PRIVACY POLICY

Welcome to the IMS People’s privacy notice.

IMS People] respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.

This privacy notice is provided in a layered format so you can click through to the specific areas set out below.

1. IMPORTANT INFORMATION AND WHO WE ARE

2. THE DATA WE COLLECT ABOUT YOU

3. HOW YOUR PERSONAL DATA IS COLLECTED

4. HOW AND WHY WE USE YOUR PERSONAL DATA

5. DISCLOSURES OF YOUR PERSONAL DATA

6. INTERNATIONAL TRANSFERS

7. DATA SECURITY

8. DATA RETENTION

9. YOUR LEGAL RIGHTS

1.  IMPORTANT INFORMATION AND WHO WE ARE

PURPOSE OF THIS PRIVACY NOTICE

This privacy notice aims to give you information on how IMS People collects and processes your personal data through your use of this website, including any data you may provide through this website or that we obtain from third parties.

This website is not intended for children and we do not knowingly collect data relating to children.

It is important that you read this privacy notice together with any other privacy notice that we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.

DATA CONTROLLER

Interactive Manpower Solutions Private Limited (also referred to as “IMS People” “we”, “us” or “our” in this privacy notice), provides outsourced recruitment services to our clients around the world. In most cases, we act as a data processor on behalf of your clients, who are data controllers. As data controllers, they are responsible for notifying you of your rights and you should refer to their privacy policies for information about how they process your data.

However, in some circumstances we may also act as a data controller in respect of your personal data. This Privacy Policy aims to give you information on how we collect and process your personal data, where we act as a data controller.

We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below.

CONTACT DETAILS

Our full details are:

Company Name: Interactive Manpower Solutions Pvt Ltd, trading as IMS People:

Data privacy manager: Pinaz Engineer

Email address: pinaz@imspeople.com

Postal address: 301, President Plaza, Thaltej Cross Road, S.G. Highway, Ahmedabad 380054, Gujarat, India

Telephone number: +91 79 3011 4444

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk) or to your own country’s supervisory authority for data protection. We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

CHANGES TO THE PRIVACY NOTICE AND YOUR DUTY TO INFORM US OF CHANGES

This version was last updated on 8th May, 2018 and historic versions can be obtained by contacting us.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

THIRD-PARTY LINKS

This 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.

2.  THE DATA WE COLLECT ABOUT YOU

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

  • Contact data including name, email address, phone number, organisation
  • Device and browser data, such as IP address, information about your device and browser settings;
  • Marketing and communications data,including your preferences in receiving marketing from us and our third parties and your communication preferences.
  • Employment and educational history data, such as CVs and job titles, qualifications and authorisations.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

Where we collect or process any other categories of personal data (including sensitive personal data) about you that are not listed above, we will send you a separate Privacy Notice regarding the processing of such data by us.

IF YOU FAIL TO PROVIDE PERSONAL DATA
If you fail to provide with personal data when requested, we may not be able to provide you with work-finding or recruitment services.

3.  HOW YOUR PERSONAL DATA IS COLLECTED?

We may collect data about you when you register with us, visit our website, or when we communicate by email, SMS, phone or in person.

We use different methods to collect data from and about you from third parties:

(a) social media platforms, such as LinkedIn and Facebook

(b) analytics providers such as Google based outside the EU;

(c) advertising networks, such as Google based outside the EU;

(d) search information providers, such as Google and Bing based outside the EU;

(e) publicly available sources, such as press releases, company websites, social media networks like LinkedIn or Google Search

(f) Chat Service provider, Zendesk, based outside the EU

4.  HOW AND WHY WE USE YOUR PERSONAL DATA

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

  • Where we need to perform the contract, we are about to enter into or have entered into with you.
  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
  • Where we need to comply with a legal or regulatory obligation.
  • Where you have consented to our doing so.

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.

Document / Personal Data  Why we need it Our lawful ground for processing it 
Name To verify your identity Legal obligation (if applicable).

Contractual obligation (if applicable).

Legitimate interests.

Contact details To communicate with you to notify you about

our services or send newsletters

Legal obligation (if applicable).

Contractual obligation (if applicable).

Legitimate interests.

CV, employment history, qualifications, authorisations To check your suitability for a role or assignment Contractual obligation (if applicable).
Legitimate interests.
Other necessary, relevant personal information To perform our services for you Contractual obligation (if applicable).

Legitimate interests.

IP address, browser and device data To deliver relevant website content and

administer our website

Legitimate interests.
Website Pages visited, Chat Duration,

how many times the visitor has visited the

website, chat start and end time

To deliver relevant website content and administer our website Legitimate interests.
Invoice Number and Billing Address, To record the invoices that you have paid Legitimate interests

MARKETING
We would like to use your contact details to contact you about news and information which we think may be of interest to you. However, we will not contact you with marketing material unless you consent to our doing so.

You may also receive marketing communications from us if you have previously requested information or services from us and you did not opt out of receiving marketing communications from us at the time.

You have the right to unsubscribe at any time, by clicking the link which appears in the email footers of marketing emails.

Call Recording:
We record all telephone calls, for training, quality and security purposes.

THIRD-PARTY MARKETING
We will get your express opt-in consent before we share your personal data with third parties for marketing purposes.

CHANGE OF PURPOSE
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. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

5.  DISCLOSURES OF YOUR PERSONAL DATA

We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.

We may share the personal data in the categories above with our clients, for the purposes of providing work-finding and recruitment services.

Your personal information will be processed by our internal staff and subcontractors (including IT providers).

We may be required by law to share certain categories of your personal data with tax authorities and other government agencies.

We may also need to share your data with our professional advisers, such as lawyers and accountants.

We may also share your personal data with 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 will not share your personal data with any other organisation unless it is necessary and in connection with providing our work-finding and recruitment services.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. 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.

6.  INTERNATIONAL TRANSFERS

Your personal data will primarily be stored in India, which is outside the European Economic Area (EEA) on either local or cloud-based servers. We may also have access to the personal data of candidates held by our hirer clients, both within the EEA and outside it. We will take all reasonable steps to ensure that your data is subject to the same protection as that provided by the EU and that it is subject to technical and organisation safeguarding protection measures as provided by the EU. The EEA comprises the EU member states plus Norway, Iceland and Liechtenstein.

Some categories of data may be transferred to our hirer clients in other countries outside the EEA. We will take all reasonable steps to ensure that your data is subject to the same protection as that provided by the EU and will only transfer your personal data to organisations located in countries outside the EEA, if the organisation:

  • is based in a country which has been deemed to provide an adequate level of protection for personal data by the European Commission, or
  • has entered into an agreement with us which contains specific contract clauses approved by the European Commission which give personal data the same protection that it has in Europe.

For further details, please see the following:
European Commission: Adequacy of the protection of personal data in non-EU countries
European Commission: Model contracts for the transfer of personal data to third countries
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

7.  DATA SECURITY

We are ISO 27001 certified and have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We will only transfer personal data to a third party if they agree to comply with those procedures and policies, or put in place adequate measures prior to receiving it. Maintaining data security means guaranteeing the confidentiality, integrity and availability (for authorised purposes) of the personal data.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

8.  DATA RETENTION

FOR HOW LONG WILL YOU USE OR RETAIN MY PERSONAL DATA?

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

By law we have to keep certain information about candidates for 8 years. Where we have entered into a contract with you, we may also need to retain data for up to 8 years in order to ensure that we can meet our contractual obligations to you.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

9.  YOUR LEGAL RIGHTS

Under certain circumstances, you have rights under data protection laws in relation to your personal data. These include the right to:

  1. request access to personal data we hold about you;
  2. object to the processing of your personal data;
  3. ask to have inaccurate data held about you removed or restricted;
  4. ask to have inaccurate data held about you or corrected;
  5. if processing of your personal data is based only on consent, to withdraw that consent;
  6. request that your personal data is shared with a third party in a commonly used, machine readable format.

If you wish to exercise any of the rights set out above, please contact us at pinaz@imspeople.com

NO FEE USUALLY REQUIRED

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a fee if requests are repeated or obviously excessive.