as by email, telephone communication, social media interaction or online forms.

This policy may be updated from time to time, so please ensure you check it regularly.

Who is included in this Privacy Policy?

This Privacy Policy applies to the personal data of Orbition Group’s website users, Candidates, Clients, Suppliers, and other business contacts or related third-parties.

Orbition Group may amend this Privacy Policy from time to time. Please visit this page for new of any changes to our policy, all of which will be posted here.

This policy describes how personal data must be collected, handled and stored in order to remain compliant the General Data Protection Regulations (GDPR).

What is covered by this Policy?

Orbition Group takes your personal data seriously.

This policy:

• defines the types of personal data that we collect about you
• details how and why we collect and use your personal data
• defines the legal basis we have for using your personal data
• details the different rights and choices you have when it comes to your personal data; and
• details how we may contact you and how you can contact us.
• defines our breach notification process
• details our complaints & breach procedure
• details who we share your data with
• details how long we keep your personal data for
• details the process when direct contact is made with us

Changes to Orbition Group Privacy Policy

This privacy policy may be changed by Orbition Group at any time. Any changes to our policy will be updated on our website. If you have any questions or concerns, please contact us at hello@orbitiongroup.com

Personal data collected by Orbition Group

Orbition Group may collect and process personal data (information that can be uniquely identified with you) about you when you apply to one of our job advertisements:

directly for an advertised role via our website
when you apply to be a candidate for whom we can facilitate a job search
via a third party when you respond to a job post placed by Orbition Group on a job board on behalf of a third-party client

We will hold your email address for marketing purposes if you opted in to receive email marketing communication, participated in a partnered event, connected with one of our employees on LinkedIn or are a member of a group to which they also belong, provided us with your business card, or had another prior connection, correspondence or relationship with us.

Data security

Orbition Group takes all reasonable steps to ensure that appropriate measures are carried out in order to safeguard the information we collect from you and to protect against unlawful access and accidental loss or damage.

This may include (as necessary):

protecting our data and computer servers with firewalls
locating data processing storage facilities in secure locations
encrypting all data stored on our server that encrypts the data between your computer and our server
disposing of or deleting your data securely
regularly performing data backups

Whilst Orbition Group does not store or request financial information from candidates, we do store highly personal information contained within your Curriculum Vitae (CV). We are aware of our responsibility to protect your information and to only share details with third parties upon receipt of your explicit consent. All our systems are password protected and only authorised users have access to the personal information stored in our systems.

Orbition Group’s use of your data

When you register with Orbition Group or subscribe to our mailing list you provide your consent to our collecting and storing your personal information. You will be unable to submit your enquiry or details to Orbition Group without consenting to our storing your personal data. This may include, but is not restricted to, your name; contact information; address; employment history; mobility and education.

During telephone conversations and in-person interviews we may collect personal information with regard to employment preferences, strengths and work experience, all of which may be stored on your personal record. This information facilitates our ability to support your career search and to provide a basis for recommendation when introducing candidates to clients for a particular role.

By explicitly providing consent when you register with Orbition Group you are providing permission for our storage of this information. Orbition Group will never share personal information or a Curriculum Vitae (CV) with a third party without your explicit consent.

Due to the nature of commercial recruitment and staffing, a significant number of candidates reconnect with our organisation periodically when they are interested in a new opportunity. It is not uncommon for this to occur years after we have placed them in a client role. For this reason, your consent includes explicit consent to retain your personal details until you wish us to delete your records from our database or refrain from further engagement.

If you do not consent to Orbition Group storing your personal data or setting up a personal profile for you, please do not submit your Curriculum Vitae (CV) for any roles advertised on our website.

We are unable to process your application without receipt of consent to process and store your personal information.

We may on occasion contact candidates stored in our database who are not actively looking for new employment. By providing consent to our storage of your personal data you are also providing consent for Orbition Group to contact you if we receive details of a role which specifically matches your career goals.

We will do this only where you meet a detailed job description provided by one of our clients, and where you have provided explicit consent to our storing and using your data.

Orbition Group’s retention of your data

Orbition Group will only retain your information for as long as is necessary for us to use your information as described above or to comply with legal obligations.

However, Orbition Group may retain some of your information after you cease to use our services, if we believe in good faith that it is necessary to meet our legal obligations, such as retaining the information for tax and accounting purposes.

When determining the relevant retention periods in each case, we will consider factors including:

(a) Orbition Group’s contractual obligations and rights in relation to the information involved;

(b) legal obligation(s) under applicable law to retain data for a defined period of time;

(c) statute of limitations under applicable law(s);

(d) in case of disputes;

(e) if you have made a request to have your information deleted; and

(f) guidelines issued by relevant data protection authorities.

In all other cases, we securely erase your information once this is no longer needed.

To unsubscribe from any of Orbition Group’s mailing lists or for removal from email marketing platforms at any time please email hello@orbitiongroup.com

Sharing of your data

Orbition Group will never share our candidates’ personal details or Curriculum Vitae (CV) with a third party without the candidate’s explicit permission.

Orbition Group’s legal basis for using your information

For prospective candidates, contractors, referees and clients, our processing is necessary for our legitimate interests – Orbition Group needs this information in order to be able to assess suitability for potential client roles, to find potential candidates and to contact clients and referees and suppliers.

If you are interviewed and submitted as a candidate, then this may involve the processing of more detailed personal data including sensitive data such as health information that you or others provide about you. In that case we always ask for your consent before undertaking such processing.

Contacting Orbition Group directly

If you contact one of our consultants or employees directly and request they consult with you regarding your career search, or regarding a particular job role, you are giving your consent to Orbition Group’s processing your email and the data contained within your email for lawful purposes, as per the clauses listed above.

By sending a copy of your Curriculum Vitae (CV) directly to a Orbition Group employee you are giving consent to Orbition Group’s processing and storing that information.

In accordance with our privacy policy, we will not share your information with any third party without your explicit consent.

Your data rights

Under law, you have a number of rights when it comes to your personal data.

Further information and advice about these rights is available at https://www.eugdpr.org/

1.The right to be informed

You have the right to be provided with clear, transparent and easily understandable information about how Orbition Group use’s your information and your rights. That is the purpose of the information contained in this Policy.

2.The right of access

You have the right to obtain access to your information (if it is being processing by Orbition Group), and certain other information (similar to that provided in this Privacy Policy). Once Orbition Group have verified your identity we will provide the information you requested within 30 days. In the unlikely event that you find personal data stored about you by Orbition Group is inaccurate, you must advise us immediately. We will amend your personal registration within two weeks of receiving the correct information from you.

If you would like to request for access to your personal information, please contact: hello@orbitiongroup.com

3.The right to rectification

You are entitled to have your information corrected if it is inaccurate or incomplete.

4.The right to erasure

You are entitled to request the deletion or removal of your information where there is no legitimate reason for Orbition Group to continue using it. This is not a general right to erasure and there are some exceptions.

5.The right to restrict processing

You have rights to restrict, block or limit further use of your information. When processing is restricted, Orbition Group may still store your information but may not use it further. We keep lists of people who have asked for further use of their information to be ‘blocked’ to make sure the restriction is respected in future.

Request for personal data to be removed or deleted

You have the right to be deleted from Orbition Group’s systems. Upon receipt of a request to delete your personal information, Orbition Group will ensure that your personal record is deleted within 30 days.

Where Orbition Group has placed a candidate in a client role, Orbition Group is required to retain evidence of that placement so that contractual obligations can be met by the client. Orbition Group will however take steps to ensure only minimal personal data is retained and will not make further contact with the candidate.

Where Orbition Group has previously received permission to share personal information with a third party, for example submitted a candidate’s CV for a role, we agree to advise that third party of your wish to be forgotten if communication has taken place within the last twelve months. Should you wish to be deleted from Orbition Group’s database, please contact hello@orbitiongroup.com clearly stating your request.

Orbition Group typically acts on all data and information requests free of charge, but may charge a reasonable fee to cover administrative costs of providing the information for:

excessive/repeated requests, or
repeated or multiple copies of the same information.

There may be instances where Orbition Group may be entitled to refuse to act on the request.

In all instances Orbition Group will endeavour to act as promptly as possible, typically within one month from receipt of any request. If the request will take longer to process, Orbition Group will advise accordingly.

Notifications of data breach

If personal data we hold about you is subject to a breach or unauthorised disclosure or access, Orbition Group will report this to the Information Commissioner’s Office (ICO).

If any breach creates a risk to your data rights and freedoms, we will notify you as soon as possible.

Use of cookies

Orbition Group’s website uses cookies to better the users experience while visiting the website. Where applicable this website uses a cookie control system allowing the user on their first visit to the website to allow or disallow the use of cookies on their computer / device. This complies with recent legislation requirements for websites to obtain explicit consent from users before leaving behind or reading files such as cookies on a user’s computer / device.

If you would like to restrict the use of cookies you can control this in your Internet browser. Links to advice on how to do this for the most popular Internet browsers are provided below for convenience and will be available for the Internet browser of your choice either online or via software user help.

Internet Explorer

http://windows.microsoft.com/en-GB/windows7/Block-enable-or-allow-cookies

Google Chrome

https://support.google.com/chrome/bin/answer.py?hl=en-GB&answer=95647&p=cpn_cookies

Mozilla Firefox

http://support.mozilla.org/en-US/kb/Blocking%20cookies

Apple Safari

http://docs.info.apple.com/article.html?artnum=32467

Complaints procedure

If you have a complaint about the way your data is stored or managed by Orbition Group, please contact us at:

hello@orbitiongroup.com

If you wish to escalate your complaint or are not satisfied with how your complaint is handled by Orbition Group, you can make a formal complaint to the Information Commissioner’s Office (ICO) via http://www.ico.org.uk/

or by writing to:

Information Commissioner’s Office (ICO)
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

Orbition Group – Events & Media Privacy Policy

This privacy policy applies between you, the User of this Website and Orbition Group, the owner and provider of this Website. Orbition Group takes the privacy of your information very seriously. This privacy policy applies to our use of any and all Data collected by us or provided by you in relation to your use of the Website. Please read this privacy policy carefully.

Definitions and interpretation

1. In this privacy policy, the following definitions are used:

Data – collectively all information that you submit to Orbition Group via the Website. This definition incorporates, where applicable, the definitions provided in Data Protection Act 2018 and the UK General Data Protection Regulation (UK GDPR).

Cookies – a small text file placed on your computer by this Website when you visit certain parts of the Website and/or when you use certain features of the Website. Details of the cookies used by this Website are set out in the clause below (Cookies);

Orbition Group, or us – Orbition Group, a company incorporated in England and Wales with registered number12856810, whose registered office is at 27 Old Gloucester Street, London, United Kingdom, WC1N 3AX.

UK Privacy and Electronic Communications Regulations 2003 (as amended), and any successor legislation – the Privacy and Electronic Communications (EC Directive) Regulations 2003 as amended by the Privacy and Electronic Communications (EC Directive) (Amendment) Regulations 2011;

UK GDPR means the retained EU law version of the General Data Protection Regulation ((EU) 2016/679) as it forms part of the law of England and Wales by virtue of section 3 of the European Union (Withdrawal) Act 2018.

[our data] We process your personal data on the legal basis of consent, legitimate interests, and, where applicable, the performance of a contract, in accordance with the UK GDPR.

[accessing your own data] You have the right to request access to, correction of, erasure of, or restriction on processing of your personal data, and to object to processing or request data portability, as outlined under the UK GDPR. To make a request, contact info@orbitiongroup.com. We will not charge a fee unless requests are manifestly unfounded or excessive.

[general] If you are unhappy with how we handle your personal data, you have the right to lodge a complaint with the UK Information Commissioner’s Office (ICO): www.ico.org.uk.

User or you – any third party that accesses the Website and is not either (i) employed by Orbition Group and acting in the course of their employment or (ii) engaged as a consultant or otherwise providing services to Orbition Group and accessing the Website in connection with the provision of such services; and

Website – the website that you are currently using, www.orbitiongroup.com, and any sub-domains of this site unless expressly excluded by their own terms and conditions.

1. In this privacy policy, unless the context requires a different interpretation:
   1. the singular includes the plural and vice versa;
   2. references to sub-clauses, clauses, schedules or appendices are to sub-clauses, clauses, schedules or appendices of this privacy policy;
   3. a reference to a person includes firms, companies, government entities, trusts and partnerships;
   4. “including” is understood to mean “including without limitation”;
   5. reference to any statutory provision includes any modification or amendment of it;
   6. the headings and sub-headings do not form part of this privacy policy.

Scope of this privacy policy

1. This privacy policy applies only to the actions of Orbition Group and Users with respect to this Website. It does not extend to any websites that can be accessed from this Website including, but not limited to, any links we may provide to social media websites.

Data collected

1. We may collect the following Data, which includes personal Data, from you:
   1. Name
   2. Job Title;
   3. Profession;
   4. Contact Information such as email addresses and telephone numbers;
   5. Demographic information such as post code, preferences and interests;
   6. IP address (automatically collected);
   7. Web browser type and version (automatically collected);
   8. A list of URLs starting with a referring site, your activity on this Website, and the site you exit to (automatically collected);
   9. in each case, in accordance with this privacy policy.

Our use of Data

1. For purposes of the Data Protection Act 2018 and the UK General Data Protection Regulation (UK GDPR), Orbition Group is the “data controller”.
2. We will retain any Data you submit for 12 months.
3. Unless we are obliged or permitted by law to do so, and subject to any third-party disclosures specifically set out in this policy, your Data will not be disclosed to third parties. This does not include our affiliates and / or other companies within our group.
4. All personal Data is stored securely in accordance with the principles ofData Protection Act 2018 and the UK General Data Protection Regulation (UK GDPR). For more details on security see the clause below (Security).
5. Any or all of the above Data may be required by us from time to time in order to provide you with the best possible service and experience when using our Website. Specifically, Data may be used by us for the following reasons:
   1. internal record keeping;
   2. improvement of our products / services;
   3. transmission by email of promotional materials that may be of interest to you;
   4. contact for market research purposes which may be done using email, telephone, fax or mail. Such information may be used to customise or update the Website;

in each case, in accordance with this privacy policy.

For more details on Campaigns and Projects see further information below.

Third party websites and services

1. Orbition Group may, from time to time, employ the services of other parties for dealing with certain processes necessary for the operation of the Website. The providers of such services have access to certain personal Data provided by Users of this Website.
2. Any Data used by such parties is used only to the extent required by them to perform the services that we request. Any use for other purposes is strictly prohibited. Furthermore, any Data that is processed by third parties will be processed within the terms of this privacy policy and in accordance with the Data Protection Act 2018 and the UK General Data Protection Regulation (UK GDPR).

Links to other websites

1. This Website may, from time to time, provide links to other websites. We have no control over such websites and are not responsible for the content of these websites. This privacy policy does not extend to your use of such websites. You are advised to read the privacy policy or statement of other websites prior to using them.

Changes of business ownership and control

1. Orbition Group may, from time to time, expand or reduce our business and this may involve the sale and/or the transfer of control of all or part of Orbition Group. Data provided by Users will, where it is relevant to any part of our business so transferred, be transferred along with that part and the new owner or newly controlling party will, under the terms of this privacy policy, be permitted to use the Data for the purposes for which it was originally supplied to us.
2. We may also disclose Data to a prospective purchaser of our business or any part of it.
3. In the above instances, we will take steps with the aim of ensuring your privacy is protected.

Controlling use of your Data

1. Wherever you are required to submit Data, you will be given options to restrict our use of that Data. This may include the following:
2. use of Data for direct marketing purposes; and
3. sharing Data with third parties.

Functionality of the Website

1. To use all features and functions available on the Website, you may be required to submit certain Data.
2. You may restrict your internet browser’s use of Cookies. For more information see the clause below (Cookies).

Accessing your own Data

1. You have the right to ask for a copy of any of your personal Data held by Orbition Group (where such Data is held) on payment of a small fee, which will not exceed £10.

Security

1. Data security is of great importance to Orbition Group and to protect your Data we have put in place suitable physical, electronic and managerial procedures to safeguard and secure Data collected via this Website.
2. If password access is required for certain parts of the Website, you are responsible for keeping this password confidential.
3. We endeavour to do our best to protect your personal Data. However, transmission of information over the internet is not entirely secure and is done at your own risk. We cannot ensure the security of your Data transmitted to the Website.

Cookies

1. This Website may place and access certain Cookies on your computer. Orbition Group uses Cookies to improve your experience of using the Website and to improve our range of products and services. Orbition Group has carefully chosen these Cookies and has taken steps to ensure that your privacy is protected and respected at all times.
2. All Cookies used by this Website are used in accordance with current UK Privacy and Electronic Communications Regulations 2003 (as amended), and any successor legislation.
3. Before the Website places Cookies on your computer, you will be presented with a message bar requesting your consent to set those Cookies. By giving your consent to the placing of Cookies, you are enabling Orbition Group to provide a better experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of the Website may not function fully or as intended.
4. This Website may place the following Cookies:
5. Type of CookiePurposeStrictly necessary cookies. These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services. Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily. Functionality cookies. These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).Targeting cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.
6. You can choose to enable or disable Cookies in your internet browser. By default, most internet browsers accept Cookies but this can be changed. For further details, please consult the help menu in your internet browser.
7. You can choose to delete Cookies at any time; however you may lose any information that enables you to access the Website more quickly and efficiently including, but not limited to, personalisation settings.
8. It is recommended that you ensure that your internet browser is up-to-date and that you consult the help and guidance provided by the developer of your internet browser if you are unsure about adjusting your privacy settings.

Transfers outside the European Economic Area

1. Data which we collect from you may be stored and processed in and transferred to countries outside of the European Economic Area (EEA). For example, this could occur if our servers are located in a country outside the EEA or one of our service providers is situated in a country outside the EEA. These countries may not have data protection laws equivalent to those in force in the EEA.
2. If we transfer Data outside the EEA in this way, we will take steps with the aim of ensuring that your privacy rights continue to be protected as outlined in this privacy policy. You expressly agree to such transfers of Data.

General

1. You may not transfer any of your rights under this privacy policy to any other person. We may transfer our rights under this privacy policy where we reasonably believe your rights will not be affected.
2. If any court or competent authority finds that any provision of this privacy policy (or part of any provision) is invalid, illegal or unenforceable, that provision or part-provision will, to the extent required, be deemed to be deleted, and the validity and enforceability of the other provisions of this privacy policy will not be affected.
3. Unless otherwise agreed, no delay, act or omission by a party in exercising any right or remedy will be deemed a waiver of that, or any other, right or remedy.
4. This Agreement will be governed by and interpreted according to the law of England and Wales. All disputes arising under the Agreement will be subject to the exclusive jurisdiction of the English and Welsh courts.

Changes to this privacy policy

1. Orbition Group reserves the right to change this privacy policy as we may deem necessary from time to time or as may be required by law. Any changes will be immediately posted on the Website and you are deemed to have accepted the terms of the privacy policy on your first use of the Website following the alterations. You may contact Orbition Group by email at info@orbitiongroup.com