In line with the General Data Protection Regulation, Equal Approach Limited is committed to providing clarity regarding the types of personal information we collect, how we use the information, who we share it with, and your data rights in terms of how your information is used, stored and shared.
Personal Information That We May Request from You
We will collect personal information about you using a variety of methods, such as (but not limited to) through our Equal Approach website, through our Inclusive Talent Portal – Reach, social media channels, events, surveys, job applications, telephone screenings, interviews and subsequent online, telephone, email contact and also through our other Embedding Inclusion product services where data collection is required.
As part of providing our services, we may request the following types of personal information from you, but not limited to:
- Contact information (name, address, email address and telephone number).
- Employment history, education, qualifications, professional registrations and information about you provided in your CV or that you complete in an application form.
- Details of your skills, competencies and capability.
- Results of skills assessments,
- Information about citizenship, visa status and right to work in the UK.
- Results of criminal and other background checks.
- NI number.
- Date of birth.
- Details provided relating to age, gender, ethnicity, disabilities / health related information as well as information relating to other protected characteristics as defined under the Equality Act 2010 which may be gathered to support diversity monitoring
- Details of those you provide as emergency contacts.
- Information provided about you in references.
- Information you provide about family, friends or other people you would like us to contact.
- Information you provide us with in surveys.
- Information about your performance on temporary assignments.
- Payroll and financial information (such as bank details, tax-related information, benefits you receive etc).
- Login details required for use of our Equal Approach Website, Reach Inclusive Talent Portal or Inclusion Hub.
PLEASE NOTE: by completing any Equal Approach registration / personal information documentation, you are giving consent for us to use, store and share your personal data for you. This could be for the purpose of sourcing suitable work for you, monitoring/managing your assignments or placements and/or if appropriate marketing relevant services that we are providing to you or your company. This is the legal basis on which we process your personal data and you can withdraw your consent at any time by emailing firstname.lastname@example.org. We will stop processing if we have no other legal basis or requirement to do so.
Where the personal data collected includes sensitive/special category data, we will obtain a separate, explicit consent from you for this, which may be withdrawn in the same way. Examples of special category data include, but are not limited to, information about your health, race, sexual orientation, criminal convictions etc.
Automated Information We May Collect from You
When you visit our website, we may collect certain information by automated means, such as using cookies, and web server logs. The information we may collect in this manner includes IP, unique device identifier, browser characteristics, device characteristics, operating system, language preferences, referring URLs, information on actions taken on our website, dates and times of visits to our website and other usage statistics.
Equal Approach uses the following cookies and logging:
|Cookies & Logs We Use||Why We Use Them|
|Google Analytics||These cookies are used to collect information about how users and visitors use our website and our blog. We use the information to compile reports and to help us improve the website.|
|Microsoft Azure||In order for Equal Approach to be fully compliant, we keep all activity logged from our web host, this only includes IP addresses and no other personal data. This is used to make sure that your experience on our website is safe and secure and ensure no data is put at risk.|
We may obtain data (including but not limited to your browser information) through these automated collection methods as you click through various pages on our website. As required by law, we will obtain your consent before collecting personal data using cookies or similar automated means.
We may also use third-party apps, tools, plug-ins and widgets on our website and these may use automated means to collect information relating to how you interact with these features. Such information collected is subject to the privacy policies of those providers and to applicable law. Equal Approach Limited is not responsible for the practices of these providers.
How We Use the Information We Collect
We will use the information you provide to:
- Provide you with our inclusive talent recruitment services or our embedding inclusion consultancy services.
- Respond to your enquiries.
- Manage client relationships.
- Analyse data and trends from our websites and using data held on our recruitment software.
- Prevent fraudulent and unlawful activity and comply with legal requirements, industry standards, contractual obligations and company policies/procedures.
- Improve our business services and the performance of our website.
- Create and manage online accounts and records.
- We also may use the information in other ways for which we will request specific consent at or prior to the time of collection.
Additional for Recruitment – Temporary, Interim & Permanent
- Assess your suitability as a candidate and validate your experience, competence, qualifications, registrations etc as required by the position for which you are applying.
- Provide you with job opportunities and work.
- Provide career advice.
- Process payments to you and send you payslips where applicable.
- Monitor and manage your performance and discipline as a temporary worker
- Audit compliance with prevailing employment law and honour contractual agreements with our clients.
- Send you information about vacancies, promotional material and other communications (e.g. invitations to participate in our surveys or events).
- We may also use the personal data we hold, to take automated decisions about your suitability for a work role, applying for such a role and providing our services to you. In this event we will notify you in advance and provide the opportunity to discuss and review any outcome with a member of our personnel.
Your IP address may be partially disclosed (region only) to third-party analytics providers such Google Analytics to help us analyse the use of our website and track the effectiveness of our marketing activity and user experience.
Information We Share
We will only disclose personal information we collect about you to facilitate delivery of our services.
Where personal information is shared with a managed service provider or other 3rd party supplier, we do not authorise them to use or disclose your personal data except in the provision of the service that they have been engaged to supply or to comply with legislation.
Finally we may disclose your personal data to comply with any applicable law, in connection with an investigation of suspected or actual fraudulent activity or is based on a lawful disclosure request.
We will never:
- Sell your personal data to a third party.
- Share your personal data with a third party for marketing purposes without your consent.
How Long We Will Retain Your Personal Data
We will retain your personal information for a reasonable duration to provide you with our services and to comply with prevailing legislation and regulation as follows:
|Type of Records||Statutory Retention Period||Statutory Authority|
|Accident book / accident records & reports||3 years from date of the last entry (or if the accident involves a child, until that person reaches the age of 21.||Reporting of Injuries, Diseases and Dangerous Occurrences Regulations 1995 (RIDDOR) (SI 1995/3163) as amended, and Limitation Act 1980.|
|Accounting records||3 years
|Section 221 of the Companies Act 1985 modified by the Companies Acts 1989 and 2006.|
|Income tax and NI returns, income tax records and correspondence with HMRC||Not less than 3 years after the end of the financial year to which they relate.||The Income Tax (Employments) Regulations 1993 (SI 1993/744) as amended, for example by The Income Tax (Employments) (Amendment No. 6) Regulations 1996 (SI 1996/2631).|
|Statutory maternity pay records, calculations, certificates or other medical evidence||3 years after the end of the tax years in which the maternity period ends.||The Statutory Maternity Pay (General) Regulations 1986 (SI 1986/1960) as amended.|
|Wage / salary records, overtime, bonuses, expenses||6 years||Taxes Management Act 1970.|
|National minimum wage records||3 years after the end of the pay reference period following the one that the records cover.||National Minimum Wage Act 1998|
|Records relating to working time||2 years from the date on which they were made||The Working Time Regulations 1998 (SI 1998/1833).|
For many types of HR records, there is no definitive retention period and we are entitled to decide how long to keep them. Equal Approach has based our records retention periods below on the time limits for potential UK tribunal or civil claims and guidance in the Conduct of Employment Agencies and Employment Businesses Regulations 2003. The UK Limitation Act 1980 contains a 6-year time limit for starting many legal proceedings, so where documents may be relevant to a contractual claim, we will keep these records for at least this period. Other records may be retained longer or permanently. These retention periods are in line with CIPD recommendations.
|Type of Records||Minimum Retention Period|
|Actuarial valuation reports||Permanently|
|Application forms and interview notes (for unsuccessful candidates)||6-12 months.|
|Assessments under health and safety regulations and records of consultations with safety representatives and committees||Permanently|
|Inland Revenue/HMRC approvals||Permanently|
|Parental leave||5 years from birth/adoption of the child or 18 years if the child receives a disability allowance.|
|Pension scheme investment policies||12 years from the ending of any benefit payable under the policy.|
|Candidate files, personnel files and training records (including disciplinary records and working time records)||7 years after the date on which we last provide services to the associated applicant or client or 7 years after employment has ended.
We may hold data significantly longer if contractually required to do so, and for contract clients we will hold all data relating to service provided for a minimum of seven years after the contract expires. Where such records could be relevant to a claim for personal injury, we will retain them for a minimum of 21 years from contract expiry.
|Redundancy details, calculations of payments, refunds, notification to the Secretary of State||6 years from the date of redundancy|
|Senior executives’ records (that is, those on a senior management team or their equivalents)||Permanently|
|Statutory Sick Pay records, calculations, certificates, self-certificates||6 years after the employment ceases.
|Timesheets||2 years after audit|
|Trade union agreements||10 years after ceasing to be effective|
After these durations have elapsed, your personal data will be securely deleted or destroyed.
How We Protect Your Personal Information
We maintain administrative, technical and physical safeguards to protect the personal information you provide against accidental, unlawful or unauthorised destruction, loss, alteration, access, disclosure or use.
Your Rights & Choices
If you have any questions about the use of your personal information or would like to update your preferences, please contact us as specified below.
Your Right to Object
You have the right to ask us not to process your personal data if you do not believe we are permitted to do so, including for marketing purposes. Following such notification, we will stop processing your personal data unless there is a legal basis or requirement to do so.
We will inform you (before collecting your data) if we intend to use your data for marketing purposes. We will only use your data for this if you have agreed in advance.
Correction of Information
If you notify us that the personal data we hold is complete or inaccurate we will correct or complete the information as soon as possible.
Deletion of Information
You have the right to request that your personal data be deleted; including if we no longer need it for the purpose we collected it, or you withdraw your consent.
Following such a request we will erase your personal data without undue delay unless continued retention is necessary and permitted by law. If we made the personal data public, we will take reasonable steps to inform other data controllers processing about your erasure request.
Restriction on Processing
You have the right to request that we stop processing your personal data, but hold it for you, in the event the personal data we hold is inaccurate, the processing is unlawful or we no longer need the personal data. Once the processing is restricted, we will only continue to process your personal data if you consent or we have another legal basis for doing so.
Access to Information
You have the right to access information held about you and any access request will usually be free of charge and responded to within 30 days. We will endeavor to provide information in a format requested, but we may charge you a reasonable fee for additional copies.
You have the right to receive a copy of your personal data which you gave to us. The copy will be provided in a commonly used and machine-readable format. You can also have it transmitted directly from us to another data controller, where technically possible.
To contact us directly about a general enquiry, you can use either of the following email addresses:
If we fail to respond to your Subject Access Request (SAR) within 30 days of receipt or you wish to make a complaint relating to our response to your SAR or any other data rights request, you should initially contact:
Ben Runcorn, Data Management Contact
Equal Approach Limited,
6 Barberry Court,
Burton upon Trent
We will aim to acknowledge a complaint within 24 hours an Investigation will commence immediately with an assessment of the situation and contact with all individuals involved.
Where appropriate, internal interviews will be held as soon as possible.
In every case we will take all reasonable and practicable steps to resolve the complaint within 15 working days of its receipt unless the nature of the complaint requires additional investigation or action by an appropriate third party in which case the complaint will be resolved as soon as possible thereafter.
During the complaints resolution process we will ensure that you are kept abreast of progress in resolving the complaint.
We maintain a written log of all complaints which includes your name and contact details, nature of the complaint, actions taken to resolve it and any changes to procedures to prevent recurrence.
If the Data Management Contact cannot resolve the problem or if you are dissatisfied with any aspect of the handling of your complaint, you should contact our Managing Director, outlining the details in full to:
Julie Patrick, Managing Director
Equal Approach Limited,
6 Barberry Court,
Burton upon Trent.
You also have the right to complain to the Information Commissioner’s Office if you believe that we have not complied with the above policy or the law pertaining to your personal information on the following number: 0303 123 1113.