2. Our legal basis for processing your data
3. What kind of personal data do we collect?
4. How do we collect your personal data?
5. How do we use your personal data?
6. Who do we share your personal data with?
7. How do we safeguard your personal data?
8. How long do we keep your personal data for?
9. How can you access, amend or take back the personal data that you have given to us?
10. How you can get in touch with us
11. Details of your local supervisory authority
It describes how we collect, use and process your personal data, and how, in doing so, we comply with our legal obligations to you. Your privacy is important to us, and we are committed to protecting and safeguarding your data privacy rights.
(2) Our legal bases for processing your data
Article 6(1)(f) of the GDPR is the one that is relevant here - it says that we can process your data where it "is necessary for the purposes of the legitimate interests pursued by [us] or by a third party, except where such interests are overridden by the interests or fundamental rights or freedoms of [you] which require protection of personal data."
We don't think that any of the following activities prejudice individuals in any way - in fact, they help us to offer you a more tailored and efficient service. However, you do have the right to object to us processing your personal data on this basis. If you would like to know more about how to do so, please see the section 'How can you access, amend or take back the personal data that you have given to us?'
Legitimate interests for candidate data:
We think it's reasonable that if you have previously registered with us, been telephone interviewed by us, attended a client interview through us, been placed by us into a new job, or, agreed with us that we can keep your details on file that you are happy for us to use your personal data to provide our recruitment services to you.
We think it's reasonable to expect that if you are looking for employment or have posted your professional CV information on a job board or professional networking site, you are happy for us to collect and otherwise use your personal data to offer or provide our recruitment services to you, share that information with prospective employers and assess your skills against our bank of vacancies.
Once it's looking like you may get the job, your prospective employer may also want to double check any information you've given us (such as the results from psychometric evaluations or skills tests, or referees) or to confirm your references, qualifications and criminal record, to the extent that this is appropriate and in accordance with local laws. We need to do these things so that we can function as a profit-making business, and to help you and other candidates get the jobs you deserve.
We want to provide you with tailored job recommendations and relevant articles to read to help you on your job hunt. We therefore think it's reasonable for us to process your data to make sure that we send you the most appropriate content.
We also need to use your data for our internal administrative activities, like payroll and invoicing where relevant.
We have our own obligations under the law, which it is a legitimate interest of ours to insist on meeting! If we believe in good faith that it is necessary, we may therefore share your data in connection with crime detection, tax collection or actual or anticipated litigation.
Legitimate interests for client data:
To ensure that we provide you with the best service possible, we store your personal data and/or the personal data of individual contacts at your organisation as well as keeping records of our conversations, meetings, registered jobs and placements. From time to time, we may also ask you to undertake a customer satisfaction survey. We think this is reasonable - we deem these uses of your data to be necessary for our legitimate interests as an organisation providing various recruitment services to you.
Legitimate interests for supplier data:
We use and store the personal data of individuals within your organisation to facilitate the receipt of services from you as one of our suppliers. We also hold your financial details, so that we can pay you for your services. We deem all such activities to be necessary within the range of our legitimate interests as a recipient of your services.
Legitimate interests for people whose data we receive from candidates:
If you have been put down by a candidate as one of their referees, we use your personal data in order to contact you for a reference. This is a part of our quality assurance procedure and so we deem this to be necessary for our legitimate interests as an organisation offering recruitment services and employing people ourselves.
In certain circumstances, we are required to obtain your consent to the processing of your personal data in relation to certain activities. Depending on exactly what we are doing with your information, this consent will be opt-in consent or soft opt-in consent.
Article 4(11) of the GDPR states that (opt-in) consent is "any freely given, specific, informed and unambiguous indication of the data subject's wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her." In plain language, this means that:
you have to give us your consent freely, without us putting you under any type of pressure;
you have to know what you are consenting to - so we'll make sure we give you enough information;
you should have control over which processing activities you consent to and which you don't. We provide these finer controls within our privacy preference centre; and
you need to take positive and affirmative action in giving us your consent - we're likely to provide a tick box for you to check so that this requirement is met in a clear and unambiguous fashion.
We will keep records of the consents that you have given in this way.
We have already mentioned that, in some cases, we will be able to rely on soft opt-in consent. We are allowed to market products or services to you which are related to the recruitment services we provide as long as you do not actively opt-out from these communications.
As we have mentioned, you have the right to withdraw your consent to these activities. You can do so at any time, and details of how to do so can be found in the section 'How can you access, amend or take back the personal data that you have given to us?'
(3) What kind of personal data do we collect?
Here's a more detailed look at the information we may collect. The information described below is, of course, in addition to any personal data we are required by law to process in any given situation.
In order to provide the best possible employment opportunities that are tailored to you, we need to process certain information about you.
We only ask for details that will genuinely help us to help you, such as your name, age, contact details, education details, employment history, immigration status, (and of course you may choose to share other relevant information with us).
Where appropriate and in accordance with local laws and requirements, we may also collect information related to your health, diversity information or details of any criminal convictions.
Depending on the relevant circumstances and applicable local laws and requirements, we may collect some or all of the information listed below to enable us to offer you employment opportunities which are tailored to your circumstances and your interests.
Date of birth (upon placement only for employment contract and other checks);
Immigration status (whether you need a work permit);
Nationality/citizenship/place of birth;
A copy of your driving licence and/or passport/identity card;
Social security number (or equivalent in your country) and any other tax-related information;
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, interviews or conversations we've had
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;
Details of any criminal convictions
Details of current renumeration, pension and other benefits
Details of locations that you are willing to work in or relocate to
If you are our customer, we need to collect and use information about you, or individuals at your organisation, in the course of providing you services such as: (i) finding candidates who are the right fit for you or your organisation; and/or (ii) notifying you of content published by Frankland Associates Ltd which is likely to be relevant and useful to you.
The data we collect about Clients is actually very limited. We generally only need to have your contact details or the details of individual contacts at your organisation (such as their names, telephone numbers and email addresses) to enable us to ensure that our relationship runs smoothly.
We may also hold extra information that someone in your organisation has chosen to tell us.
We don't collect much data about Suppliers - we simply need to make sure that our relationship runs smoothly. We'll collect the details for our contacts within your organisation, such as names, telephone numbers and email addresses. We'll also collect bank details, so that we can pay you. We may also hold extra information that someone in your organisation has chosen to tell us.
Website users in all categories: Clients, Candidates and Suppliers:
We collect a limited amount of data from our website users which we use to help us to improve your experience when using our website and to help us manage the services we provide. This includes information such as how you use our website, the frequency with which you access our website, and the times that our website is most popular - all via Google Analytics.
If you email us a CV via our website, the document is not stored on our site, it is emailed directly to us
We do not store any personal information on our website.
People whose data we receive from candidates:
In order to provide Candidates with suitable employment opportunities, we may need some basic background information. We only ask for very basic contact details, so that we can get in touch with you either for a reference for one of our Candidates.
(4) How do we collect your personal data?
We collect candidate personal data in three primary ways:
1. Personal data that you, the candidate, give to us;
2. Personal data that we receive from other sources; and
3. Personal data that we collect automatically.
1. Personal data you give to us
Toro Recruitment Limited needs to know certain information about you in order to provide a tailored service. This will enable us to provide you with the best opportunities and should save you time in not having to trawl through information about jobs and services that are not relevant to you.
There are numerous ways you can share your information with us. It all depends on what suits you. These may include:
Emailing your CV to a consultant directly
Being interviewed by them
Applying for jobs through a job board
Calling us on any of our contact phone numbers including landline and mobile numbers, and expressing an interest in jobs
Emailing us directly on any of our email addresses
Contacting us via LinkedIn to express your interest in jobs or other opportunities.
Connecting with us on LinkedIn (your information remains on this platform until such time as we make contact with you)
2. Personal data we receive from other sources
We also receive personal data about candidates from other sources. Depending on the relevant circumstances and applicable local laws and requirements, these may include personal data received in the following situations:
Your referees may disclose personal information about you;
Our Clients may share personal information about you with us;
We may obtain information about you from searching for potential candidates from third party sources, such as LinkedIn and other job sites;
Your name and contact details may be given to us as a Referral, from another Candidate, or, Client, or Supplier of ours
3. Personal data we collect automatically
To the extent that you access our website or read or click on an email from us, where appropriate and in accordance with any local laws and requirements, we may also collect your data automatically or through you providing it to us.
We collect Client personal data in three ways:
1. Personal data that we receive directly from you;
2. Personal data that we receive from other sources; and
3. Personal data that we collect automatically.
Personal data that we receive directly from you
We both share the same goal - to make sure that you have the best staff for your organisation. We will receive data directly from you in two ways:
Where you contact us proactively, usually by phone or email, LinkedIn message or other messaging; and/or
Where we contact you, either by phone or email, or through our consultants' business development activities more generally.
Personal data we receive from other sources
Where appropriate and in accordance with any local laws and requirements, we may seek more information about you or your colleagues from other sources generally by way of due diligence or other market intelligence including:
From third party market research and by analysing online and offline media (which we may do ourselves, or employ other organisations to do for us);
From delegate lists at relevant events; and
From other limited sources and third parties (for example from our candidates to the extent that they provide us with your details to act as a referee for them).
We collect your personal data during the course of our work with you.
People whose data we receive from candidates:
We collect your contact details only where a candidate gives them to us in order for you to serve as a referee.
(5) How do we use your personal data?
The main reason for using your personal details is to help you find employment or other work roles that might be suitable for you. The more information we have about you, your skillset and your ambitions, the more bespoke we can make our service. Where appropriate and in accordance with local laws and requirements, we may also use your personal data for things like marketing. Where appropriate, we will seek your consent to undertake some of these activities.
We generally use Candidate data in three ways:
3.To help us to establish, exercise or defend legal claims
Candidate Recruitment Activities
Obviously, our main area of work is recruitment - connecting the right candidates with the right jobs. We've listed below various ways in which we may use and process your personal data for this purpose, where appropriate and in accordance with any local laws and requirements. Please note that this list is not exhaustive.
We may use your personal data for the below purposes if we deem it necessary to do so for our legitimate interests. If you want to know more about what this means in the section 'Our legal basis for processing your data'.
Collecting your data from you and other sources, such as LinkedIn;
Storing your details (and updating them when necessary) on our database, so that we can contact you in relation to recruitment;
Providing you with our recruitment services and to facilitate the recruitment process;
Enabling you to submit your CV, apply online for jobs
Enabling you to subscribe to alerts about jobs we think may be of interest to you;
Assessing data about you against vacancies which we think may be suitable for you;
Sending your information to Clients, in order to apply for jobs or to assess your eligibility for jobs;
Allowing you to participate in the interactive features of our services, when you choose to do so;
Carrying out our obligations arising from any contracts entered into between us;
Facilitating invoicing processes;
Verifying details you have provided, using third party resources such as references, qualifications and potentially any criminal convictions, to the extent that this is appropriate;
If you are not happy about this, in certain circumstances you have the right to object and can find out more about how and when to do this in the section 'How can you access, amend or take back the personal data that you have given to us?'
Candidate Marketing Activities
We may periodically send you information that we think you may find interesting, or to ask for your help with connecting other Candidates with jobs.
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;
We need your consent for some aspects of these activities which are not covered by our legitimate interests
Soft opt-in consent is a specific type of consent which applies where you have previously engaged with us (for example by submitting a job application or CV, or phoning us, or asking to be kept on file, or registering a vacancy to be filled), and, we are marketing other recruitment-related services.
Under 'soft opt-in' consent, we will take your consent as given unless or until you opt out.
For most people, this is beneficial as it allows us to suggest other jobs to you alongside the specific one you applied for, significantly increasing the likelihood of us finding you a new position.
For other types of e-marketing, we are required to obtain your explicit consent.
All our marketing is based on what we think will serve our Clients and Candidates best, but we know we won't always get it right for everyone.
If you want to know more about how we obtain consent, please see the section 'Our legal basis for processing your data'.
If you are not happy about our approach to marketing, you have the right to withdraw your consent at any time and can find out more about how to do so in the section 'How can you access, amend or take back the personal data that you have given to us?'
Nobody's perfect, even though we try to be. We want to let you know that even if you have opted out from our marketing communications through the options given here, it is possible that your details may be recaptured through public sources in an unconnected marketing campaign.
We will try to make sure this doesn't happen, but if it does, we're sorry.
Also, it may take some time for the request to be confirmed as we sometimes schedule email marketing in advance. Your request may miss the cut off point for that particular mailing.
So, we'd just ask that in those circumstances you opt out again.
People whose data we receive from candidates
We use referees' personal data to help our Candidates to find employment which is suited to them. If we are able to verify their details and qualifications, we can make sure that they are well matched with prospective employers.
We will only use the information that our Candidate gives us about you for the following purposes:
If you were put down by our Candidate as a referee, we will contact you in order to take up a reference. This is an important part of our Candidate quality assurance process and could be the difference between the individual getting a job or not.
(6) Who do we share your personal data with?
We may share your personal data with various parties, in various ways and for various reasons.
Primarily we will share your information with prospective employers to increase your chances of securing the job you want.
Who else do we share your Candidate personal data with?
In the case of Candidates: potential employers and other recruitment agencies/organisations to increase your chances of finding employment;
Individuals and organisations who hold information related to your reference or application to work with us, such as current, past or prospective employers, educators and examining bodies and employment and recruitment agencies;
Tax, audit, or other authorities, when we believe in good faith that the law or other regulation requires us to share this data (for example, because of a request by a tax authority or in connection with any anticipated litigation);
Third party service providers who perform functions on our behalf (including external consultants, business associates and professional advisers such as lawyers, auditors and accountants, technical support functions and IT consultants carrying out testing and development work on our business technology systems);
Third party outsourced IT and document storage providers where we have an appropriate processing agreement (or similar protections) in place;
Marketing technology platforms and suppliers
We will share your data primarily to ensure that we provide you with a suitable pool of Candidates; Unless you specify otherwise, we may share your information with associated third parties such as our service providers to help us meet these aims.
Unless you specify otherwise, we may share your information with any associated third parties such as our service providers and organisations to whom we provide services.
(7) How do we safeguard your personal data?
We are committed to taking all reasonable and appropriate steps to protect the personal information that we hold from misuse, loss, or unauthorised access.
We do this by having in place a range of appropriate technical and organisational measures.
These include measures to deal with any suspected data breach.
If you suspect any misuse or loss of or unauthorised access to your personal information, please let us know immediately.
You can contact us by emailing
(8) How long do we keep your personal data for?
If we have not had meaningful contact with you (or, where appropriate, the company you are working for or with) for a period of five years, we will Delete your personal data from our systems unless we believe in good faith that the law or other regulation requires us to preserve it (for example, because of our obligations to tax authorities - or in connection with any anticipated litigation).
When we refer to "meaningful contact", we mean, for example, communication between us (either verbal or written), or where you are actively engaging with our services - online, by email, by telephone, over other social media sites such as LI, Facebook and Twitter.
If you are a Candidate, we will consider there to be meaningful contact with you if you submit your updated CV to us.
We will also consider it meaningful contact if you communicate with us about potential roles, either by verbal or written communication or click through from any of our marketing communications.
Your receipt, opening or reading of an email or other digital message from us will not count as meaningful contact - this will only occur in cases where you click-through or reply directly.
(9) How can you access, amend or take back the personal data that you have given to us?
One of the GDPR's main objectives is to protect and clarify the rights of EU citizens and individuals in the EU with regards to data privacy.
This means that you retain various rights in respect of your data, even once you have given it to us. These are described in more detail below.
If your interests or requirements change, you can unsubscribe from part or all of our marketing content by clicking the unsubscribe link in the email
If you would like to exercise any of these rights, or withdraw your consent to the processing of your personal data (where consent is our legal basis for processing your personal data), details of how to contact us can be found in the section titled 'How can you access, amend or take back the personal data that you have given to us?, or, in this section: 'How you can get in touch with us'
Please note that we may keep a record of your communications to help us resolve any issues which you raise.
You may ask to unsubscribe from job alerts at any time.
Details of how to do so can be found here: 'How can you access, amend or take back the personal data that you have given to us? or, in this section: 'How you can get in touch with us', or you can simply click the unsubscribe link in the email.
Please keep us informed if your personal information changes during the period for which we hold your data. It is important that the personal information we hold about you is accurate and current.
Even if we already hold your personal data, you still have various rights in relation to it.
To get in touch about these, please contact us. We will seek to deal with your request without undue delay, and in any event in accordance with the requirements of any applicable laws. Please note that we may keep a record of your communications to help us resolve any issues which you raise.
Right to object:
This right enables you to object to us processing your personal data where we do so for one of the following four reasons:
1.Our legitimate interests;
2.To enable us to perform a task in the public interest or exercise official authority;
3.To send you direct marketing materials; and
4. For scientific, historical, research, or statistical purposes.
The "legitimate interests" and "direct marketing" categories above are the ones most likely to apply to our Website Users, Candidates, Clients and Suppliers.
If we are using your data because we deem it necessary for our legitimate interests to do so, and you do not agree, you have the right to object.
We will respond to your request within 30 days (although we may be allowed to extend this period in certain cases). Generally, we will only disagree with you if certain limited conditions apply.
If your objection relates to us processing your personal data because we deem it necessary for your legitimate interests, we must act on your objection by ceasing the activity in question unless: we can show that we have compelling legitimate grounds for processing which overrides your interests; or we are processing your data for the establishment, exercise or defence of a legal claim.
If your objection relates to direct marketing, we must act on your objection by ceasing this activity.
Right to withdraw consent:
Where we have obtained your consent to process your personal data for certain activities (for example, consent to market to you outside our legitimate interest activities), you may withdraw this consent at any time and we will cease to carry out the particular activity that you previously consented to unless we consider that there is an alternative reason to justify our continued processing of your data for this purpose in which case we will inform you of this condition.
Data Subject Access Requests (DSAR):
Just so it's clear, you have the right to ask us to confirm what information we hold about you at any time, and you may ask us to modify, update or delete such information.
If we provide you with access to the information we hold about you, we will not charge you for this unless your request is "manifestly unfounded or excessive". If you request further copies of this information from us, we may charge you a reasonable administrative cost where legally permissible. Where we are legally permitted to do so, we may refuse your request. If we refuse your request, we will always tell you the reasons for doing so
At this point we may comply with your request or, additionally do one of the following:
we may ask you to verify your identity or ask for more information about your request; and where we are legally permitted to do so, we may decline your request, but we will explain why if we do so.
Important Point regarding DSAR requests
Please consider that in making a DSAR, you may be required to provide to us MORE information than we currently hold on you, in order to verify your identity.
Right to erasure:
In certain situations, you have the right to request us to "erase" your personal data.
We will respond to your request within 30 days (although we may be allowed to extend this period in certain cases) and will only disagree with you if certain limited conditions apply.
If we do agree to your request, we will delete your data but will generally assume that you would prefer us to keep a note of your name on our register of individuals who would prefer not to be contacted. That way, we will minimise the chances of you being contacted in the future where your data are collected in unconnected circumstances. If you would prefer us not to do this, you are free to say so.
You have the right to request that we erase your personal data in certain circumstances. Normally, the information must meet one of the following criteria:
the data are no longer necessary for the purpose for which we originally collected and/or processed them;
where previously given, you have withdrawn your consent to us processing your data, and there is no other valid reason for us to continue processing;
the data has been processed unlawfully (i.e. in a manner which does not comply with the GDPR);
it is necessary for the data to be erased in order for us to comply with our legal obligations as a data controller; or
if we process the data because we believe it necessary to do so for our legitimate interests, you object to the processing and we are unable to demonstrate overriding legitimate grounds for our continued processing
We would only be entitled to refuse to comply with your request for one of the following reasons:
to exercise the right of freedom of expression and information;
to comply with legal obligations or for the performance of a public interest task or exercise of official authority;
for public health reasons in the public interest;
for archival, research or statistical purposes; or
to exercise or defend a legal claim.
When complying with a valid request for the erasure of data we will take all reasonably practicable steps to delete the relevant data.
Right to restrict processing:
You have the right to request that we restrict our processing of your personal data in certain circumstances. This means that we can only continue to store your data and will not be able to carry out any further processing activities with it until either:
One of the circumstances listed below is resolved;
(ii) you consent; or
(iii) further processing is necessary for either the establishment, exercise or defence of legal claims, the protection of the rights of another individual, or reasons of important EU or Member State public interest.
The circumstances in which you are entitled to request that we restrict the processing of your personal data are:
where you dispute the accuracy of the personal data that we are processing about you. In this case, our processing of your personal data will be restricted for the period during which the accuracy of the data is verified;
where you object to our processing of your personal data for our legitimate interests. Here, you can request that the data be restricted while we verify our grounds for processing your personal data;
where our processing of your data is unlawful, but you would prefer us to restrict our processing of it rather than erasing it; and
where we have no further need to process your personal data but you require the data to establish, exercise, or defend legal claims.
If we have shared your personal data with third parties, we will notify them about the restricted processing unless this is impossible or involves disproportionate effort. We will, of course, notify you before lifting any restriction on processing your personal data.
Right to rectification:
You also have the right to request that we rectify any inaccurate or incomplete personal data that we hold about you. If we have shared this personal data with third parties, we will notify them about the rectification unless this is impossible or involves disproportionate effort. Where appropriate, we will also tell you which third parties we have disclosed the inaccurate or incomplete personal data to. Where we think that it is reasonable for us not to comply with your request, we will explain our reasons for this decision.
Right of data portability:
If you wish, you have the right to transfer your data from us to another data controller. We will help with this - either by directly transferring your data for you, or by providing you with a copy in a commonly used machine-readable format.
Right to lodge a complaint with a supervisory authority:
You also have the right to lodge a complaint with your local supervisory authority, details of which can be found in the 'Details of your local supervisory authority' section.
(10) How you can get in touch with us:
You can email us:
to access, amend or take back the personal data that you have given to us;
if you suspect any misuse or loss of or unauthorised access to your personal information;
to withdraw your consent to the processing of your personal data (where consent is the legal basis on which we process your personal data);
How you can get in touch with us to update your marketing preferences
You can email us at
Remember to contact us from the email address you are wishing to discuss, otherwise we may not find you on our database.
By email at firstname.lastname@example.org
Unit F5 Fareham Heights,
(11) Details of your local supervisory authority:
The Information Commissioner's Office.
The details below may change so please check the ICO website too
You can contact them in the following ways:
Phone:0303 123 1113
Information Commissioner's Office
Candidates - includes applicants for all roles advertised or promoted by Toro Recruitment Limited, including permanent, part-time and temporary positions and freelance roles with Toro Recruitment Limited's Clients; as well as people who have supplied a speculative CV to Toro not in relation to a specific job.
Clients - this category covers our customers, clients, and others to whom Toro provides services in the course of its business.
Delete - while we will endeavour to permanently erase your personal data once it reaches the end of its retention period or where we receive a valid request from you to do so, some of your data may still exist within our systems, for example if it is waiting to be overwritten. For our purposes, this data has been put beyond use, meaning that, while it still exists on an archive system, this cannot be readily accessed by any of our operational systems, processes or staff.
General Data Protection Regulation (GDPR) - a European Union statutory instrument which aims to harmonise European data protection laws. It has an effective date of 25 May 2018, and any references to it should be construed accordingly to include any national legislation implementing it.
Staff - includes employees engaged directly in the business of Toro Recruitment Limited (or who have accepted an offer to be engaged)
Suppliers - refers to partnerships and companies (including sole traders), and atypical workers such as independent contractors and freelance workers, who provide services to Toro Recruitment Limited.
Website Users - any individual who accesses the Toro Recruitment website.