- INTRODUCTION
- THE DATA WE COLLECT ABOUT YOU
- HOW IS YOUR PERSONAL DATA COLLECTED?
- HOW WE USE YOUR PERSONAL DATA
- DISCLOSURES OF YOUR PERSONAL DATA
- INTERNATIONAL TRANSFERS
- DATA SECURITY
- DATA RETENTION
- YOUR LEGAL RIGHTS
- GLOSSARY
- SCHEDULE 1 – THIRD PARTIES
- SCHEDULE 2 – YOUR LEGAL RIGHTS
Welcome to Enablis Consulting Ltd. privacy notice.
Enablis respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from), if you are a candidate or a client or a supplier. This notice also tells you about your privacy rights and how the law protects you.
Purposes of this privacy notice
This privacy notice aims to give you information on how Enablis collects and processes your personal data through your use of this website and by using our recruitment services, including any data you may provide through this website when you fill a form and any information and details you may provide by e-mail or any data you may provide to us directly.
This website and our consultancy services are not intended for children and we do not knowingly collect data relating to children.
It is important that you read this privacy notice together with any other privacy notice or fair processing notice 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 privacy notice supplements the other notices and is not intended to override them.
Controller
Enablis Consulting Ltd is the controller and responsible for your personal data (collectively referred to as “Enablis”, “Enablis Ltd”, “Enablis Consulting Ltd”, “we”, “us” or “our” in this privacy notice).
Enablis is the controller and responsible for this website, the processing of client and candidate data and the provision of consultancy services.
We have appointed a data privacy team which is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the data privacy team using the details set out below.
Contact details
Our full details are:
Enablis
Email address: dataprotection@enablis.co
Postal address: Enablis, Second Floor, 1 York place, Leeds, LS1 2DR, UK
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority 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.
Changes to the privacy notice and your duty to inform us of changes
This version was last updated on 15th November 2024.
The data protection law in the UK changed on 25 May 2018. Although this privacy notice sets out most of your rights under the new laws, we might update the notice from time to time to take new guidance, rules, regulations and best practice into account.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
Third-party links
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
2. 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).
Whether you are candidate, contractor, client, supplier, or website user, we may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:
Identity Data includes first name, last name, username or similar identifier, title, job role or position held.
Contact Data includes postal address, email address and telephone numbers, which may include professional contact details.
Financial Data of our clients or suppliers including bank details you may supply to us.
Transaction Data includes details about payments from you or your company following use of our services.
Technical Data includes internet protocol (IP) address, time zone setting and location, operating system and platform and other technology on the devices you use to access this website.
Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
If you are a candidate or contractor, further details about the specific data we collect about you are available here.
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.
3. 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, Contact, Job title, Position, Employer or Role by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
Fill the contact form on our website;
Request marketing to be sent to you;
Contact us directly;
Provide us your details at a job fair or any event that we run;
Give us some feedback.
Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:
Social media and Job boards based inside or outside the EU, and the Internet (for example, public LinkedIn accounts or from your professional profile on your company’s website)
Identity and Contact Data from publicly availably sources such as Companies House and the Electoral Register based inside the EU.
If you are a candidate or contractor, further details about how we use job boards and social media are available here.
4. HOW WE USE 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 we need to perform the contract we are about to enter into or have entered into with you.
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.
Where we need to comply with a legal or regulatory obligation.
See Schedule 2 below to find out more about the types of lawful basis that we will rely on to process your personal data.
Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message, or unless you are a candidate or contractor. You have the right to withdraw consent to marketing at any time by sending us an email to: dataprotection@enablis.co
If you are a candidate or contractor, further details about how we rely on consent or legitimate interests are available here.
Purposes for which we will use your personal data
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 on dataprotection@enablis.co if you need details about the specific legal ground we are relying on to process your personal data.
Emails of interest from us
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 services may be relevant for you, such as by sending market reports to potential or existing clients. Sometimes we will send candidates and contractors emails about events that we hold, if we have collected your information by you either attending or signing up to these events. In any case, we only ever send you emails in accordance with the laws on Direct Marketing and this notice, and you are always able to unsubscribe at any moment using the link or contact provided in each of our emails.
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 at dataprotection@enablis.co
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.
DISCLOSURES OF YOUR PERSONAL DATA
We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.
Consultants or Clients
Specific third parties such as lawyers, tax administration, auditors and accountants
Suppliers such as data centres, cloud storage, IT service providers, e-mail providers and data base managements systems (in this case, we will ensure that data is encrypted or anonymised to protect your privacy rights).
INTERNATIONAL TRANSFERS
From time to time, we may transfer your personal data outside the European Economic Area (EEA), such as when using CRM systems, cloud storage, email services, or data centers, or when providing your contact details to our candidates who may be based outside the EEA.
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to your personal data by ensuring that at least one of the following safeguards is implemented:
- Standard Contractual Clauses (SCCs): We use specific contracts approved by the European Commission, known as Standard Contractual Clauses, which ensure your personal data receives the same level of protection as within Europe.
- Binding Corporate Rules (BCRs): Where applicable, we may rely on Binding Corporate Rules approved by a relevant data protection authority, which provides an adequate safeguard for personal data within multinational corporate groups.
- Adequacy Decisions: Where the European Commission has deemed certain countries as providing an adequate level of data protection, we may transfer data to these locations under the adequacy decision.
Please note that with recent legal changes, the EU-U.S. Privacy Shield framework is no longer valid for data transfers to the United States. If we need to transfer personal data to the U.S., we will rely on SCCs or other valid transfer mechanisms that ensure your data is protected in compliance with the GDPR.
If you would like further information on the specific mechanism we use for transferring your personal data outside the EEA, please contact us at dataprotection@enablis.co.
Details of our third-party providers are set out in Schedule 1
DATA SECURITY
We take the protection of your personal data seriously and have implemented strict measures to safeguard it from unauthorized access, loss, misuse, or alteration. Here is how we secure your data and how we will respond to any suspected breaches.
Data Security Measures
- Technical Security Measures
We use a range of technical safeguards to protect your data, including:- Encryption of data during transmission and storage to prevent unauthorized access.
- Firewalls and Intrusion Detection Systems to monitor for and prevent unauthorized access to our systems.
- Access Controls to restrict data access to only those employees, agents, contractors, and third-party service providers who need it for their roles, each bound by strict confidentiality agreements.
- Organizational Security Measures
We adopt best-practice organizational security measures, including:- Regular Security Audits and Assessments to evaluate the effectiveness of our technical and physical data security measures.
- Security Awareness Training for our employees to ensure they are aware of their responsibilities in safeguarding your data.
- Access Management Policies that ensure only authorized personnel have access to sensitive data, with access granted on a need-to-know basis.
- Third-Party Security
Where we use third-party service providers (for data storage, processing, or management), we conduct due diligence and ensure they adhere to data protection and security standards equivalent to our own. We have data protection agreements with these third parties to confirm their commitment to data security.
Data Breach Response
Despite our best efforts, security breaches can still occur. Our Data Breach Response Plan ensures that we can respond swiftly and effectively in such an event to mitigate impact and fulfill our legal obligations.
- Immediate Breach Containment and Assessment
If a data breach is detected or suspected, we immediately:- Contain the breach to prevent further unauthorized access or data loss.
- Assess the nature and extent of the breach, including the types of data involved, the potential risk to affected individuals, and the root cause of the breach.
- Notification to Affected Individuals
If a breach poses a high risk to your rights and freedoms, we will notify you without undue delay. This notification will include:- A description of the breach and the types of data involved.
- Information on actions we are taking to mitigate risks and protect your data.
- Advice on what steps you can take to protect yourself.
- Contact details for our Data Privacy Team, should you have questions or require further assistance.
- Regulatory Notification
We will notify the Information Commissioner’s Office (ICO) or other relevant data protection authority of a breach within 72 hours, as required by law, particularly if the breach is likely to result in a risk to individuals’ rights and freedoms. - Post-Breach Review and Improvement
After addressing the breach, we conduct a post-breach review to:- Investigate the cause of the breach and prevent similar incidents in the future.
- Review and update our security policies, practices, and employee training to strengthen our data security measures.
Contact Us
If you suspect any misuse, loss, or unauthorized access to your personal data, please contact us immediately at dataprotection@enablis.co.
We are committed to keeping your data secure and responding promptly to any data security concerns.
DATA RETENTION
How long will you use my personal data for? We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. 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 requirements. However, by law we have to keep basic information about our clients (including Contact, Identity, Financial and Transaction Data) in accordance with legal and tax obligations. In some circumstances you can ask us to delete your data. In some circumstances we may 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.
YOUR LEGAL RIGHTS
Under data protection laws, you have specific rights regarding your personal data. These rights are designed to empower you with control over your data. If you wish to exercise any of these rights, please contact us at dataprotection@enablis.co. We aim to respond to all legitimate requests within one month; however, if your request is complex or if you have made multiple requests, we may extend this period and will notify you accordingly.
Your Rights Include:
- Right to Access
You may request a copy of the personal data we hold about you. This right, known as a “Data Subject Access Request” (DSAR), enables you to verify the lawfulness of our data processing. - Right to Rectification
If you notice any inaccurate or incomplete data that we hold about you, you have the right to request correction or completion. - Right to Erasure
Also known as the “Right to be Forgotten,” this enables you to request the deletion of your personal data where:- The data is no longer necessary for the purposes for which it was collected.
- You withdraw consent on which the processing is based.
- You successfully object to the processing, or we have processed your data unlawfully.
- Local laws require us to delete your data.
Please note, in some cases, we may not be able to comply with your request due to specific legal reasons, which will be communicated at the time of your request.
- Right to Object to Processing
You may object to our processing of your data where it impacts your fundamental rights and freedoms, particularly in cases of processing based on our legitimate interests or for direct marketing purposes. - Right to Restrict Processing
You have the right to request that we suspend processing of your data in the following scenarios:- If you want us to verify the accuracy of the data.
- Where our data use is unlawful, but you do not wish for it to be erased.
- Where you need us to retain the data even if we no longer require it, in order to establish, exercise, or defend legal claims.
- You have objected to our use of your data, and we are verifying whether we have overriding legitimate grounds.
- Right to Data Portability
You may request a copy of your data in a structured, commonly used, machine-readable format (such as CSV) and have the right to request that this data be transferred directly to another party. This right applies to personal data that you initially provided to us, where we process the data based on consent or contract, and where the processing is automated. - Right to Withdraw Consent
Where our processing of your personal data relies on your consent, you may withdraw that consent at any time. This withdrawal will not affect the lawfulness of any processing carried out before you withdraw your consent. - Right to Lodge a Complaint
If you are dissatisfied with how we have handled your personal data or a request relating to your rights, you have the right to make a complaint to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues, at www.ico.org.uk. We would appreciate the chance to resolve your concerns before you approach the ICO, so please feel free to contact us initially.
No Fee Usually Required
Typically, you will not need to pay a fee to access your personal data or to exercise any of these rights. However, if your request is clearly unfounded, repetitive, or excessive, we may charge a reasonable fee or refuse to comply in such cases.
What We May Need from You
To confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights), we may request specific information from you. This measure helps us protect your data and respond appropriately.
GLOSSARY
Lawful basis
Legitimate Interest 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 on: dataprotection@enablis.co.
Performance of Contract 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. Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to
SCHEDULE 1 – THIRD PARTIES
External third parties:
Service providers acting as processors based in the EEA and outside of the EEA such as Bullhorn (our CRM provider), Engage Technology Partners (our Contractor Compliance and Timesheet portal provider) and Broadbean (aggregates job advert responses) who provide IT and system administration services.
Social media and other web-based platforms, such as LinkedIn or Job boards acting as controllers based inside and outside of the EU who provide personal data.
Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the United Kingdom who provide consultancy, banking, legal, insurance and accounting services.
HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.
SCHEDULE 2 – YOUR LEGAL RIGHTS
You have the right to:
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.
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.
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.
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.
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: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) 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 (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
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.
