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Legal

Privacy Policy

How Smart Resource Solutions collects, uses and protects personal information.

1. Preamble

This Privacy Policy should be read and understood together with our general terms and conditions of business for Clients, Suppliers, Employees, Assignees and Candidates seeking employment. It applies to all Sofcomit Limited companies and trading styles namely, Smart Resource Solutions and SRS Group (collectively referred to as “Smart Resource Solutions”), why data is collected and processed by the businesses within the group, what data is collected and how it is processed. Smart Resource Solutions is committed to full compliance with UK Data Privacy Legislation for the time being as far as the utilisation and disclosure of data subject personal information (PI) is concerned.

Hence, technical, and operational measures have been put in place to protect data subject privacy and Smart Resource Solutions invites all data subjects and/ or requesters of (PI) to engage with its Information Officer (IO) in respect of any matter related hereto.

This Privacy Policy:

  • Outlines Smart Resource Solution’s practices and commitment to complying with Data Protection Act 2018;
  • Sets out the categories of personal information companies within Smart Resource Solutions may collect from third parties or other sources;
  • Outlines how Smart Resource Solutions processes personal information; and
  • Is fully binding on all stakeholders.

This privacy policy is an evolving document.

2. Scope of application

This policy applies to data subjects under UK Data Privacy Laws for the Time being in respect of requesters of records held by Smart Resource Solutions. PI applies to both natural and juristic persons. Data subjects and requesters are invited to engage with the Group’s Information Officer about any matter pertaining to the Data Protection Act 2018, including but not limited to updating PI, deletion of PI, complaints in respect of how PI is being processed and updating consent for electronic direct marketing. The “Information Officer” details are contained herein below for these types of engagement.

3. About the company

Smart Resource Solutions comprises of a group of businesses specialising in employment and staffing. The business specialises in offering services in recruitment, outsourcing, temporary employment services, permanent recruitment, skills development and training and international recruitment.

4. Purpose of Data Protection Act 2018

The Data Protection Act 2018 was promulgated to regulate the constitutional right to privacy and aims to protect the free flow of information and advance the right of access to information whilst giving effect to the right to privacy. The purpose of Data Protection Act 2018 is to ensure that when a responsible party is in possession of “personal information”, certain protective measures are taken to ensure that the information is protected.

5. Definition of personal information

(PI) Personal information’’ means information relating to an identifiable, living, natural person, and where it is applicable, an identifiable, existing juristic person, including, but not limited to:

  • information relating to the race, gender, sex, pregnancy, marital status, national, ethnic, or social origin, colour, sexual orientation, age, physical or mental health, well-being, disability, religion, conscience, belief, culture, language, and birth of the person.
  • information relating to the education or the medical, financial, criminal or employment history of the person.
  • any identifying number, symbol, e-mail address, physical address, telephone number, location information, online identifier, or other particular assignment to the person.
  • the biometric information of the person; (e) the personal opinions, views or preferences of the person.
  • correspondence sent by the person that is implicitly or explicitly of a private or confidential nature or further correspondence that would reveal the contents of the original correspondence.
  • the views or opinions of another individual about the person; and the name of the person if it appears with other personal information relating to the person or if the disclosure of the name itself would reveal information about the person.

6. Purpose of collecting and processing PI

Businesses and associates operating as a part of the Smart Resource Solutions process and use PI for various purposes including:

  • performing its duties in pursuance of any agreement or contract.
  • conducting market research, business and statistical analysis.
  • engaging in various forms of direct marketing.
  • facilitating transactions with data subjects.
  • collecting data for business intelligence purposes to improve its services by using cookies.
  • fulfilling its contractual obligations to its clients and client contacts.
  • providing recruitment services.
  • streamlining the job application process by enabling candidates to submit their applications and CV’s.
  • to send out candidate information to clients in order to apply for employment or to assess eligibility for employment.
  • to disclose information to third parties in order to verify details provided by candidates, through reference checks, qualification checks, credit checks, security checks, criminal checks and psychometric or skills assessments.
  • complying with the provisions of statute and regulations.
  • attending to the legitimate interests of data subjects.
  • identifying prospects for enhanced service delivery and business sustainability.
  • making contact, if and when required, to promote its services or in relation to a customer care query.
  • tracking data subject activity on the website and its links as well as their transactions with Smart Resource Solutions.
  • providing data subject information to partners in order for them to use the information to market their services to data subjects who are current clients and/ or who have consented as envisaged in the UK Data Protection Act. These partners who are recipients of PI are business organisations who are permitted to use the information only for lawful sales, marketing, and engagement and with the permission of the data subject.
  • confirming and verifying data subject identity or to verify that they are authorised users for security purposes.
  • conducting market research.
  • auditing and record keeping purposes.
  • in connection with legal proceedings.
  • conducting any other reasonable business operation.

Information may also be used for other purposes for which permission is given, if required to by law, or if it is of public interest to disclose such information. Smart Resource Solutions undertakes to only process information that is required and relevant for the purposes set out above. Smart Resource Solutions will not intentionally collect information about children and will only process information about children with the consent of a parent or guardian, or if otherwise required to do so by law.

Smart Resource Solutions does not intend to process any “special personal information” as defined in Data Protection Act 2018, which includes for example political, religious or health-related information, and will only process special personal information with the stakeholders’ consent, or if otherwise allowed to do so in law if for a specific operational reason. Stakeholders may on reasonable grounds object to the processing of information, after which Smart Resource Solutions undertakes not to continue to process, except when required to do so by law.

7. Lawful basis

In respect of the processing of PI as provided for above, Smart Resource Solutions will adhere to all conditions for the lawful processing of PI, based on its desire to provide its data subjects with services in their best interests as well as a legitimate interest of Smart Resource Solutions to achieve its business objectives.

8. Data subjects’ rights

Data subjects have the right to request that Smart Resource Solutions provides them with access to their PI, to rectify or correct their personal information, erase PI, or restrict the processing of PI, including refraining from sharing it or otherwise providing it to any third parties. Data subjects also have the right to raise complaints with the Information Commissioner’s Office (ICO). The afore-going rights may be subject to certain limitations pursuant to applicable law. In order to access any of these rights, they may contact the Information Officer.

9. Period of holding personal information

All companies that fall under Smart Resource Solutions endeavour to provide the most accurate information as possible to their stakeholders, including their data subjects. Smart Resource Solutions seeks to verify the accuracy of its information as frequently as possible and to remove information that it learns to be inaccurate. Thus, Smart Resource Solutions intends to process the information it has about data subjects for as long as it is legally specified or until the data subject gives any instruction to refrain from processing it. In order to instruct any company within Smart Resource Solutions to refrain from collecting and/ or processing their PI, data subjects may contact the Information Officer. Notwithstanding the above, Smart Resource Solutions shall hold PI for such period as may be required in terms of statutes such as the Companies Act and UK Employment laws for the time being.

10. Consent

The supply of PI to any company within Smart Resource Solutions by any of its stakeholders is at the stakeholders’ discretion. By supplying their information, stakeholders are accepting the practices and terms contained in this privacy policy. Smart Resource Solutions will not process stakeholders’ PI without obtaining stakeholders’ consent.

In respect of all marketing activities relating to Smart Resource Solutions’ services and/or products, consent to collect or use PI will be obtained. In respect of other activities, consent to collect or use will be obtained via acknowledgement by the stakeholder concerned, that a company within Smart Resource Solutions is collecting his or her PI. This acknowledgment will be contained in all documents where PI is collected, including any agreements and/or contracts concluded between the relevant company and the stakeholder, where the stakeholder will be specifically requested to sign an acknowledgment of the collection of PI.

If PI is collected through a third party, the third party will be requested to sign a declaration that they comply with Data Protection Act 2018 requirements. Smart Resource Solutions processes and shares stakeholder information internally and will only share PI relating to that stakeholder internally in instances where operationally required or where it is obliged to disclose certain categories of information relating to regulatory, statutory, and legal purposes.

11. Categories of personal information collected and processed

Smart Resource Solutions collects information about data subjects who may be clients or prospective clients. It also collects information on its employees, assignees, candidates, consultants, agents, and suppliers as well as third parties that are part of its scope of operations. In respect of clients and prospective clients, Smart Resource Solutions profiles business organisations and contacts who work for said organisations and it may have some or all of the following categories of personal information on data subjects, historical or current:

  • Name and Surname
  • Identity Number
  • Equity, Gender & Disability Status
  • Contact Details (email, contact numbers)
  • Birth date
  • Position held and responsibilities.
  • Areas of interest in respect of any of Smart Resource Solutions offerings
  • Sales and transaction history
  • Record of services used.
  • Email correspondence and attachments.
  • Organisation details
  • Office address
  • Office contact details
  • Organisation email address
  • Organisation and data subject
  • Social media URL’s
  • Other information that is available in the public domain.

We collect and process personal information to contact data subjects for the purpose of understanding their requirements and delivering services accordingly. Where possible, we will inform data subjects what information they are required to provide to Smart Resource Solutions and what information is optional, as well as the consequences of not providing the said information. Website usage information may be collected using “cookies” which allows Smart Resource Solutions to collect standard internet visitor usage information. See our Cookies Policy.

12. Collecting information and sources of information

The type of information collected varies. Information includes any personal information as defined in Data Protection Act 2018, but is not limited to details such as company information, partner agreements, name, age, ID numbers, registration numbers, addresses and other contact details, previous employment history, educational information, salary information, liabilities, income and payment records, financial information and banking details such as account numbers and biometric details such as fingerprints. Stakeholders’ information in general refers to information submitted to Smart Resource Solutions through:

  • its website: that identifies or relates to an online visitor or customer, whether they are an individual or a business or where job seekers may register via a Smart Resource Solutions Job Portal to join the data base for prospective employment opportunities or to apply for specific jobs that have been advertised;
  • agreements and/or contracts concluded with the Company.
  • Third party sources where allowed to do so in law.
  • Emails.
  • social media.
  • Registers.
  • Employment.
  • other communications sources.

Given that PI can be extracted and/ or obtained from several sources and consolidated into one database or other similar systems of record, it may be difficult or impossible to identify the exact source of one particular piece of information.

13. Information security and safeguarding

Smart Resource Solutions understands the value of information and will take all reasonable steps to protect the information from loss, misuse, or unauthorised access. Smart Resource Solutions are legally obliged to and take responsibility for:

  • Protecting and managing the PI that it holds about its stakeholders.
  • Making use of electronic and computer safeguards, such as firewalls and data encryption, to secure stakeholders’ information.
  • Ensuring physical and electronic access control to its premises; and
  • Only authorising access to information to those employees who require it to fulfil their designated responsibilities.
  • Reviewing their security controls and related processes on a regular basis to ensure that the PI of data subjects remains secure.

14. Access to information

Stakeholders have the right to access information, including certain personal information held by Smart Resource Solutions. Requests for information must be made to hello@smartresourcesolutions.com.