Agility by Nature Ltd is committed to protecting and respecting your privacy.
This notice, together with our terms of business (which can be found on our website or by emailing A subject access request should be submitted to email@example.com), sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us.
The General Data Protection Regulation (GDPR) (Regulation (EU) 2016/679) is a new regulation which replaces the Data Protection Regulation (Directive 95/46/EC) The Regulation aims to harmonise data protection legislation across EU member states, enhancing privacy rights for individuals and providing a strict framework within which commercial organisations can legally operate.
Even though the UK has expressed its intention to leave the EU in March 2019, the GDPR has been applicable in the UK from 25th May 2018. The Government intends for the GDPR to continue in UK law post Brexit and has also introduced a Data Protection Bill to replace the current Data Protection Act in due course.
Your new rights under the GDPR are set out in this notice and apply now that the GDPR has become law.
Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.
For the purposes of data protection legislation in force from time to time the data controller is Agility by Nature of Venture House, Arlington Square, Downshire Way, Bracknell, Berkshire, RG12 1WA.
Our nominated representative is Paula Bacon
Who we are and what we do
We are an associate driven consultancy. Our focus is not utilisation and “the bench” but instead it is to deliver outcomes with people and always focus on Value.
Information you give to us or we collect about you
This is information about you that you give us by uploading your CV to our website (our site) or by corresponding with us by phone, e-mail or otherwise. It includes information you provide when you register with us, to enter our database, or other social media functions on our site.
The information you give to us or we collect about you may include your name, address, private and corporate e-mail address and phone number, financial information, compliance documentation and references verifying your qualifications and experience and your right to work in the United Kingdom or elsewhere, curriculum vitae and photograph, links to your professional profiles available in the public domain e.g., LinkedIn, Twitter, business Facebook or corporate website.
Information we collect about you when you visit our website
On each of your visits to our website we will automatically collect the following information
• technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information if applicable, browser type and version, operating system and platform.
• information about your visit, including [the full Uniform Resource Locators (URL),] clickstream to, through and from our site (including date and time), download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page and any phone number used to call our contact number.
Other uses we will make of your data
Information we obtain from other sources
This is information we obtain about you from other sources such as LinkedIn, corporate websites, job board websites, online CV libraries, your business card, personal recommendations, and any other means. In this case we will inform you, by sending you this privacy notice, within a maximum of 30 days of collecting the data of the fact we hold personal data about you, the source the personal data originates from and whether it came from publicly accessible sources, and for what purpose we intend to retain and process your personal data.
We are working closely with third parties including business partners, sub-contractors in technical, professional, payment and other services, advertising networks, analytics providers, search information providers, credit reference agencies, professional advisors and others We may receive information about you from them for the purposes of our recruitment services and ancillary support services.
Purposes of the processing and the legal basis for the processing
We use information held about you in the following ways
To carry out our obligations arising from any contracts we intend to enter into or have entered into between you and us and to provide you with the information, products and services that you request from us or we think will be of interest to you because it is relevant to your career or to your organisation.
To provide you with information about other services we offer that are similar to those that you have already been provided with or enquired about.
The core service we offer to our candidates and clients is the introduction of candidates to our clients for the purpose of contract or permanent engagement. However, our service expands to supporting individuals throughout their career and to supporting businesses’ resourcing needs and strategies.
Our legal basis for the processing of personal data is our legitimate business interest, described in more detail below, although we will also rely on contract, legal obligation and consent for specific uses of data.
We will rely on contract as our legal basis for processing if we are negotiating or have entered into a placement agreement with you or your organisation or any other contract to provide services to you or receive services from you or your organisation.
We will rely on legal obligation if we are legally required to hold information on to you to fulfil our legal obligations.
We will in some circumstances rely on consent for particular uses of your data and you will be asked for your express consent, if legally required. An example of when consent may be the lawful basis for processing is when we need to hold or process sensitive personal data, such as your right to work in the UK, if you are a contractor.
Our Legitimate Business Interests
Our legitimate interest in collecting and retaining your personal data is described below.
As a recruitment business and recruitment agency we introduce candidates to clients for permanent employment or independent professional contracts. The exchange of personal data of our candidates and our client contacts is a fundamental, essential part of this process.
So that we can support our candidates’ career aspirations and our clients’ resourcing needs we require a database of candidate and client personal data containing historical information as well as current resourcing requirements.
To maintain, expand and develop our business we need to record the personal data of prospective candidates and client contacts.
Should we want or need to rely on consent to process your data lawfully, we will request your consent orally, by email or by an online process for the specific activity we require consent for and record your response on our system. Where consent is the lawful basis for our processing you have the right to withdraw your consent to this particular processing at any time.
Disclosure of your information inside and outside of the EEA
We will share your personal information with
Any member of our company or suppliers of our support services, both in the EEA and outside of the EEA.
Selected third parties including
• clients, for the purpose of introducing candidates to them;
• candidates, for the purpose of arranging interviews and engagements;
• clients, business partners, suppliers and sub-contractors for the performance and compliance obligations of any contract we enter into with them or you;
• subcontractors including payment and other financial service providers.
• credit reference agencies, our insurance broker, compliance partners and other sub-contractors for the purpose of assessing your suitability for a role where this is a condition of us entering into a contract with you.
We will disclose your personal information to third parties
• If we sell or buy any business or assets, in which case we will disclose your personal data to the prospective seller or buyer of such business or assets.
• If Agility by Nature or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
• If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms of business or terms and conditions for supply of and other agreements; or to protect the rights, property, or safety of Agility by Nature, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
The lawful basis for the third-party processing will include
• Their own legitimate business interests in processing your personal data, in most cases to fulfil their internal resourcing needs;
• satisfaction of their contractual obligations to us as our data processor;
• for the purpose of a contract in place or in contemplation;
• to fulfil their legal obligations.
Where we store and process your personal data
The data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (”EEA”). It may be transferred to third parties outside of the EEA for the purpose of our recruitment services. It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers. This includes staff engaged in, among other things, our recruitment services and the provision of support services. By submitting your personal data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy notice.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
Retention of your data
We understand our legal duty to retain accurate data and only retain personal data for as long as we need it for our legitimate business interests and that you are happy for us to do so. Accordingly, we have a data retention policy to remove data that we no longer have a legitimate business interest in maintaining.
We do the following to try to ensure our data is accurate
• Prior to making an introduction we check that we have accurate information from you
• We keep in touch with you during the recruitment process so you can let us know of changes to your personal data
• We check documentation provided by you in support of your registration or application for a particular role
We segregate our data so that we keep different types of data for different time periods. The criteria we use to determine whether we should retain your personal data includes
• the nature of the personal data;
• its perceived accuracy;
• our legal obligations;
• whether an interview or placement has been arranged; and
• our recruitment expertise and knowledge of the industry by country, sector and job role.
We may archive part or all of your personal data or retain it on our financial systems only, deleting all or part of it from our main Customer Relationship Manager (CRM) system. We may pseudonymise parts of your data, particularly following a request for suppression or deletion of your data, to ensure that we do not re-enter your personal data on to our database, unless requested to do so.
For your information, Pseudonymised Data is created by taking identifying fields within a database and replacing them with artificial identifiers, or pseudonyms.
Our current retention notice is available upon request.
You have the right to ask us not to process your personal data for marketing purposes. We will usually inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes and we will collect express consent from you if legally required prior to using your personal data for marketing purposes.
You can exercise your right to accept or prevent such processing by contacting us at A subject access request should be submitted to firstname.lastname@example.org
The GDPR provides you with the following rights. To
• Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
• Request erasure of your personal information. This enables you to ask us to delete or remove personal information 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 information where you have exercised your right to object to processing (see below).
• Object to processing of your personal information 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. You also have the right to object where we are processing your personal information for direct marketing purposes.
• Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
• Request the transfer of your personal information to another party in certain formats, if practicable.
• Make a complaint to a supervisory body which in the United Kingdom is the Information Commissioner’s Office. The ICO can be contacted through this link: https://ico.org.uk/concerns/
Access to information
The GDPR give you the right to access information held about you. We also encourage you to contact us to ensure your data is accurate and complete.
Your right of access can be exercised in accordance with the GDPR and any access request under the Data Protection Act will not be subject to a fee.
A subject access request should be submitted to email@example.com
Changes to our privacy notice
Any changes we make to our privacy notice in the future will be posted on this page and where appropriate notified to you by e-mail. Please check back frequently to see any updates or changes to our privacy notice.
Questions, comments and requests regarding this privacy notice are welcomed and should be addressed A subject access request should be submitted to firstname.lastname@example.org