Privacy Policy
Introduction
We at BrilliantIN Recruitment Ltd know it is a big responsibility to protect your personal data. This Privacy Notice is meant to help you understand what information we collect, why we collect it, and how you can update, manage, export, and delete your information.
We may from time to time update this Privacy Notice, where we deem it appropriate, we will seek to notify you about the changes, however, we recommend you review this page periodically.
This Privacy Notice was last updated on: 16th January 2024.
About Us
BrilliantIN Recruitment Ltd has a company registration number of 12710048. The registered address is Kings Court Business Centre, London Road, Hertfordshire, SG1 2NG.
For this Privacy Notice, BrilliantIN Recruitment Ltd is the controller of the personal data which is processed by it as a controller. Other BrilliantIN Recruitment Ltd entities may become joint controllers of your information from time to time.
Our Group Data Protection Officer is Linda Bryant. To contact us regarding our use of personal data, you may email us at [email protected] or [email protected]
Why do we have your information?
We process personal data to fulfil our contractual obligations to our customers and to otherwise improve and market our solutions.
There are various ways in which we may obtain your personal data.
For example, because:
- an organisation you work for uses one of our solutions;
- an organisation you have engaged with uses our solutions to provide or otherwise make available service to you;
- you have used one of our solutions where we process your data in our capacity as a data controller;
- you have contacted us;
- you work for us;
- you visited our website;
- your personal data was provided to us by a third party; or
- because of other lead-generating activities done by us.
On what legal basis do we have your information?
We will only ever process your personal data where we have a lawful basis to do so. We have expanded upon the reasons for us processing your personal data below.
Where an organisation you work for uses one of our solutions
If you use our solutions through your employer, for example, our HR, Payroll, or eLearning solutions, then we will process your personal data as a processor (your employer is the controller).
We recommend you read your employer’s relevant privacy documentation for information explaining what personal data is collected, and what for, etc.,
Third parties may also process your personal data (on our behalf). The details of these third parties will be included in the contract we hold with the controller (your employer).
To fulfil our contractual obligations with the controller, we may contact you from time to time regarding the solution. For example, regarding scheduled or non-scheduled downtime, or an update that you should know about (‘service messages’).
Some of our solutions also can capture your feedback regarding the use of the solution. Where this is enabled by your employer, and you choose to provide feedback to us, we will process a limited amount of your data in our capacity as a controller.
Our lawful basis for processing this data is legitimate interests. The legitimate interest sought is for us to understand how to improve the solution.
If you use our solutions via a third-party organisation; for example, to submit your CV to a recruitment agency, then we will process your personal data as a processor (the relevant third-party organisation is the controller).
We recommend you read the third-party organisation’s relevant privacy documentation for information explaining what personal data is collected, and what for, etc.,
Some of our solutions have dedicated privacy notices, where this is the case, these are accessible via our Security Portal or they may be accessible within the solution itself.
Third parties may also process your personal data (on our behalf). The details of these third parties will be included in the contract we hold with the controller.
Some of our solutions also can capture your feedback regarding the use of the solution. Where this is enabled by the organisation, and you choose to provide feedback to us, we will process a limited amount of your data in our capacity as a controller.
Our lawful basis for processing this data is legitimate interests. The legitimate interest sought is for us to understand how to improve the solution.
You have used one of our solutions where we process your data in our capacity as a data controller
We provide a limited number of solutions where some or all of your personal data is processed by BrilliantIN Recruitment Ltd in its capacity as a controller. For example,
Where you use any of our solutions and you’re an “administrator” user, we may collect your personal data in our capacity as a controller.
In this case, the information we process is limited to: your first name; surname; business email address; location; business phone number; user role(s); and last login date.
The lawful basis for processing your information is legitimate interests.
The legitimate interest pursued is to share service messages about the solution that is used and to market BrilliantIN Recruitment Ltd solutions which may be of interest to you.
The lawful basis for collecting and sharing your information with BrilliantIN Recruitment Ltd customers who have procured services from you as a Provider is contractual, as the processing is necessary for the performance of the contract with you. Where BrilliantIN Recruitment Ltd customer processes your information outside of the relevant solution, they are doing so as an independent controller of your information.
Where we use your information to market BrilliantIN Recruitment Ltd solutions which may be of interest to you, our lawful basis is legitimate interests. The legitimate interest pursued is to share service messages about the solution that is used and to market BrilliantIN Recruitment Ltd solutions which may be of interest to you.
The information we will process for marketing purposes is limited to business email address; business phone number; your name; company name; service category reference and which local authority you’re engaged with to provide services.
We use third-party solutions to store and otherwise process your information, they will therefore process your personal data on our behalf.
Where you have contacted us.
If you contact us, for example, for technical support, to inquire about our recruitment solutions, or to download some of our content, we will record the contact made and log the necessary details of the interaction on our systems. We process any personal data collected via these methods as a controller.
The data collected (which may be via telephone recording) may include your first and last name, the email address and telephone number you use for business purposes, your job title, and your employer.
Our lawful basis for processing your personal data in this case is legitimate interests. The legitimate interests pursued are to support us in delivering on our contractual obligations (where applicable), internal training, improving the quality of our services, making information available to you (including marketing), and or to resolve any conflict resolution (where applicable).
We use third-party solutions to record and log the contact made with us; they will therefore process your personal data on our behalf.
Where you work for BrilliantIN Recruitment Ltd
If you are an employee of ours, then we will process your personal data as a controller.
Our lawful basis for processing is described in the dedicated employee privacy notice.
The relevant privacy notice is made available to you on our internal systems. If you need help locating it, please ask your leader or the DPO.
Where you visit our website
Your personal data, such as your first and last name, telephone number, email address, postal address, job title, employer and any other relevant contact details may be collected by us when you contact us using any of our online forms.
The lawful basis for processing this information is legitimate interests. The legitimate interest pursued is to keep you informed about the solutions we offer which we think may be of interest to you (i.e., marketing).
We will also use cookies when you use our website and interact with us via email, to optimise your experience of us and our sites. Please see our Cookie Policy for more information.
Our lawful basis for processing personal data via cookies is consent. The legitimate interest sought is the administration, statistical analysis, and enhancement of our website.
All personal data collected by us through our website is done on the basis that we are the controller.
Where you choose to share your personal data with us through the mechanisms available via the website, we will process that data using third-party solutions.
These third parties will process your personal data on our behalf.
Where your data was provided to us by a third party.
We work with several reputable third parties for them supplying us with business contact details to allow us to market our solutions effectively. We may also collect information about you from other sources, for example, public sources or third-party social network sites.
Our lawful basis for processing is legitimate interests. The legitimate interest sought is the marketing of our available solutions.
All personal data obtained by us through our sources is done on the basis that we are the controller.
Where we obtain your personal data through these sources, we will process that data using third-party solutions. These third parties will process your personal data.
Where we collect your data through lead-generating activities done by us
We may collect your personal data through various lead-generating activities such as events, webinars, and other networking activities.
Our lawful basis for processing is legitimate interests. The legitimate interest sought is the marketing of our available solutions, or where relevant, engaging with you regarding a sales and purchase agreement.
All personal data collected by us is done on the basis that we are the controller.
Where we obtain your personal data through these activities, we will process that data using third-party solutions. These third parties will process your personal data on our behalf.
Sharing your personal data
We may have to ad hoc share your personal data with regulators, law enforcement bodies, government agencies, courts or other third parties where we think it’s necessary to comply with applicable laws or regulations, or to exercise, establish or defend our legal rights.
We have also partnered with reputable third parties to provide a best-in-class service offering to you and our wider customer base (which may include the marketing of BrilliantIN Recruitment Ltd solutions or compatible solutions provided by BrilliantIN Recruitment Ltd’s trusted partners). Where sharing your personal data with our trusted partners means a transfer to a third country (without an adequacy decision or adequacy regulations, as applicable) is to take place, we will ensure we put in place appropriate safeguards and supplementary measures to ensure an essentially equivalent level of protection (as compared to the UK and EU GDPR) to your personal data will be given.
We may also share your personal data with other members of BrilliantIN Recruitment Ltd:
We will only do this where we have a lawful basis for doing so, for example, fulfilment of contract or legitimate interests. Where the receiver of your personal data is a BrilliantIN Recruitment Ltd entity which is in a third country without an adequacy decision or adequacy regulation (as applicable), the transfer will be safeguarded by, at minimum, an intra-group agreement (which includes a recognised model clause and the UK’s IDTA).
Lastly, we may share your personal data with third parties in connection with a sale of BrilliantIN Recruitment Ltd (or any part thereof). Where that divested entity becomes a controller of your information, they will supply or otherwise make available to you their relevant privacy notice.
Storage and disposal your personal data
Where we have your personal data acting in our capacity as a controller, we will delete your personal data by our data retention schedule (available via our Security Portal), or as otherwise required by data protection legislation: including where you choose to exercise your rights as a data subject (see ‘Your Rights’ section for more information).
Where we have your personal data acting in our capacity as a processor, we will delete your personal data by the controller’s instruction, or as otherwise required by data protection legislation. If we are required by law to retain any of your personal data, we will inform the controller of this lawful obligation.
Your Rights
We will process your personal data by the principles – external link and Individuals’ Rights – external link of The General Data Protection Regulation (both the EU version (2016/679/EU) and UK retained version thereof).
Your data protection rights under data protection law, you have rights including:
- Your right of access – You have the right to ask us for copies of your personal information.
- Your right to rectification – You have the right to ask us to rectify personal information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.
- Your right to erasure – You have the right to ask us to erase your personal information in certain circumstances.
- Your right to restriction of processing – You have the right to ask us to restrict the processing of your personal information in certain circumstances.
- Your right to object to processing – You have the right to object to the processing of your personal information in certain circumstances.
- Your right to data portability – You have the right to ask that we transfer the personal information you gave us to another organisation, or you, in certain circumstances.
- Rights about automated decision-making.
To exercise any of these rights, please contact [email protected]
Where we rely on consent as a lawful basis for processing, you may withdraw your consent at any time by emailing us at [email protected]
Important note: If you feel we have not processed your data in accordance with the Principles and Rights of the individual under GDPR (EU or UK), please contact [email protected] for our complaints procedure, or you may raise a complaint with the Information Commissioners Office – external link (or other relevant supervisory authority) but we would like the opportunity to resolve any issues first.