Smart People Pro understands that your privacy is important to you and that you care about how your personal data is used by us. We respect and value the privacy of all of our clients and customers and will only collect and use personal data in ways that are described here, and in a way that is consistent with our obligations and your rights under the law.
1. Information About Us
Smart People Pro LLP A Limited Company registered in England under company number 0307189
Registered address: 9a Tinto, Place Edinburgh UK, EH6 5GD
Trading address: 9a Tinto, Place Edinburgh UK, EH6 5GD
Data Protection Officer: Managing Director
Email address: info@smartpeoplepro.com
Telephone number: +441316187781
Postal address: 9a Tinto, Place Edinburgh UK, EH6 5GD
2. What Does This Notice Cover?
This Privacy Information explains how we use your personal data: how it is collected, how it is held, and how it is processed. It also explains your rights under the law relating to your personal data.
3. What Is Personal Data?
Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) and the Data Protection Act 2018 (collectively, “the Data Protection Legislation”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.
Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.
The personal data that we use is set out in Part 5, below.
4. What Are My Rights?
Under the Data Protection Legislation, you have the following rights, which we will always work to uphold:
a) The right to be informed about our collection and use of your personal data. This Privacy Notice should tell you everything you need
to know, but you can always contact us to find out more or to ask any questions using the details in Part 11.
b) The right to access the personal data we hold about you. Part 10 will tell you how to do this.
c) The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in Part 11 to find out more.
d) The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that us hold. Please contact us using the details in Part 11 to find out more.
e) The right to restrict (i.e. prevent) the processing of your personal data.
f) The right to object to us using your personal data for a particular purpose or purposes.
g) The right to withdraw consent. This means that, if we are relying on your consent as the legal basis for using your personal data, you are free to withdraw that consent at any time.
h) The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.
i) Rights relating to automated decision-making and profiling. We do not use your personal data in this way.
For more information about my use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Part 11.
It is important that your personal data is kept accurate and up-to-date. If any of the personal data us hold about you changes, please keep us informed as long as we have that data.
Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.
If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information
Commissioner’s Office. We would welcome the opportunity to resolve your concerns ourselves, however, so please contact us first, using the details in Part 11.
5. What Personal Data Do You Collect and How?
Depending upon your use of our Site, we may collect and hold some or all of the personal and non-personal data set out in the table below, using the methods also set out in the table. We do not collect any ‘special category’ or ‘sensitive’ personal data and data relating to criminal convictions and/or offences.
Data Collected How We OR Collect the Data
Identity Information including Name, Title, Date of Birth and Gender. Candidate registration form or CV.
Contact information including Address, Email Address and Phone number(s). Candidate registration form or CV..
Business information including Company Name, Skills/functions and Job Title. Candidate CV or social media profile such as LinkedIn.
Payment information including bank account details. Candidate registration form.
Identity information including copies of Passport or National ID Card. Candidate registration process.
6. How Do You Use My Personal Data?
Under the Data Protection Legislation, we must always have a lawful basis for using personal data. The following table describes how we may use your personal data, and our lawful bases for doing so:
What We Do What Data We Use Our Lawful Basis
Administering our business. Identity Information, Contact Information and Business Information. Providing you with the necessary contracts and documentation required for the work you carry out.
Supplying our services to you. Contact Information. Contacting you with relevant job opportunities.
Managing payments for your services. Payment Information. Remitting the required funds to you for the work you carry out.
Communicating with you. Contact Information. Providing you with all of the necessary information required such that you are able to apply for jobs, attend interviews and commence assignments.
We will only use your personal data for the purpose(s) for which it was originally collected unless we reasonably believe that another
purpose is compatible with that or those original purpose(s) and need to use your personal data for that purpose. If we do use your personal data in this way and you wish us to explain how the new purpose is compatible with the original, please contact us using the details in Part 11.
If we need to use your personal data for a purpose that is unrelated to, or incompatible with, the purpose(s) for which it was originally
collected, we will inform you and explain the legal basis which allows us to do so.
In some circumstances, where permitted or required by law, we may process your personal data without your knowledge or consent. This will only be done within the bounds of the Data Protection Legislation and your legal rights.
How Long Will You Keep My Personal Data?
We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Your
personal data will therefore be kept for the following periods (or, where there is no fixed period, the following factors will be used to
determine how long it is kept):
Type of Data How Long We Keep It
Identity Information including Name, Date of Birth and Gender. For a period of 3 years and thereafter your permission will be sought to
retain it further.
Contact information including Address, Email Address and Phone number(s). For a period of 3 years and thereafter your permission will
be sought to retain it further.
Business information including Company Name, Skills/functions and Job Title. For a period of 3 years and thereafter your permission will be sought to retain it further.
Payment information including bank account details. For the duration of your contract with us and thereafter your permission will be sought to retain it further.
Identity information including copies of Passport or National ID Card. For a period of 3 years and thereafter your permission will be sought to retain it further.
How and Where Do You Store or Transfer My Personal Data?
We may store or transfer some or all of your personal data in countries that are not part of the European Economic Area (the “EEA”
consists of all EU member states, plus Norway, Iceland, and Liechtenstein). These are known as “third countries” and may not have
data protection laws that are as strong as those in the UK and/or the EEA. This means that we will take additional steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the Data Protection Legislation as follows:
We may share your data within the group of companies of which we are a part. Where this involves the transfer of personal data outside the EEA, our group ensures that personal data is protected by requiring all companies within the group to follow the same rules with respect to personal data usage. These are known as “binding corporate rules”. More information on binding corporate rules is available from the European Commission.
Do You Share My Personal Data?
We may share your personal data with other companies in our group for the purposes of administering our business. This includes our holding company and its subsidiaries.
We may sometimes contract with the following third parties to supply services to you.
Recipient Activity Carried Out Sector Location
Umbrella Payroll Companies. Processing of Identity, Contact and Payment Information in order to remit funds to you. Payroll. Within the EEA.
If any of your personal data is shared with a third party, as described above, we will take steps to ensure that your personal data
is handled safely, securely, and in accordance with your rights, our obligations, and the third party’s obligations under the law, as described above in Part 8.
If any personal data is transferred outside of the EEA, we will take suitable steps in order to ensure that your personal data is treated
just as safely and securely as it would be within the UK and under the Data Protection Legislation, as explained above in Part 8.
If we sell, transfer, or merge parts of our business or assets, your personal data may be transferred to a third party. Any new owner of
our business may continue to use your personal data in the same way(s) that we have used it, as specified in this Privacy Policy.
In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved
in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.
How Can I Access My Personal Data?
If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.
All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 11.
There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you
make repetitive requests) a fee may be charged to cover our administrative costs in responding.
We will try to respond to your subject access request within 14 working days and, in any case, not more than one month of receiving
it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however,
particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.
How Do I Contact You?
To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the following details:
Email address: info@smartpeoplepro.com
Telephone number: +441316187781
Postal address: 9a Tinto, Place Edinburgh UK, EH6 5GD.
Changes to this Privacy Notice
We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if we change our
business in a way that affects personal data protection.
This Privacy Notice was last updated on 21 March 2021