Privacy and Cookies Policy for www.gradtouch.com
1. About us
Welcome to CareerPass Network’s privacy policy. In this Policy, CareerPass Network is referred to as “we”, “us” or “our”.
• GradTouch Limited
• Graduate-jobs.com Limited
• Gradcore Limited
• Smart Resourcing Solutions Limited
(our “Group”); and
• gradtouch.com
• graduate-jobs.com
• graduate-women.com
• second-jobber.com
• future-talent.com
• gradcore.co.uk
• assess.digital
• smart-resourcing-solutions.com
• kaampus.com
(our “Websites”).
We are made up of different legal entities. This Policy is issued on behalf of our Group, so when we mention “we”, “us” or “our” in this Policy, we are referring to the relevant company in our Group responsible for processing your data.
2. Introduction
We respect your privacy and are committed to protecting your personal data. This Policy tells you how we look after your personal data when you visit the Websites (regardless of where you visit them from), or otherwise provide us with your personal data when you communicate with us or our platforms, and tells you about your privacy rights and how the law protects you. This Policy applies where we are a controller of your personal data, meaning we decide why and how to use the personal data that you provide to us.
3. What this Policy is for
This Policy aims to give you information on how we collect and process your personal data through your use of the Websites or when you otherwise interact with us, including any data you may provide through a Website when you create an account, sign up to our newsletter, register for email alerts, use the services available through the Websites, or otherwise communicate with us. It is really important that the personal data we hold about you is accurate and current. Please tell us if your personal data changes during your relationship with us. The Websites are not intended for people under the age of 18, and we do not knowingly collect data relating to children. It is important that you read this Policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you, so that you are fully aware of how and why we are using your data. This Policy supplements other notices and privacy policies and is not intended to override them. We keep this Policy under regular review. This version was last updated on 5th April 2022.
4. Getting in touch with us
If you have any questions about this Policy or our privacy practices, please contact our data privacy manager in the following ways:
Full name of legal entity: GradTouch Limited
Email address: hello@careerpass.network
Postal address: Gradtouch Limited, Work.Life, Brown Street, Manchester, M2 1DH
You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO, so please contact us in the first instance.
5. Third-party links
The Websites may include links to third-party websites, plug-ins and applications. This includes where you want to apply for a job with certain employers that have a role listed on a Website. Clicking on those links or enabling those connections may allow third parties to collect or share data about you, and the third-party websites may use cookies or similar technologies in accordance with their own privacy and cookies policies. Those third parties will control the personal data you provide to them. We do not control these third-party websites and are not responsible for their privacy policies. When you leave the Websites, we encourage you to read the privacy policy of every website you subsequently visit.
6. Where we are not responsible for your information
If you do leave a Website and follow a link to a third-party website, that third party will be responsible for your personal data if you provide it to them; we may help them process your personal data, but only if that third party shares your personal data with us. Again, you should read the privacy policy of that third party to understand how they use your personal data (and why they share it with us). If you attend an event or assessment that we run through gradcore.co.uk, smart-resourcing-solutions.com and assess.digital, the university, college or other educational institution that has asked us to run the event for them is responsible for your personal data. You may be able to sign-up for an account to use our services at the event itself (in which case this Policy will apply to the information you provide directly to us, and we are responsible for the personal data you provide to us). However, in all other instances, you should read the privacy policy of the relevant educational institution to understand how they use your personal data (and why they share it with us).
7. The data we collect about you
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
| When using the services available through the Websites | |
|---|---|
| Identity Data | This includes first name, maiden name, last name, username or similar identifier, marital status, title, nationality, date of birth and gender. If you registered for an account with us at a careers fair or similar event, we will collect and store that information. |
| Contact Data | This includes email address and telephone numbers. |
| Technical Data | This includes 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 the Websites. |
| Profile Data | This includes your username and password, any information you add to you profile (such as education history, career history, location, career interests, historic and current salary, and your CV) your interests, preferences, feedback and survey responses. |
| Usage Data | This includes information about how you use the Websites, and our products and services. |
| Marketing and Communications Data | This includes your preferences in receiving marketing from us and your communication preferences. |
| Special Categories of Personal Data | This includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data. It may also include information about criminal convictions and offences. We collect this information to the extent you include it in your Profile Data, Usage Data or Marketing and Communications Data (such as information you include in your CV). We need to have your explicit consent before collecting and using Special Categories of Personal Data. We will ask you for your consent in our onboarding processes within the Websites, before you provide that information to us. |
| Society Information | When using kaampus.com only:
• The name, email address and password for the president and/or other committee members for a particular university society • The name and description of that university society • Where the relevant president or committee member has agreed to provide us with the information, the names and email addresses of members of that university society • Payment information for that university society |
| When otherwise communicating with the Group, whether through the Websites or otherwise | |
|---|---|
| Identity Data | This includes first name and last name. |
| Contact Data | This includes email address and telephone numbers. |
| Technical Data | This includes 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 the Websites. |
| Usage Data | This includes information about how you use the Websites. |
| Marketing and Communications Data | This includes your preferences in receiving marketing from us and your communication preferences. |
We also collect, use and share anonymised and Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific Website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Policy. Unless you provide it to us in using the services available through the Websites, or we receive it as part of the Society Information, we do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences. If we do collect any such information, we will obtain your explicit consent first.
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to help you find a job by using the services available through the Websites). In this case, we may have to cancel your access to some or all of those services, or you may not be able to use those services as much as we would like, but we will notify you if this is the case at the time.
8. How is your personal data collected?
We use different methods to collect data from and about you including through:
| Direct interactions | You may give us your Identity Data and Contact Data by filling in forms on the Websites or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
• Create an account on the Websites. • Subscribe to our services. • Add information to your account on the Websites. • Request marketing to be sent to you. • Enter a competition, promotion or survey. • Give us feedback or contact us. |
|---|---|
| Automated technologies or interactions | As you interact with the Websites, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. Please see paragraph 9 below on how we use cookies. |
| Third parties or publicly available sources | We will receive personal data about you from various third parties and public sources as set out below:
• Identity, Contact and Profile Data from third parties who provide sign-in functionality to allow you to use an account you have with them to sign-up to, and sign-in to, our services, such as Google based outside the UK. • Identity, Contact and Profile Data from Dig-in (https://www.digin.co.uk/, based in the UK), our partner that operates in the student media and blogging space, if you have opted-in to that service with Dig-in to receive communications from us. • Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register based inside the UK. |
9. How we use cookies and other identifiers
What is a cookie?
The Websites use cookies and similar identifiers to distinguish you from other users of the Websites. A cookie is a small text file which is placed onto your device (e.g. computer, smartphone or other electronic device) when you use the Website. Cookies help us recognise you and your device and store some information about your preferences or past actions.
For example, we may monitor how many times you visit a particular Website, which pages you go to, traffic data and the originating domain name of your internet service provider. This information helps us to build a profile of our users. Some of this data will be aggregated or statistical, which means that we will not be able to identify you individually.
For further information on our use of cookies, including a detailed list of your information which we and others may collect through cookies, please see our Cookies Statement.
For further information on cookies generally, including how to control and manage them, visit the guidance on cookies published by the UK Information Commissioner’s Office, www.aboutcookies.org or www.allaboutcookies.org.
Consent to use cookies and changing settings
We will ask for your consent to place cookies or other similar technologies on your device, except where they are essential for us to provide you with a service that you have requested, for example in creating an account to use the services provided through the Websites. If you do not want to accept any cookies, you may be able to change your browser settings so that cookies (including those which are essential to the services requested) are not accepted. If you do this, please be aware that you may lose some of the functionality of the Website you are visiting.
For more information on how to disable cookies, please visit the guidance on cookies published by the UK Information Commissioner’s Office, www.aboutcookies.org or www.allaboutcookies.org.
What cookies we use
Please see our Cookies Statement, which gives you more information about the cookies we use and why.
10. How we use your personal data
How do we justify using your personal data
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:
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. This means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before 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 are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
• Where we need to perform the contract we are about to enter into or have entered into with you. This means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
• Where we need to comply with a legal obligation.This means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.
• Where we get your consent to using your personal data in a particular way. This means that we will ask you to confirm your agreement to us using your personal data in a particular way before we actually use it.
We will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
Purposes for which we will use your personal data
The table below describes of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate. Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
| Purpose/Activity | Type of data | Lawful basis for processing including basis of legitimate interest |
|---|---|---|
| To register you for an account on the Websites | (a) Identity
(b) Contact |
Performance of a contract with you |
|
To provide you with the services available through an account on the Websites, including:
• if you are a candidate, allowing you to have visibility of roles listed on the Websites, and to apply for those roles, and to add information to your profile and account on the Websites • if you are a potential employer or recruiter, allowing you to interact with candidates and, where approved by a candidate, viewing that candidate’s profile within the Websites • allowing you to access the functionality available through the Website account • if you are a candidate, allowing you to follow certain employers • if you are a candidate, storing your history of using the Websites and your application/role history for future access • allowing you to save favourite content available through the Websites • if you are a candidate, allowing you to provide your availability to meet with a potential employer (whether remotely or in-person) |
(a) Identity
(b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Special Categories of Personal Data |
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to match users of our platform with potential employers in respect of particular roles) (c) Consent for Special Categories of Personal Data only |
| To make your Website profile visible to potential employers registered for that access |
(a) Identity
(b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Special Categories of Personal Data |
Consent for (a) to (e) Explicit consent for (f) |
|
To manage our relationship with you which will include:
(a) Notifying you about changes to our terms, this Policy or our Cookies Statement (b) Asking you to leave a review or take a survey |
(a) Identity
(b) Contact (c) Profile (d) Marketing and Communications |
(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to study how users use the Websites and our services) |
| To enable you to complete a survey |
(a) Identity
(b) Contact (c) Profile (d) Usage (e) Marketing and Communications |
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to study how users use the Websites and our services, to develop them and grow our business) |
| To administer and protect our business and the Websites (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) |
(a) Identity
(b) Contact (c) Technical (d) Usage |
(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
(b) Necessary to comply with a legal obligation |
| To deliver relevant Website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you |
(a) Identity
(b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical |
Necessary for our legitimate interests (to study how users use the Websites and our services, to develop them, to grow our business and to inform our marketing strategy) |
| To use data analytics to improve the Websites and our services, marketing, user relationships and experiences |
(a) Technical
(b) Usage |
Necessary for our legitimate interests (to define types of users for the Websites and our services, to keep the Websites updated and relevant, to develop our business and to inform our marketing strategy) |
| To make suggestions and recommendations to you about roles and other products/services that may be of interest to you, including using keywords search of your CV to provide relevant roles to you |
(a) Identity
(b) Contact (c) Technical (d) Usage (e) Profile (f) Marketing and Communications (g) Special Categories of Personal Data |
(a) Necessary for our legitimate interests (to develop the Websites and our services, and grow our business)
(b) Consent for Special Categories of Personal Data only. |
| To allow us to share details about your university society with potential employers and sponsors, and to provide sponsored offers to individual members of your society |
(a) Identity
(b) Contact (c) Profile (d) Marketing and Communications (e) Society (f) Special Categories of Personal Data |
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to match users of our platform with potential employers in respect of particular roles) (c) Consent for Special Categories of Personal Data only. |
Marketing and promotions
In your account on the Websites, we provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
• We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which roles may be relevant for you – we call this marketing.
• We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
• You can ask us (or third parties if relevant) to stop sending you marketing messages at any time by access your account on the Websites, by following the opt-out links on any marketing message sent to you, by contacting us at any time. Where you opt out of receiving these marketing messages, this will not apply to us communicating with you as a result of personal data provided to us by, for example, you using your account on the Websites, or otherwise communicating with us (whether through the Websites or otherwise).
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
11. Disclosures of your personal data
We may share your personal data with the parties, and for the purposes, set out below:
| Internal Third Parties | Other companies in our Group acting as controllers and who are based in the UK. Those companies assist in the services we provide. |
|---|---|
| External Third Parties |
• Potential employers, registered with us, to help you find employment.
• Service providers acting as processors based in the EU who provide IT and system administration services, our CRM system, job boards that we use, and marketing services. • Service providers acting as processors based in the US who provide email marketing support platforms, such as MailChimp (operated by The Rocket Science Group LLC, and Intuit Inc., being its parent company, and its various group companies). • Professional advisers acting as processors or controllers including lawyers, bankers, auditors and insurers based in the UK who provide consultancy, banking, legal, insurance and accounting services. • HM Revenue & Customs, regulators and other authorities acting as processors or controllers based in the United Kingdom who require reporting of processing activities in certain circumstances. |
| Third parties relating to a change in our business structure | We will share your personal data with third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. |
| Third parties we have to share personal data with by law | We will share your personal data with the Information Commissioner's Office or another regulator or relevant body (such as the Police) when we are legally required to do so. |
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
12. Recruitment/Instruction
We are the data controller for any information you give to us during an enquiry about a job opening within our Group, or through an application process that you commence through our Websites or otherwise for a role within our Group.
We will only collect the information that we need for such purposes, such as your name, address, email address, phone number, employment history, salary history and referees (together, "Suitability Data"). We will retain Suitability Data for as long as is necessary, and in any event for no longer than six months after you provide the information to us if we do not employ you and, if we employ you, for the duration of your employment/instruction with us and for a period after your employment/instruction ends, in accordance with our internal policies of which you will be informed if you join us or are instructed by us.
We will use Suitability Data only for the purpose of dealing with your enquiry or application, or to fulfil our legal and/or regulatory obligations. This might include contacting you to keep your application moving and/or assessing your suitability for the particular role we have available.
We will not share Suitability Data with any third parties for marketing purposes, and we will not transfer it outside of the European Economic Area.
You do not have to provide personal data to us when we ask for it, but it may impact your application, or our assessment of your suitability, if you do not give us all of the information we need.
If we make you an offer of employment or to procure your services, we will ask you for further information, such as proof of your qualifications and identity, and information about your health. If you accept our offer of employment or to procure your services we will ask you for details of your bank account (so we can pay you). At that point, the way we process your personal data will be subject to our internal employee privacy notice, which we will provide to you at that time.
13. International transfers
In general, we do not transfer your personal data outside the UK or the European Economic Area. We do share your personal data within the The Rocket Science Group LLC, operators of MailChimp (and, in doing so, with Intuit Inc., being its parent company, and its various group companies). This involves transferring your data outside the UK. In making that transfer, we use specific contracts approved for use in the UK which give personal data the same protection it has in the UK. Please contact us if you want further information.
14. Data security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
15. How long we will use your personal data for
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by contacting us.
In some circumstances you can ask us to delete your data: see paragraph 16 below, on Your Legal Rights, for further information.
In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you
16. Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. You have the right to:
1. Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
2. Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
3. Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
4. 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 information which override your rights and freedoms.
5. 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 want us to establish the data's accuracy.
• Where our use of the 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.
• You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
6. Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
7. Withdraw consent at any time where we are relying on 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 products or services to you. We will advise you if this is the case at the time you withdraw your consent.
If you wish to exercise any of the rights set out above, please contact us.
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of your other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
What we may need from you
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). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it could 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.