Privacy Policy

Who we are

Our website address is: http://rubea.co.uk.

This Privacy Notice (“Notice”) describes how Rubea Ltd (we, us, our, Rubea, Rubea Consulting) may use, process, store and disclose personal data that we may collect about individuals, including if you register with us for recruitment services , through this website and from other sources, such as when you apply for a job through job sites. The types of personal data we collect are described in the section below ‘Your Data and how we collect it’.

Your Data and how we collect it

We collect different types of personal data depending on our relationship with you and you may be in one or more of these categories:

candidates registered with us searching for work either temporary or permanent or fixed term contract employment;
business contacts at clients, hiring organisations and suppliers of goods and services.

Using this Website

When you use this website, we may ask for certain personal data including your name and contact information (email and phone number). Depending on the nature of your activities on our website, we may also ask for your job search criteria and preferences, employment experience, salary, and other background information.

Registering as a Candidate for recruitment services

We will collect personal data directly from you during in person interviews, video and online meetings and from other sources including your CV when you apply for a job through job sites, directly through our website, from Social Media sites such as LinkedIn, Facebook and Twitter and when you provide us with your details during a job fair, promotional, networking or training event. When you ask us to provide you with work finding services we will ask you to register as a Candidate. During the Registration process we will collect your personal data directly from you, your CV. We may disclose your personal data to our clients and partner organisations in the UK for relevant job vacancies. Our clients may request additional personal data about you in relation to their job vacancies and requirements. Your personal data will be securely stored in our candidate database. As part of our work finding services our consultants may send you job alert emails closely matching your job search criteria and preferences and other jobs and roles you may find interesting when your qualifications, skills and experience match our clients’ vacancies. You may stop receiving these job alerts at any time by clicking the ‘unsubscribe’ link contained in the email.

The categories of personal data we may collect include:

your identity (your full name, previous names, evidence of change of name); gender, date of birth, marital status and social media URL);
evidence of your right to work in the UK which may include a photograph, nationality, place of birth, birth certificate, driving licence, etc;
contact details including your name, personal email, home address and phone numbers so that we can contact you by email and text message;
bank account and national insurance number (so we can make payments to you and account for tax if you are working as an agency worker supplied through Rubea Consulting or one of our Partner organisations);
your job search criteria, preferences and expectations;
your qualifications, skills, experience and training;
current and desired remuneration/payrate and other benefits;
educational history;
employment history;
details of past and current employment and/or educational referees;
references;
online skill tests;
details of health/disabilities (where you choose to provide this data and it is relevant);
unspent criminal / motoring convictions, court proceedings and pending court proceedings relating to an offence committed or alleged to have been committed by you;
other information contained in your CV or that you choose to provide to us;
technical data including internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website. We may also receive technical data about you if you visit other websites employing our cookies.
profile data including your username and password
usage data including information about how you use our website and services;
marketing and communications data including your marketing and communication preferences.

The basis we process your personal data for these purposes is your consent and to fulfil a contract.

Clients, Hiring Organisations and Suppliers

If you are a client, hiring organisation or supplier of goods and services, we will collect and process information about individuals in your organisation. We may enter the individual’s name and business email address in to our database as a point of contact for that organisation, together with the individual’s other business contact data. We process personal data about business contacts, for the purposes of providing our services, for invoicing or as a recipient of the supplier’s goods and services. If the individual business contact is also a registered candidate we may be processing additional personal data for work finding and other purposes as described in this Notice. This processing is necessary for the purposes of our legitimate interests in providing our services, managing our business relationships and/or to fulfil obligations. We may send business to business email marketing to corporate contacts.

How we use your Personal Data

We use, process, store and disclose your personal data and other data we collect including to administer your job application, during our registration process, to provide you with work finding services including temporary assignments, permanent and fixed term contract placements. We provide you with employment opportunities and relevant information through this website and by email. After you complete our registration process we process your personal data in accordance with our candidate contract, to evaluate your suitability for roles, conducting background and verification checks and we will disclose your personal data to our clients in relation to their job vacancies. We also process your personal data for other legitimate interests in connection with our business. If you provide us with information about third parties, we will assume that the third party has given you permission to do so and to Rubea Consulting collecting, processing and transferring their personal data to the same extent as yours.

Change of Purpose

We may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by applicable law.

Disclosing your Personal Data to Third Parties

To the extent necessary or appropriate and without notifying you, Rubea Consulting may disclose your personal data to external third parties (who are not members of Rubea Consulting) for legitimate and commercial purposes for the management and conduct of the business, in the following circumstances:

to companies and individuals we employ to perform business functions and services on our behalf. Examples include but are not limited to: payroll services; screening and verification services; managing job posting applications and CVs submitted through job sites; analysing data and producing statistics; and legal, accounting, audit and other professional services;
to government agencies;
to comply with applicable laws, the service of legal process, or if we reasonably believe that such action is necessary to: (a) comply with the law requiring such disclosure; (b) protect the rights or property of Rubea Consulting or its group companies; (c) prevent a crime, protect national security or for fraud detection or prevention; or (d) protect the personal safety of individuals using our website and/or members of the public;
to third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets including candidate sharing with other agencies with suitable vacancies. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, we will let you know;

Third parties who are also controllers are responsible for processing your personal data for their purposes, for example, HM Revenue & Customs is a controller for tax purposes. We may not be able to impose obligations or restrictions on these controllers and we recommend that you review the applicable third party’s privacy notice in connection with how they process your personal data.

Keeping your Personal Data Secure

We have put in place appropriate security measures to prevent personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to personal data to those employees, contractors and other third parties who have a business need to do so.

We have put in place procedures to deal with personal data breaches and we will notify you and the applicable supervisory authority of a breach when we are legally required to do so.

How long we Retain your Personal Data

Rubea Consulting retains personal data for as long as necessary to fulfil the purposes that we collected it for. This means we will keep your personal data throughout the period of your relationship with us and whilst we are providing you with recruitment services, administering a job application and keeping in contact with clients and hiring organisations and after our relationship ends.

If you no longer wish to receive our services you have the right at any time to request us to delete your personal data from our database. When we have deleted your data, we may retain your name and email address on our suppression list for 7 years (or until you apply for another job or ask us to provide work finding services and then will we check with you before removing your data from our suppression list). Subject to the services we have provided, we may continue to retain some of your personal data for legal, compliance, accounting and tax purposes and other legitimate business purposes. We may keep basic information about our candidates, client contacts and customers including contracts, name, evidence of identity and right to work in the UK, financial and transaction data (e.g. timesheets, payslips, invoices, receipts) for up to 7 years from when our relationship ends.

Where there is no retention period stated in law, we determine the appropriate retention period for personal data by considering the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of the data, the purposes for which we process it and whether we can achieve those purposes through other means, and the applicable legal requirements.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you and we cannot identify you). We do this for research or statistical purposes in which case we may use this anonymised data indefinitely without further notice to you.

Your Legal Rights

You have the right at any time to:

Make a Data Subject Access Request to access personal data we hold about you. This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request rectification of the personal data that we hold about you. This enables you to have any incomplete or inaccurate personal data we hold about you corrected, although we may need to verify the accuracy of the new data you provide to us.

Request erasure / deletion of personal data we hold about you. This enables you to ask us to delete personal data in the following circumstances: it is no longer necessary in relation to the purposes we collected or processed it or you have withdrawn your consent on which the processing is based and in each case, there is no other legal ground for the processing; if you object to the processing and there are no overriding legitimate grounds for the processing; if the personal data is unlawfully processed; and where we are required to erase your personal data to comply with local law. We may not always be able to comply with your request for erasure for legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data 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 as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your personal data which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: if you contest the accuracy of the personal data and you want us to verify the data’s accuracy; the processing of the personal data is unlawful but you do not want us to erase it; where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or you have objected to the processing and we need to verify whether we have overriding legitimate grounds to process it.

Data Portability / Request the transfer of your personal data to you or directly to another controller. This right only applies to automated information which you initially provided consent for us to use or where we used the personal data to perform a contract with you. We will (unless there is an exemption) assist you by securely transferring your personal data directly to another controller where technically feasible or by providing you with a copy in a structured commonly used machine readable format. The data we can provide is:

Report Title	Candidate Information
Personal Details	Full name, address, phone number, e-mail (business/personal), nationality, place of birth, birthdate, gender. Online presence URLs. Emergency contact name and phone.
Eligibility Details	National ID, tax information. Work visa / passport details. Full name, business phone number and company name of job references.
Education and Skills	Skills and skill test results. Education certifications and qualifications with dates. Industries worked in.
Work History	Work history (employer, job title/function, employment dates, remuneration).
Job Placement/role	Job placement /employment (company, job title/function, start date, end date, compensation/pay rates, worksite addresses).

Withdraw consent at any time where we are relying on your consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain services to you. We will advise you if this is the case at the time you withdraw your consent.

Additional Information, Response Times and Fees

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights or when you make an informal request). This is a security measure to ensure that personal data is not disclosed to any person other than the individual who has the right to receive it. We may also contact you to ask you for further information in relation to your request to help us locate personal data we hold about you and to speed up our response.

We try to respond to all legitimate requests within one month. It may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

You will not have to pay a fee to exercise any of these rights. However, we may charge a reasonable fee if your request is unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

The Legal Basis for processing your Personal Data

We have set out a short description of the legal bases we rely on for processing personal data. We have also identified what our legitimate interests are, where appropriate.

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

to fulfil a contract we are about to enter into or have entered into with you (UK GDPR Article 6(1)(b));
where it is necessary for the purposes of our legitimate interests (UK GDPR Article 6(1)(f));
when it is necessary for compliance with a legal or regulatory obligation (UK GDPR Article 6(1)(c)); and
when you consent (UK GDPR Article 6(1)(a)) and Data Protection Act 2018.

A legitimate interest is when we have a business or commercial reason to use your information in conducting and managing our business. We will consider and balance any potential impact on you and your legal rights when we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or it is necessary for compliance with a legal or regulatory obligation or we are permitted to by applicable law).

Purpose/Activity	Type of Personal Data	Lawful basis for processing Personal Data
To contact you when you: submit your CV via our website, a job site; to register you as a candidate for recruitment services; when you make an employment application to us direct or via a job site and manage your application for an employed position.	(a) Identity (b) Contact details (c) Evidence of your identity and right to work in the UK (d) CV (e) referees (f) unspent criminal / motoring convictions	Legitimate Interests Legal and regulatory duties (e.g. complying with applicable recruitment industry and immigration regulations) Your consent;
To provide you with work finding services including: sending you details of available job opportunities and job alert emails in accordance with your job search preferences and criteria, providing career advice, asking you to complete online skills tests, providing your CV, test results and/or background screening and verification (including when relevant and to the extent necessary, special category and/or criminal convictions data to clients in relation to their job vacancies / roles), paying your wages (if you are an agency worker) paying the fees if you work through an umbrella or your own Limited Company, and charging clients for placements we make.	(a) Identity (b) Contact details (c) Financial data (d) Transaction data (e) Marketing and Communications	Fulfil a contract (RH Candidate Agreement and Client Contracts); Legitimate interests (e.g. sending you job opportunities that may be of interest to you or considering your job application) Legal and regulatory duties Your consent
Disclosing your personal data to government and law enforcement agencies and our appointed third party vendors providing goods and services	a) Identity (b) Contact details (c) Evidence of your identity and right to work in the UK (d) CV (e) referees (f) unspent criminal / motoring convictions	Fulfil a contract Legitimate interests (including administrative purposes) Legal and regulatory duties
To manage our relationship with you including: (a) Notifying you about changes to our Candidate or Client Agreements or Privacy Notices (b) Asking you to leave a review or feedback or complete a survey (c) administration and IT services connected with representing you for roles, placing you in temporary assignments to work for our clients, processing timesheets, payroll and other payments, tax deductions, issuing payslips, etc	(a) Identity (b) Contact (c) Profile/Survey (d) Marketing and Communications	Fulfil a contract Legal or regulatory duty Your consent
Keeping your personal data secure to prevent it from being lost, used, accessed, disclosed or altered in an authorised way	(a) Identity (b) Contact details (c) Evidence of your identity and right to work in the UK (d) CV (e) references (f) unspent criminal / motoring convictions	Legal and regulatory duties Legitimate interests Fulfil a contract
To investigate issues, disputes and complaints between us, and between us, you and our clients and to respond and seek to resolve them	(a) Identity (b) Contact (c) Profile (d) Usage data (e) Marketing and Communications	Legal and regulatory duties Legitimate interests Fulfil a contract Your consent
To administer and protect our business and our website (including monitoring activities, troubleshooting, data analysis, analytics, testing, system maintenance, technical support, reporting and hosting of data and cookies)	(a) Identity (b) Contact (c) Technical data	Legitimate interests Legal and regulatory duties
For marketing and communications, job alerts and to make suggestions and recommendations to you about other relevant services that may be of interest to you and inviting you to attend events	(a) Identity (b) Contact (c) Technical data (d) Usage data (e) Profile data	Legitimate interests Your consent (send you job opportunities, salary guides, careers and other relevant information) Where we have a business relationship with you, sending you marketing based on the ‘soft opt in’
To deliver relevant website content and measure or understand the effectiveness of our advertising	(a) Identity (b) Contact (c) Profile data (d) Usage data (e) Marketing and Communications (f) Technical data	Legitimate interests (to study how customers use our products/services/website, to develop them, to grow our business and to inform our marketing strategy) Your consent
To use providers of data analysis services including the assistance of artificial intelligence for the purpose of efficient placement of candidates and job recommendations, data analytics to improve our website, non-essential cookies, products/services, marketing, customer relationships and experiences	(a) Technical data (b) Usage data (c) Profile data	Legitimate interests (to help us match your job search requirements with vacancies, define types of customers for our products and services, maintain and monitor website performance, improve our website and services and to develop our business and to inform our marketing strategy) Your consent
Retaining your personal data for as long as necessary for the purposes of providing you with work finding services and/or to manage the internal hiring process for employed roles	(a) Identity (b) Contact details (c) Evidence of your right to work in the UK (d) CV (e) referees (f) unspent criminal / motoring convictions	Fulfil a contract Legal and regulatory duties
To help us respond to queries, and requests from regulators, government and law enforcement agencies such as HMRC, Home Office, UK Visas and Immigration, the Courts, Police and other law enforcement agencies	(a) Identity (b) Contact	Legitimate interests Legal and regulatory duties

Marketing Messages

We will ask you for consent to send you direct marketing communications via email. However, where we are providing a client or hiring organisation with work finding services, you will receive email marketing communications from us even if you have not given us consent as we rely on the ‘soft opt in’ form of consent.

You may receive email marketing communications from us if you provided us with your details when you entered a competition or registered with us at a job fair, promotional or networking event or attended a training course and you have given us consent to send you marketing. If you give us consent we may also use your identity, contact details, technical data, usage data and profile data to form a view and decide which services may of interest or relevant for you.

You can opt out of receiving email marketing from us at any time by:

Visiting our website and checking or unchecking the relevant box to change your email marketing preference;
Clicking ‘unsubscribe’ contained in our marketing email messages;

Customer Feedback and Complaints

You have the right to make a complaint at any time to the UK supervisory authority for data protection issues, the Information Commissioner’s Office (ICO), (https://www.ico.org.uk). We would ask you to provide us with the opportunity to discuss your concerns with you before you contact the ICO:

If you have any questions about how we use your personal data, contact us at: sam.stuart@rubea.co.uk

Comments

When visitors leave comments on the site we collect the data shown in the comments form, and also the visitor’s IP address and browser user agent string to help spam detection.

An anonymized string created from your email address (also called a hash) may be provided to the Gravatar service to see if you are using it. The Gravatar service privacy policy is available here: https://automattic.com/privacy/. After approval of your comment, your profile picture is visible to the public in the context of your comment.

Media

If you upload images to the website, you should avoid uploading images with embedded location data (EXIF GPS) included. Visitors to the website can download and extract any location data from images on the website.

Cookies

If you leave a comment on our site you may opt-in to saving your name, email address and website in cookies. These are for your convenience so that you do not have to fill in your details again when you leave another comment. These cookies will last for one year.

If you visit our login page, we will set a temporary cookie to determine if your browser accepts cookies. This cookie contains no personal data and is discarded when you close your browser.

When you log in, we will also set up several cookies to save your login information and your screen display choices. Login cookies last for two days, and screen options cookies last for a year. If you select “Remember Me”, your login will persist for two weeks. If you log out of your account, the login cookies will be removed.

If you edit or publish an article, an additional cookie will be saved in your browser. This cookie includes no personal data and simply indicates the post ID of the article you just edited. It expires after 1 day.

Embedded content from other websites

Articles on this site may include embedded content (e.g. videos, images, articles, etc.). Embedded content from other websites behaves in the exact same way as if the visitor has visited the other website.

These websites may collect data about you, use cookies, embed additional third-party tracking, and monitor your interaction with that embedded content, including tracking your interaction with the embedded content if you have an account and are logged in to that website.

Who we share your data with

If you request a password reset, your IP address will be included in the reset email.

How long we retain your data

If you leave a comment, the comment and its metadata are retained indefinitely. This is so we can recognize and approve any follow-up comments automatically instead of holding them in a moderation queue.

For users that register on our website (if any), we also store the personal information they provide in their user profile. All users can see, edit, or delete their personal information at any time (except they cannot change their username). Website administrators can also see and edit that information.

What rights you have over your data

If you have an account on this site, or have left comments, you can request to receive an exported file of the personal data we hold about you, including any data you have provided to us. You can also request that we erase any personal data we hold about you. This does not include any data we are obliged to keep for administrative, legal, or security purposes.

Where your data is sent

Visitor comments may be checked through an automated spam detection service.