Privacy Notice

1. Collection and use of personal data

a. Purpose of processing and legal basis

The Companies will collect your personal data (which may include Special Category personal data) and will process your personal data for the purposes of providing you with work-finding services and related marketing. This includes for example, contacting you about job opportunities, assessing your suitability for those opportunities, updating our databases, putting you forward for job opportunities, arranging payments to you and developing and managing our services and relationship with you and our clients.

In some cases, we may be required to use your data for the purpose of investigating, reporting and detecting crime and also to comply with laws that apply to us. We may also use your information during the course of internal audits to demonstrate our compliance with certain industry standards.

The legal bases we rely upon to offer our work-finding services to you are:

• Where we have a legitimate interest
• To comply with a legal obligation that we have
• To fulfil a contractual obligation that we have with you
• Your consent

b. Consent

The Companies will seek your specific consent to process data relating to your health, our ability to undertake regular and ongoing status checks with the Disclosure and Barring Service and any criminal convictions. If you have opted-in we may also send you various company and sector news, career development advice and courses, and job alerts via email/ text. You can opt-out from receiving these at any time by clicking the link to the Companies’ Preference Services when you receive these communications from us and changing your preferences.

c. Legitimate interest

This is where a Company has a legitimate reason to process your data provided it is reasonable and does not go against what you would reasonably expect from us. Where the Companies have relied on a legitimate interest to process your personal data our legitimate interests are as follows:

• Managing our database and keeping work-seeker records up to date
• Providing work-finding services to you and our clients
• Contacting you to seek your consent where we need it
• To determine level of interaction with our pages in order to improve our services and interactions with you
• Giving you information about similar products or services that you have used from us recently

d. Statutory/contractual requirement

The Companies have certain legal and contractual requirements to collect personal data. These include, but are not limited to:

• To comply with the Conduct of Employment Agencies and Employment Businesses Regulations 2003
• Immigration and tax legislation
• To carry out pre-engagement vetting checks, including but not limited to:
  • To comply with the Safeguarding Vulnerable Groups Act 2006
  • To comply with the Department for Education statutory guidance (Keeping Children Safe in Education) to verify your physical and mental fitness to teach and/or work with children
  • To comply with the Education (Health Standards) (England) Regulations 2003 to verify your suitability to work in regulated activity with children
  • Verify your right to work

Our clients may also require this personal data, and/or we may need your data to enter into a contract with you.

If you do not give us the personal data we need to collect then we will be unable to continue to provide work-finding services to you.

e. Recipients of data

The Companies will process your personal data and/or Special Category personal data with the following recipients:

• Clients (whom we may introduce or supply you to)
• The other Companies and their brands, which use your candidate record to offer you work across the group
• Former employers whom we may seek references from
• Named individual you provided for seeking a reference from
• Payroll service providers who manage payroll on our behalf or other payment intermediaries whom we may introduce you to
• Third parties which provide, host, develop and/or support our IT systems and software, including the Orbit platform, subject to appropriate security measures and, where they are located outside the United Kingdom, to the safeguards described in section 4
• uCheck and TrustID for the purposes of carrying out DBS and identity checks
• GOV.UK, the Disclosure and Barring Service and the Department for Education for performing criminal records update checks, qualification checks, teacher sanction and restriction checks and the overall protection of vulnerable groups
• Teaching Regulation Agency and Education Workforce Council to perform teacher status checks
• HMRC for audit purposes and the provision of employment and payroll information
• Pension providers
• UK Government’s Visas and Immigration and the Home Office for checking right to work status.
• Overseas criminal records agencies and law enforcement agencies if you have been resident outside of the UK in the last 5 years for at least 6 months
• Audit and accreditation providers, such as The Recruitment and Employment Confederation (REC) and the International Organization for Standardization (ISO)
• Recruitment support teams operating within or on behalf of companies in the Supporting Education Group, which may be based outside the United Kingdom. Where personal data is transferred to such teams, appropriate safeguards are in place, including contractual protections and, where required, a UK International Data Transfer Agreement or equivalent mechanism. See Section 4 for further details.

The Companies are part of a group known as Supporting Education Group. As explained at the start of this notice, your candidate record is held on one shared platform and is available to all of the Companies so that they can provide work-finding services and related services to you. We may also share your personal data with other companies within Supporting Education Group where this is necessary for those services or for the administration of the group.

2. Marketing

From time to time, the Companies will provide marketing communications to you in various forms. Communications may come from any of the Companies, or from their parent company Supporting Education Group (“SEG”), including communications from other companies within SEG. This is in order to provide you with a personalised and targeted service but we also wish for you to have the choice in what communications you receive from us.

We follow laws and guidelines when sending marketing communications including: -

• Sending marketing communications to a work email address where possible
• When communicating with a non-work email address, we will ensure that we do so either under the soft opt in principles or with the user’s explicit consent to carry out marketing.
• In all instances to provide you with the ability to opt out of marketing. Because you have one record across our brands, opting out of marketing applies to marketing from all of the Companies and their brands rather than to one brand only. You can also tell us which channels we may use to contact you, and you can change your choices at any time.
• When using third party companies to assist with marketing we ensure data collection and use is done in accordance with data protection laws
• We never provide your details to third party companies outside of SEG.

Such marketing activities may include sending promotional and commercial communications regarding services offered by the Companies and/or SEG. This may include co-marketing or joint sale opportunities, including promotional events, training and webinars.

In some cases you provide personal data to us through group company platforms. That data may be shared and combined with personal data collected throughout your relationship with the Companies. Where this is done we will tell you and, where necessary, we will obtain your consent before doing so.

To view the SEG Privacy Policy, click here.

3. The Companies have collected or may collect the following personal data on you:

Personal data:

• Contact details (name, address, phone number and email address)
• ID documents
• Type of candidate, subject specialism, focus areas and work preferences when provided on job boards and/or LinkedIn
• Your CV (including video CVs)
• Photographs (in order to aid recruitment possibilities but also for schools to be able to identify you when starting a placement)
• Details of your qualifications, experience, employment history (including job titles, salary and working hours)
• References
• Client feedback
• Consultant notes
• Records of your availability, bookings, timesheets, pay and expenses
• Online activity on the Companies’ websites and on the Orbit platform

Special Category personal data:

• Health information in accordance with the Education (Health Standards) (England) regulations 2003

Criminal Offence Data:

• Criminal conviction and record checks strictly adhering to all established codes of conduct and processing

Source of the personal data: The Companies sourced your personal data:

• Former employer
• A referee whose details you provided to us
• Various Jobs boards and aggregators, such as Broadbean and Idibu, and LinkedIn
• Cookies
• Records held in the systems used by the Companies before the Orbit platform was introduced

This information did not come from a publicly accessible source.

4. Overseas Transfers

From time to time, the Companies may transfer your personal data to countries outside the United Kingdom. This may occur where, for example, we use recruitment support teams or operational partners located overseas. At the time of publishing this notice, this includes transfers to India, Vietnam and the United States of America. We will ensure that any such transfers are made only where appropriate safeguards are in place, in accordance with UK data protection law. These safeguards may include a UK International Data Transfer Agreement (UK IDTA) or another legally recognised transfer mechanism. These transfers include personal data held on, or accessed through, the Orbit platform by the teams and suppliers who develop, host and support it. You have the right to obtain a copy of the safeguards we have put in place for any such transfer by contacting us using the details at the top of this notice.

5. Data retention

The Companies will retain your personal data only for as long as is necessary for the purpose we collect it. Different laws require us to keep different data for different periods of time. For example, the Conduct of Employment Agencies and Employment Businesses Regulations 2003, require us to keep work-seeker records for at least one year from (a) the date of their creation or (b) after the date on which we last provide you with work-finding services.

We must also keep your payroll records, holiday pay, sick pay and pensions auto-enrolment records for as long as is legally required by HMRC and associated national minimum wage, social security and tax legislation. This is currently 3 to 6 years.

There is a legitimate interest to hold your personal data for no longer than 6 years after our work-finding service relationship ends.

Because you have one record across our brands, these periods run from the end of your relationship with the Companies as a whole and not from the end of your relationship with any single brand. If you stop working through one brand but remain registered with another, your record is retained for as long as that relationship continues.

We must retain any records relating to concerns or safeguarding allegations in accordance with statutory retention periods:

• Low-level concerns: retained for a minimum of the agency worker’s engagement period plus 6 years.
• Allegations meeting the harm threshold: retained until the agency worker reaches normal retirement age or for 10 years, whichever is longer.

Where the Companies have obtained your consent to process your personal data and Special Category data, we will do so in line with our retention policy.

Where consent is not granted the Companies will cease to process your personal data and Special Category personal data.

If you have any questions about our retention policy, you can email dataservices@judicium.com.

6. Your rights

Please be aware that you have the following data protection rights:

• The right to be informed about the personal data the Companies processes on you;
• The right of access to the personal data the Companies processes on you;
• The right to rectification of your personal data;
• The right to erasure of your personal data in certain circumstances;
• The right to restrict processing of your personal data;
• The right to data portability in certain circumstances;
• The right to object to the processing of your personal data that was based on a public or legitimate interest;
• The right not to be subjected to solely automated decision-making that produces legal or similarly significant effects, including where artificial intelligence tools are used in our recruitment and selection process (see Section 14); and
• The right to withdraw consent at any time.

Where you have consented to the Companies processing your personal data and Special Category personal data you have the right to withdraw that consent at any time by contacting us using the details above. Please note that if you withdraw your consent to further processing that does not affect any processing done prior to the withdrawal of that consent, or which is done according to another legal basis. There may be circumstances where the Companies will still need to process your data for legal or official reasons. Where this is the case, we will tell you and we will restrict the data to only what is necessary for those specific reasons. If you believe that any of your data that the Companies processes is incorrect or incomplete, please contact us using the details above and we will take reasonable steps to check its accuracy and correct it where necessary. You can also contact us using the above details if you want us to restrict the type or amount of data we process for you, access your personal data or exercise any of the other rights listed above.

Because the Companies are joint controllers, you can exercise any of these rights against any one of them, and a request made to one is treated as a request made to all. Where we act on a request we will apply it to your whole record across all of our brands, unless you ask us to apply it more narrowly and we are able to do so.

Automated checks on your record. The Orbit platform carries out some automated checks. For example, it monitors when a clearance, qualification or training certificate is due to expire, and it records the outcome of status checks with the Disclosure and Barring Service, the Teaching Regulation Agency and the Education Workforce Council. These checks can change the status of your record and can pause your availability for work while the position is confirmed. A member of our team reviews the position before a decision is made about your registration or your engagement, so these are not decisions taken solely by automated means. You can ask us to explain a change to your record, and you can ask for it to be reviewed, by contacting us using the details above.

7. Cookies

We may obtain data about you from cookies. These are small text files that are placed on your computer by websites that you visit. They are widely used in order to make websites work, or work more efficiently, as well as to provide information to the owners of the site. Cookies also enable us to deliver more personalised content.

Most web browsers allow some control of most cookies through the browser settings. To find out more about cookies, please refer to our Cookie policy or visit www.allaboutcookies.org or www.youronlinechoices.eu. Please note that in a few cases some of our website features may not function if you remove cookies from your browser.

8. Log Files

We use IP addresses to analyse trends, administer the site, track users’ movements, and to gather broad demographic information for aggregate use. IP addresses are not linked to personally identifiable information.

9. Links to external websites

The Companies’ websites may contain links to other external websites. Please be aware that the Companies are not responsible for the privacy practices of such other sites. When you leave our site we encourage you to read the privacy statements of each website that collects personally identifiable information. This privacy statement applies solely to information collected by the Companies’ websites.

10. Sale of business

If the Companies’ businesses are sold or integrated with another business your details may be disclosed to our advisers and any prospective purchasers and their advisers and will be passed on to the new owners of the business.

11. Data Security

The Companies take every precaution to protect our users’ information. Security measures include, but are not limited to, the use of firewalls and endpoint protection, browser certification technology, encryption, limited access principle, malware protection, and use of AI-based ransomware and exploit protection tools.

Only employees who need the information to perform a specific job (for example, consultants, our accounts clerk or a marketing assistant) are granted access to your information.

The Companies use all reasonable efforts to safeguard your personal information. However, you should be aware that the use of email/ the Internet is not entirely secure and for this reason the Companies cannot guarantee the security or integrity of any personal information which is transferred from you or to you via email/ the Internet. If you share a device with others we recommend that you do not select the “remember my details” function when that option is offered. If you have any questions about the security at our website, you can email dataservices@judicium.com

12. Changes to this privacy statement

We will update this privacy statement from time to time. We will post any changes on the statement with revision dates. If we make any material changes, we will notify you. The current version is available on our websites and, where you use it, through the Orbit platform.

13. Complaints or queries

If you wish to complain about this privacy notice or any of the procedures set out in it please contact the Data Protection Officer using the details above.

You also have the right to raise concerns with Information Commissioner’s Office on 0303 123 1113 or at https://ico.org.uk/concerns/, or any other relevant supervisory authority should your personal data be processed outside of the UK, if you believe that your data protection rights have not been adhered to.

If you have any questions or if you feel that we are not complying with the terms of this privacy policy please do contact us by e-mailing us at the following address dataservices@judicium.com inserting the words ‘Privacy Policy Grievance’ in the heading.

14. Use of Artificial Intelligence in our Recruitment and Selection Process

The Companies and associated companies within Supporting Education Group may use artificial intelligence (AI) tools to support elements of the recruitment and selection process. This may include, but is not limited to, the use of AI-assisted interviewing tools, automated screening, skills assessment, and the evaluation of candidate responses against role-specific criteria.

AI-assisted interviewing is currently used only in defined parts of our process and only where you have applied to a role with us. Where an AI-assisted element applies to you, we will tell you before it is used and we will give you further information about the tool and its provider at that point.

Where AI tools are used in our process, we want you to be aware of the following:

• Human review: AI-generated outputs are used to inform, not solely to determine, decisions about your application. A qualified member of our recruitment team will always review AI outputs before any decision is made about your progression in the recruitment process. We will not make decisions about your application based solely on automated processing.
• Your right to an alternative process: If you do not wish to participate in an AI-assisted element of the recruitment process, you have the right to request an alternative human-led assessment instead. Requesting an alternative will not disadvantage your application in any way. Please contact your recruitment consultant or email us using the details at the top of this notice to exercise this right.
• Data processed by AI tools: Where you participate in an AI-assisted element of the process, the personal data you provide (such as your responses to interview questions) will be processed by the AI tool and its provider, who acts as a data processor on our behalf. That provider is contractually required to process your data only on our instructions, to keep it secure, and to delete it when no longer required. Your data may be stored on servers outside the UK; where this is the case, appropriate safeguards are in place as described in Section 4.
• Fairness and bias: We take the risk of algorithmic bias seriously. We only use AI tools where we have taken steps to satisfy ourselves that they operate fairly. We monitor outcomes from AI-assisted processes to identify and address any patterns of unfair treatment. If you have concerns about how AI has been used in your application, please contact us using the details at the top of this notice.
• Lawful basis: Our use of AI tools in recruitment is based on our legitimate interests in operating an efficient, fair and effective recruitment service. Where we rely on legitimate interests, we have assessed that our interests do not override your rights and freedoms as a candidate, taking into account the safeguards described above.