Joss Search and Selection Limited respects your privacy and is committed to protecting your personal data. We process personal data in accordance with the UK General Data Protection Regulation (UK GDPR), the Data Protection Act 2018 and, where applicable, the EU General Data Protection Regulation (EU GDPR). This privacy notice will inform you as to what personal data we collect, why we process it, for how long we will process it, with whom we will share your data, as well as your legal rights regarding the processing of your personal data, and how we look after the personal data which you provide to us or which we obtain when you are a Client, Candidate, when you use our website (www.josssearch.com), or when we deal with you in the course of our business.
We may update this privacy policy from time to time – you can find our latest policy on our website at https://josssearch.com/privacy-policy/ or by asking us for a copy.

IMPORTANT INFORMATION ABOUT THE CONTROLLER:
Joss Search and Selection Limited (a company with company number 07143280) is the controller and responsible for your personal data (collectively referred to as “Joss Search”, “we”, “us” or “our” in this privacy notice).
This privacy notice makes reference to our “Clients”, being businesses that seek our services to source and recruit individuals on their behalf, and our “Candidates”, who are individuals that we source in order to fulfil our Clients’ personnel requirements (on a temporary or permanent basis).
If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact us using the details set out below.

Contact details: Our full contact details are as follows:
– Address: 10 York Road, London, SE1 7ND
– Telephone Number: +44 (0)20 3096 7050
– Email address: dataprotection@josssearch.com

Third-party links: Our 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.

Calls made to us: Calls may be recorded for training, quality assurance, compliance, dispute resolution and record-keeping purposes. Access is restricted to authorised personnel and recordings are retained in accordance with our retention schedule.

THE PERSONAL DATA WE COLLECT:

Personal data is any information relating to you that allows us to identify you.

For the purposes listed below, we collect, use, store and transfer the following information:

Identity and Contact Data: personal and identity data, including your name, date of birth, copies of ID, postal address, email address, telephone numbers and information relating to your immigration status and right to work;
• Recruitment Data: references and other information included in a CV or covering letter;
• Financial Data: information regarding remuneration packages offered to Candidates by our Clients including information regarding salary, fee rates, bonuses, expenses and benefits in kind; bank account numbers.
• Technical Data: information we collect automatically when you visit our website or interact with us by email, including your IP address, browser details, and device details;
• Transaction Data: details of services we provide to you;
• Marketing and Communications Data: including your preferences in receiving marketing from us and your communication preferences.
• Photographs and videos: we may take your photograph for promotion and marketing purposes at social events that we hold and you attend, however we will not publish any image of a person without first seeking consent.
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 (for example, to provide you with our services).

Criminal Records
We occasionally conduct Disclosure and Barring Service (DBS) checks on our Candidates. Where we carry out DBS checks, we will only do so with a Candidate’s prior written consent. Where a DBS check is required for a particular role, the outcome of the check or confirmation of its completion may be shared with the relevant Client, to the extent necessary for the recruitment process and permitted by law. We have relevant and appropriate safeguards in place which we are required by law to maintain when processing data regarding criminal convictions.

Where we collect your data from
• We collect your data from different sources:
• We collect all of the types of data listed above directly from you when you interact with us;
• We may obtain personal data from publicly available professional sources, including LinkedIn, employer websites and job boards, where relevant to legitimate recruitment activities;
• We collect data on criminal records from the Disclosure and Barring Service;
• We collect name and contact details from professional contacts or third parties who send us your details as prospective Candidates or Clients;
• We collect Technical Data automatically when you interact with our website or email us or unsubscribe from our mailing list, by using cookies and other similar technologies.

HOW WE USE YOUR PERSONAL DATA:
We will only use your personal data when the law allows us to. We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate. 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 using the details above if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

NOTE: For each processing activity, you can rely on ONE legal basis

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. 

In addition, we may process your personal data without your knowledge or consent where this is required or permitted by law. 

Marketing 

We may use your personal data to send you occasional emails containing market insights, salary information, career advice and events that we believe may be of genuine interest to you. We aim to ensure that these communications are relevant to your professional profile and relationship with Joss Search and are sent on an infrequent basis.

Where permitted by applicable law, we send these communications on the basis of our legitimate interests in maintaining our relationship with candidates, providing ongoing recruitment services, sharing useful industry information and helping candidates identify suitable career opportunities.

You have the right to object to receiving marketing communications from us at any time. Each marketing communication will include a simple way to unsubscribe, and you may also contact us directly to update your preferences. We will promptly honour any request to stop receiving marketing communications.

Unsubscribing from marketing communications will not prevent us from contacting you about roles you have specifically applied for, ongoing recruitment processes, placements, contractual matters or other non-marketing communications relevant to our services.

Cookies when using our website 

Non-essential cookies and similar technologies are used only with your consent where required by law. You can manage your cookie preferences through our cookie banner and browser settings. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.

Use of AI-Assisted Interview Recording, Transcription and Candidate Summaries

We may record video or telephone interviews and use AI-assisted tools to generate a written transcript and draft summary based solely on information you provide during your interview with us. These tools are used to support our recruiters by improving the accuracy, consistency and efficiency of note-taking and record-keeping.

AI-generated outputs may include draft summaries of your experience, responsibilities, achievements, skills and competencies, derived from information shared during the interview. Any such summaries are intended solely to assist our recruiters in preparing candidate records and profiles. They are not used to assess, score, rank, compare or make decisions about you, and do not determine whether you progress through a recruitment process.

All AI-generated transcripts, summaries and profile updates are reviewed by a human recruiter before use and may be amended, supplemented or removed where necessary to ensure accuracy, fairness and appropriate context. Recruitment decisions remain entirely human-led and are based on the recruiter’s professional judgement and consideration of all relevant information. We do not use AI-generated outputs as the sole basis for any decision that produces legal or similarly significant effects concerning an individual.

Where AI-assisted recording or transcription is used, you will be informed in advance. You may request that recording is paused or stopped, or discuss alternative arrangements with us, without any adverse impact on your application or relationship with us.

Interview recordings, transcripts and related summaries are retained only for a defined and proportionate period in accordance with our retention policies, and access is restricted to authorised personnel with a legitimate business need. We do not use recordings, transcripts or AI-generated summaries to infer sensitive personal characteristics, undertake automated decision-making, create candidate scores or rankings, or generate suitability recommendations. All personal data is processed in accordance with applicable data protection laws and this Privacy Policy.

Automated decision-making

We do not carry out solely automated decision-making in relation to candidates or clients. Any assessment of suitability for a role is undertaken by a human recruiter.

 DISCLOSURES OF YOUR PERSONAL INFORMATION 

We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 3 above: 

Third parties who we interact with on your behalf including Clients’ employees and staff and Candidates 

Joss Search Inc. Your data may be accessible to our subsidiary organisation in the US. 

Service Providers  based within the UK, wider EEA or outside the EEA who provide IT and system administration services. For example, CRM software providers.

Event Partners who assist us with organising events and marketing those events, based in the UK, wider EEA or outside the EEA. 

Our professional advisers including lawyers, bankers, auditors and insurers based in the UK or EEA who provide consultancy, banking, legal, insurance and accounting services. 

HM Revenue & Customs regulators and other authorities based in the UK who require reporting of our processing activities in certain circumstances. 

Disclosure and Barring Service for carrying out DBS checks. 

Third parties who provide background checks and references. 

Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice. 

We may share limited information with banking providers, lenders, investors or funding partners where necessary for legitimate business, financing, audit or due diligence purposes and where appropriate confidentiality obligations apply.

We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions. 

INTERNATIONAL TRANSFERS 

We may transfer your personal data to third parties providing services to us who are based outside of the UK and the European Economic Area (EEA). This includes parties providing cloud storage, hosting, CRM, communications and marketing platforms.

As stated above, your data may be accessible to our subsidiary organisation in the US. 

Whenever we transfer your personal data outside of the UK or EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented: 

– you have expressly consented to the transfer of data; 

– transferring data to countries that have been recognised as providing an adequate level of protection for personal data under UK data protection law and, where applicable, by the European Commission;

– using specific contracts with the Service providers approved by the European Commission which give you the same level of protection as when your personal data is processed in the European Unions; 

– for organisations based in the United States, we may transfer personal data where the recipient participates in a recognised adequacy framework or where appropriate safeguards are in place, including the UK International Data Transfer Agreement (IDTA), the UK Addendum to the EU Standard Contractual Clauses, or the European Commission’s Standard Contractual Clauses, as applicable.

– In the case of Joss Search Inc., Standard Contract Clauses are in place to ensure the same level of protection as when your personal data is processed in the European Union 

DATA STORAGE 

Personal data may be stored and processed within the United Kingdom, the European Economic Area and other jurisdictions where appropriate safeguards are in place. We implement technical and organisational security measures designed to protect personal data against unauthorised access, loss, misuse or disclosure.

DATA RETENTION 

We will only retain your personal data for as long as is necessary to fulfil the purposes for which it was collected, including to provide recruitment services, maintain our relationship with you, comply with legal, regulatory, accounting and reporting obligations, and protect our legitimate business interests.

The length of time for which we retain personal data will vary depending on the nature of our relationship with you, the type of information involved, and whether we continue to have meaningful contact with you.

For example: 

– If you are an active Candidate, we may retain your information while we are assisting you with job opportunities, managing applications, arranging interviews or placements, and providing related recruitment services.

– If you are a Candidate with whom we have had previous contact, we may retain your information where there remains a reasonable expectation that we may assist you with future employment opportunities, where you continue to engage with our communications or services, or where our relationship with you remains active notwithstanding a period without recent recruitment activity.

– If you are a Client, prospective Client or professional contact, we may retain your information for as long as we maintain an ongoing business or professional relationship with you.

We may retain records relating to placements, contractual arrangements, financial transactions, complaints, disputes, regulatory matters or legal claims where necessary to comply with legal obligations or to establish, exercise or defend legal rights.

Interview recordings, transcripts, AI-generated notes and related recruitment records will be retained only for so long as they remain relevant to the recruitment and relationship-management purposes for which they were collected.

When we determine that personal data is no longer required, we will securely delete, anonymise or otherwise dispose of it in accordance with our internal retention and information security procedures.

In determining appropriate retention periods, we take into account factors including the nature and sensitivity of the personal data, the purposes for which it is processed, the existence of any ongoing relationship with you, the time elapsed since our last meaningful interaction, our legal and regulatory obligations, and any actual or anticipated disputes or claims.

For further information about our retention practices, please contact us using the details set out in this Privacy Policy.

APPLYING TO WORK AT JOSS SEARCH

If you apply for a role directly with Joss Search, we will process your personal information to manage and assess your application, communicate with you during the recruitment process, verify information you provide, conduct interviews, obtain references where appropriate, and carry out any pre-employment checks required by law or relevant to the role.

In addition to the information described elsewhere in this Privacy Policy, we may collect and process recruitment-specific information such as interview notes, assessment results, reference information, right to work documentation, salary expectations and information relating to reasonable adjustments, health conditions or diversity monitoring where relevant to the recruitment process.

Your information will be accessible only to those involved in the internal recruitment process and will not be shared with our recruitment clients. Recruitment decisions are never based solely on automated processing.

If your application is unsuccessful, we may retain your information in accordance with the retention principles set out in this Privacy Policy and may consider you for future opportunities with Joss Search unless you ask us not to do so. If you are successful, your recruitment information will become part of your employee record and will be processed in accordance with our Employee Privacy Notice, which will be provided separately.

YOUR LEGAL RIGHTS 

Under certain circumstances, you have rights under data protection law in relation to your personal data. If you wish to exercise any of the rights set out below, or if you have concerns about how we have collected, used, shared, stored or otherwise processed your personal data, please contact us at dataprotection@josssearch.com.

You will not have to pay a fee to exercise your rights. However, we may charge a reasonable fee or refuse to act on a request where permitted by law, for example if a request is manifestly unfounded or excessive. 

Data protection complaints

If you believe that we have not handled your personal data in accordance with applicable data protection law, you have the right to make a complaint directly to us. 

Complaints can be submitted by contacting us at dataprotection@josssearch.com. We will acknowledge your complaint, investigate the matter appropriately and keep you informed of its progress where necessary. We will then notify you of the outcome of our investigation without undue delay.  

We hope to resolve any concerns you may have directly. However, if you remain dissatisfied with our response, you may contact the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection matters, through its website at www.ico.org.uk.  

Your Rights

Your rights under data protection law include 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 personal data corrected.

– Request erasure of your personal data in certain circumstances.

– Object to processing of your personal data where we are relying on legitimate interests as our lawful basis for processing. You also have the right to object to the processing of your personal data for direct marketing purposes.

– Request restriction of processing of your personal data in certain circumstances.

– Request the transfer (data portability) of your personal data to you or, where technically feasible, to another organisation, where this right applies.

– Withdraw consent at any time where we rely on consent as the lawful basis for processing your personal data. Withdrawal of consent will not affect the lawfulness of any processing carried out before consent was withdrawn.

If EU GDPR applies to the processing of your personal data, you may also have the right to lodge a complaint with the data protection supervisory authority in the EU Member State of your habitual residence, place of work or alleged infringement

Our EU Representative:

Under Article 27 of the GDPR , we have appointed an EU Representative to act as our data protection agent. If you want to raise a question to Joss Search and Selection, or exercise your rights under GDPR, you may prefer to contact our appointed EU representative rather than directly contacting us. Our nominated EU Representative is :

Instant EU GDPR Representative Ltd.

Adam Brogden contact@gdprlocal.com

Tel +35315549700

INSTANT EU GDPR REPRESENTATIVE LTD

Office 2,

12A Lower Main Street, Lucan Co. Dublin

K78 X5P8

Ireland