Privacy Policy

About Gabrielle Brooke Associates Ltd and what we do

Gabrielle Brooke Associates Ltd provides recruitment solutions to meet our clients’ needs by connecting specialised talent with leading employers across multiple geographies, industries and disciplines.

We are a recruitment agency and recruitment business as defined in the applicable employment and industry specific legislation and regulations, including but not limited to, the Employment Agencies and Employment Businesses Regulations 2003.

Within Gabrielle Brooke Associates Ltd, we also provide other services as follows: executive search, managed services, and consultancy, acting in the capacity of Processor.

Overview of our approach to privacy

The protection of your personal data is very important to us because we recognise how important it is to you, and quite simply, YOU are OUR business.

In most cases Gabrielle Brooke Associates Ltd is the controller of personal data processed as described in this Privacy Statement for the purposes of the General Data Protection Regulation in Europe (“GDPR”). 

This Privacy Statement applies to the processing of personal data by Gabrielle Brooke Associates Ltd in its role as controller of personal data under the GDPR. Personal data includes any data about a person that enables them to be identified from that data. This Privacy Statement describes our approach to privacy. It includes detailed information about the type of personal data that we process and how it is used and managed within Gabrielle Brooke Associates Ltd.

Whose personal data do we have?

This Privacy Statement applies to personal data we process in relation to:

· Candidates

· Clients

· Suppliers

· Website Users

As a recruitment business we connect those looking for a job (“Candidates”) with businesses who are looking for Candidates (“Clients”). For the purposes of this Privacy Statement, a Candidate is:

· an active job seeker;

· someone we identify as a potential job seeker;

· a contractor of Gabrielle Brooke Associates Ltd.

Our services include:

· the placing of Candidates with Clients in permanent and contract positions. A contract position is where the Candidate is supplied to a Client of Gabrielle Brooke Associates Ltd and is engaged on a contract of, or for, service, is operating via a personal service or umbrella company, or is an employee;

· a managed service offering, where bespoke sourcing and managed recruitment solutions are provided to meet the needs of the Client.

This Privacy Statement is not applicable to employees of Gabrielle Brooke Associates Ltd.

Sharing of personal data

We will need to share your information in order to provide services to you. We will always ensure that any transfer of personal data is undertaken in compliance with the law and ensures that appropriate technical and organisational measures are undertaken by any processor or sub-processor.

We will need to share your information in order to provide services to you. We will always ensure that any transfer of personal data is undertaken in compliance with the law and ensures that appropriate technical and organisational measures are undertaken by any processor or sub-processor.

In certain circumstances, we may disclose personal data as follows:

· to business partners and sub-contractors for the performance of any contract relating to services provided for the purposes of servicing our Clients and Candidates, including email, chat, ticketing, CRM, ATS, payment processors, data aggregators, hosting service providers, external consultants, auditors, IT consultants and lawyers;

· to analytics and search engine providers that assist us in the improvement and optimisation of the Website. This consists of information relating to the web pages visited on the Website and tracking codes from service providers like LinkedIn, Google, etc.;

· if Gabrielle Brooke Associates Ltd or substantially all of its assets are acquired by a third party, in which case personal data held by us will be one of the transferred assets;

· if we are under a duty to disclose or share personal data in order to comply with any legal obligation (including tax, audit or other authorities), or in order to enforce or apply any contracts that we have; and/or

· to protect our rights, property, or safety, or that of our Clients, Candidates or others. This may include exchanging information with other companies and organisations for the purposes of fraud protection.

More specifically, we may share Candidate information with the following parties:

· Clients and potential Clients;

· third party representatives of our clients;

· third parties providing verification services (for example, criminal record checks/ pre-employment screening services and assessments);

· We may be required to share references provided by Associate Contacts of Candidates in the event of an access request by the Candidate.

How do we access/update and delete your data

You have various rights relating to how your personal data is used including the right:

· to ask for access to the information we hold on you;

· to change information you think is inaccurate;

· to delete information (your right to be forgotten);

· to ask us to limit what we use your data for;

· to have your personal data moved to another provider (data portability);

· to make a complaint.

You have various rights relating to your personal information and how it is used by Gabrielle Brooke Associates Ltd as follows:

· You can ask for access to the information we hold on you. When we receive a request from you in writing, we must give you access to the information you have requested as well as details of the processing, the categories of personal data concerned and the recipients of the personal data. We will provide the first copy of your personal data free of charge but we may charge you a reasonable fee for any additional copies.

· You can ask to change information you think is inaccurate. You should let us know if you want to change the personal data we hold. We may not always be able to change or remove that information, but we will correct factual inaccuracies and may include your comments in the record.

· You can ask to delete information (your right to be forgotten). In some circumstances you can ask for your personal information to be deleted, for example, where:

- your personal information is no longer needed for the reason that it was collected in the first place;

- you have removed your consent for us to use your information (where we have no other legal reason us to use it);

- there is no legal reason for the use of your information;

- deleting the information is a legal requirement.

Where your personal information has been shared by Gabrielle Brooke Associates Ltd with others, we will do what we can to make sure those using your personal information on our behalf as processors comply with your request for erasure. Please note that we can’t delete your information where:

· we are required to have it by law;

· it is used for freedom of expression;

· it is used for public health purposes;

· it is used for scientific or historical research or statistical purposes where deleting the data would make it difficult or impossible to achieve the objectives of the processing; or

· it is necessary for legal claims.

We cannot give you access to a copy of your data if this would adversely affect the rights and freedoms of others. 

You can ask us to limit what we use your personal data for

You have the right to ask us to restrict what we use your personal data for where:

· you have identified inaccurate information, and have told us of it;

· where we have no legal reason to use that information but you want us to restrict what we use it for rather than erase the information altogether.

When personal data is restricted, it can’t be used other than to: securely store the data, with your consent, to handle legal claims and protect others, or where it is for important public interests.

Where restriction of use has been granted, we will inform you before we carry on using your personal data.

You have the right to ask us to stop using your personal data for any of our services. Where possible we will seek to comply with your request, but we may need to hold or use data because we are required to by law. You should also be aware that if your request is approved this may cause delays or prevent us delivering that service.

You can ask to have your personal data moved to another provider (data portability)

You have the right to ask for your personal information to be given back to you or another service provider of your choice in a commonly used format. This is called data portability. This right only applies to data stored in electronic form where we’re using your personal information on the grounds of consent or pursuant to a contract with you. It does not apply where it would adversely affect the rights and freedoms of others.

You can make a complaint

You have the right to lodge a complaint with the local supervisory authority for data protection. 

Security Measures

We monitor for and do everything that we can to prevent security breaches.

We will take all steps reasonably necessary to ensure that all personal data is treated securely in accordance with this Privacy Statement and the relevant law.

In particular, we have put in place appropriate technical and organisational procedures to safeguard and secure the information we manage and collect.

To protect the privacy and security of personal data, we will also take reasonable steps to verify your identity before granting access to information as appropriate.

Once we have received your information, we will use strict procedures and security features for the purpose of preventing unauthorised access.

If you think that there has been any loss or unauthorised access to personal data of any individual, please let us know immediately.

Third party websites

We are responsible for our own privacy practices, not those of a third party.

You may access Gabrielle Brooke Associates Ltd services through links to and from third party websites. If you follow a link to any of these websites, please note that these websites may have their own privacy statements. We do not accept any responsibility or liability for these third party websites nor do we provide support for their services. Please undertake the appropriate due diligence before submitting any personal data to these websites.

Amendments to this privacy statement

We will update the date on this Privacy Statement when we make changes to it.

We will post any changes on the website and when doing so will change the updated date at the top of this privacy statement. If you are not happy with any changes that we have made, we understand you may wish to cease using our services

In some cases we may provide you with additional notice, for example by email, of changes to this Privacy Statement. If we deem the changes to be material, we will provide you with such additional notice well in advance of the changes taking effect.