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Data Privacy Policy And Notice

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Data Privacy Policy And Notice

Privacy Statement of Limited

Under the Data Protection legislation, Limited (hereafter “Fortray”) must comply with certain regulations designed to ensure that any data provide is processed with proper care and attention – but in any event Limited (‘Fortray’) is committed to safeguarding the privacy of Users (defined below) of Fortray’s site (the ‘Site’) and the following explains the information gathering and dissemination practices of Fortray relating to the Site.

In this Privacy Policy, a ‘User’ is one who uses the Site and who registers their details with Fortray for the purposes of recruitment, which can be either the gaining of employment or the recruiting of staff (and the masculine includes the feminine, the singular the plural and vice versa).

Except as permitted by this Privacy Policy, Fortray will not share a User’s information with third parties without the User’s prior consent.

Where the Site contains links to third-party sites, this Privacy Policy does not apply to such sites.

Data Collected by Fortray

Fortray collects personal data for the purpose of assisting in the recruitment process. This data consists of information as follows (which list may not be exclusive) where appropriate: the User’s name, address, e-mail address, telephone number, date of birth, sex, nationality (which item of information Fortray is required by law to collect), current remuneration level, education history, work history and all other details comprising a User’s curriculum vitae (‘CV’) as submitted by the User, details of available jobs, plus the User’s responses to assessments administered through the Site and the results of such assessments. Additionally, Fortray collects personal information from Users via enquiry and registration forms and also on each occasion that Users e-mail details to Fortray.

Supplementary information relevant to the recruitment service which Fortray provides may also be collected by Fortray, including a record of any contact Fortray may have with candidates in the course of recruitment assignments and details of reference checks, education verification and other recruitment-related research which Fortray may effect.

In addition, Fortray may collect information automatically (which information could include demographic data, geographic trends and browsing patterns) in order to assist strategic development, to audit usage of the Site and generally to provide Fortray with an enhanced understanding of the Users of the Site as a group. Such information would only be used in aggregate form and would not contain information of a personally identifiable nature.


By a User’s use of this website and by his registration of his details with Fortray, the User agrees to the terms and conditions of this Privacy Policy and Data Privacy Notice, and at the time of registering, consents to:

a. Fortray’s collection of and processing of sensitive/personal data supplied by the User; and

b. Fortray’s transfer of this information to potential employers/candidates in relation to the process of recruitment.

Before releasing a User’s personal data to potential employers, or candidates, or to any other third parties, Fortray will first require them to agree to use the User’s personal data only in accordance with this Privacy Policy.

Third Parties

Where necessary, Fortray will pass to prospective or intended employers or candidates for the purpose of recruitment. In addition, Fortray may share aggregate information with selected third parties, though in this event Fortray will disclose neither individual names nor any identifying information. Further details are set out in Fortray’s Data Privacy Notice below.

Safeguarding of Data

Fortray complies with the Data Protection legislation. Personal data will only be made available to the staff of Fortray and to those third parties who help Fortray to process data and (in order to assist the process of recruitment) to prospective employers or candidates.

‘Cookies’ and Their Use

‘Cookies’, small items of personal information stored by one’s browser on the hard drive of one’s computer, used to store and track information, allow the server to take back information from the browser. The list of Cookies can we found here

Generally (but not necessarily exclusively) Fortray uses Cookies on the Site for the following purposes:

a. to save the User’s User ID and Password;

b. to allow easy access to the Site (by alerting Fortray as to who the User is) and to access the User’s member information (stored on Fortray’s computers) in order to offer a service which strives constantly to be improved and become ever more personalised;

c. Fortray collects Internet Protocol (“IP”) addresses, which may be used to send to Users the employment recommendations relevant to them; and

d. to record searches Users have made during visits to the Site;

If a User selects the “Save User ID & Password” option, he thereby informs Fortray that Fortray should always assume that the User is the person logging onto his computer. Therefore, if the User’s computer is shared with other people, Fortray recommends that when the User signs out of his account he selects the ‘Don’t remember my details’ option. By so doing, the User will remove all details from the Cookie.

Accessing, Correcting, or Removing your Data

Users have rights with regard to the personal data Fortray holds about them, as set out in Fortray’s Data Privacy Notice.

Where the disclosing of an item of information would interfere with the privacy rights of another person or where it would breach confidentiality attaching to that item of information, Fortray will withhold access from certain portions of the User’s database record.

If a User wishes to exercise his right of access to his personal information, or if he wishes to make further inquiries or complaints about the Privacy Policy and Data Privacy Notice of Fortray, he should refer to the process set out in the Data Privacy Notice below. In the event that a User wishes access to his personal information, he will require to verify his identity to Fortray. Fortray will not charge the User for providing access. It is understood that the processing of an application for access may take up to 30 days.

Changes to Fortray’s Privacy Policy

In the event that Fortray makes privacy policy changes (whether for business reasons or because of legislative changes) such alterations will be posted on these Privacy Policy and Data Privacy Notice pages and may also be announced via the Site.

How we used Cookies

Cookies are small text files that are placed on your web browser by websites that you visit.

We use a few to make some features work and to let us know what’s working and what’s not so we can continuously improve our service.

In addition to 3rd party cookies that can be found here the Cookies on this site include:

  1. CAKEPHP – CakePHP session cookie (i.e. identify who you are logged in as and who you are)
  2. CakeCookie[Auth][User] – Set when the user chooses to “Remember Me” when logging in
  3. __utma – Google Analytics (website features & measurement)
  4. __utmb – Google Analytics (website features & measurement)
  5. __utmc – Google Analytics (website features & measurement)
  6. __utmz – Google Analytics (website features & measurement)

Your consent for us to use cookies

As cookies are essential for provision of high quality service by this site, users can enable cookies and provide their consent for us to use them before they register or log in, or start using any service provided, to get the full benefit of the service. You can block or delete existing cookies through your web browser settings, but this will restrict the functions that you are able to carry out on this site. By continued use of this site you are agreeing to Fortray’s use of the above Cookies.


To receive more information or to opt out of Google Ads cookies please visit Google Ads settings page

Google Analytics is a tool that helps us understand how our visitors engage with our website. It may store into cookies information such as time of your visit, whether you have been to this site before and what site referred you to the current web page. For more information on their privacy policy or to opt out from their cookies please visit Google Analytics privacy page.

Data Privacy Notice

We are LIMITED with registered number 05627376 and address Dairy House Money Row Green SL6 2ND. Our Data Protection Officer can be contacted at We have produced this privacy notice in order to keep you informed of how we handle your personal data. All handling of your personal data is done in compliance with the General Data Protection Regulation (EU) 2016/679 (“Data Protection Legislation”). The terms “Personal Data”, “Special Categories of Personal Data”, “Personal Data Breach”, “Data Protection Officer”, “Data Controller”, “Data Processor”, “Data Subject” and “process” (in the context of usage of Personal Data) shall have the meanings given to them in the Data Protection Legislation.

What are your rights?

When reading this notice, it might be helpful to understand that your rights arising under Data Protection Legislation include:

  1. The right to be informed of how your Personal Data is used (through this notice);
  2. The right to access any personal data held about you;
  3. The right to rectify any inaccurate or incomplete personal data held about you;
  4. The right to erasure where it cannot be justified that the information held satisfies any of the criteria outlined in this policy;
  5. The right to prevent processing for direct marketing purposes, scientific/historical research or in any such way that is likely to cause substantial damage to you or another, including through profile building; and
  6. The right to object to processing that results in decisions being made about you by automated processes, and prevent those decisions being enacted.

You can exercise your right to access personal data held about you by emailing with the subject line: “Subject Access Request”. When you submit a ‘subject access request’, you will need to provide confirmation of your identity by contacting us using the email address associated with your profile, or attaching a photocopy of your driver’s license or passport. Our response is provided free of charge and will be made within thirty (30) days, unless our Data Protection Officer deems your request as being excessive or unfounded. If this is the case, we will inform you of our reasonable administration costs in advance and/or any associated delays, giving you the opportunity to choose whether you would like to pursue your request. If you believe we have made a mistake in evaluating your request, please see the section ‘Who can you complain to?’.

If you have questions about any of the rights mentioned in this section, please contact our Data Protection Officer at

Who is the Data Controller?

  1. If we have collected your personal data directly from you for our own purposes, we are the Data Controller.
  2. If we have purchased your personal data from a third-party for our own purposes, we are the Data Controller. Where we have purchased your personal data, we will contact you to let you know before we first start to use it, or, at the latest, within thirty (30) days of acquiring it.
  3. If we have been passed your personal data from a third-party for our own purposes, we are the Data Controller. You should be notified directly by the job board/CV search provider when they have passed your personal data to us. We will notify you before using your personal data – or, at the latest, within thirty (30) days – where we have obtained your data from and for what purpose.
  4. If we have received your personal data as part of a direct administrative relationship between our business and yours, the Data Controller is your employer for that purpose.

What are the lawful bases for processing personal data?

Under Data Protection Legislation, there must be a ‘lawful basis’ for the use of personal data. The lawful bases are outlined in Article 6, Section 1 of the GDPR under the following sub-sections:

  1. ‘your consent’;
  2. ‘performance of a contract’;
  3. ‘compliance with a legal obligation’;
  4. ‘protection of your, or another’s vital interests’;
  5. ‘public interest/official authority’; and
  6. ‘our legitimate interests’.

What are LIMITED’s ‘legitimate interests’?

Legitimate interests are a flexible basis upon which the law permits the processing of an individual’s personal data. To determine whether we have a legitimate interest in processing your data, we balance the needs and benefits to us against the risks and benefits for you of us processing your data. This balancing is performed as objectively as possible by our Data Protection Officer. You are able to object to our processing and we shall consider the extent to which this affects whether we have a legitimate interest. If you would like to find out more about our legitimate interests, please contact

About our processing of your data

We might collect, use, store and transfer different kinds of Personal Data about you. This may be information you provide to us, information we collect about you, or information we receive from other sources, which we have grouped together as follows:

Identity Data such as names, usernames or similar; marital status; title; date of birth; sex and gender.

Contact Data such as addresses; email addresses and telephone numbers.

Profile Data such as usernames; passwords; security answers; purchases/orders; interests; preferences; feedback and responses to surveys, blogs and messages.

Transaction Data such as information about your dealings with us, including applications for vacancies, submission of candidates for vacancies, messages between us, CV-related communications and advice, and any payments you have made. (Payments relate only to companies and not candidates/job-seekers).

Technical Data such as IP addresses; login data; browser info; time zone; location; browser plug-ins; operating systems; platforms and other technology on the device used to access this website.

Company Financial Data such as bank account and payment card information. Usage Data such as analytics relating to how you use the website.

Marketing and Communications Data such as your preferences about receiving communications from us.

We also collect, use and share Aggregated Data such as statistical or demographic data. Aggregated Data can be derived from your Personal Data but is not itself Personal Data as it cannot be used to reveal your identity. If Aggregated Data is ever used in combination with your Personal Data and becomes identifiable, it will be treated in accordance with this notice. LIMITED does not collect any Special Categories of Personal Data about you or any information about criminal convictions/offences unless you voluntarily share such information.

Candidate Communications, Application Submission and CV Management

What categories of information about you do we process?

Identity Data, Contact Data, Profile Data, Transaction Data, Technical Data, Usage Data

Why are we processing this data?

To communicate with candidates regarding a vacancy / vacancies. This processing is conducted lawfully on the basis of ‘our legitimate interests’.

To fulfil a candidate’s request to apply for and be considered for a vacancy. This processing is conducted lawfully on the basis of ‘our legitimate interests’.

To inform clients of candidates who are suitable for a vacancy. This processing is conducted lawfully on the basis of ‘our legitimate interests’.

Where did we get your personal data from?

Directly obtained from you or from job boards and CV search providers.

Ad-Hoc Responses

What categories of information about you do we process?

Identity Data, Contact Data, Technical Data, Usage Data

Why are we processing this data?

To answer queries submitted through the website, through email or from a phone call. This processing is conducted lawfully on the basis of ‘our legitimate interests’.

Where did we get your personal data from?

Directly obtained.

Client Communications

What categories of information about you do we process?

Identity Data, Contact Data, Profile Data, Transaction Data, Technical Data, Usage Data

Why are we processing this data?

To communicate with clients in the performance of’s services. This processing is conducted lawfully on the basis of ‘performance of a contract’.

Where did we get your personal data from?

Directly obtained.

Fee Protection

What categories of information about you do we process?

Identity Data, Contact Data, Profile Data, Transaction Data, Technical Data, Company Financial Data, Usage Data.

B2B Marketing

What categories of information about you do we process?

Identity Data, Contact Data, Profile Data, Usage Data, Marketing and Communications Data

Why are we processing this data?

Direct email marketing to clients. This processing is conducted lawfully on the basis of ‘our legitimate interests’.

Where did we get your personal data from?

Directly obtained.

Supplier management

What categories of information about you do we process?

Identity Data, Contact Data, Company Financial Data

Why are we processing this data?

To engage and manage suppliers/contractors in their performance of services to This processing is conducted lawfully on the basis of ‘performance of a contract’.

Where did we get your personal data from?

Directly obtained.

What happens if I refuse to give LIMITED my personal data?

The information about you that we have collected for the performance of our contracts is required in order for us to successfully fulfil our obligations to you. If you choose not to provide the personal data requested, we will not be able to provide the services we offer.

If your personal data is used for ‘Application Submission and CV Management’, your personal information will, in part, be retained as part of a statutory obligation arising under Code of Conduct (Agency) Regulations 2003. Failure to process your data could result in us being unable to fulfil your orders.

What profiling or automated decision making does LIMITED perform?

RECRUITMENT REVOLUTION.COM LIMITED does not perform any profiling or automated decision making based on your personal data.

How long will your personal data be kept?

All categories of personal data that are held by us because they are essential for the performance of a contract, will be held for a period of six years, as determined by reference to the Limitations Act 1980, for the purposes of exercising or defending legal claims. This includes candidate data processed on the basis of ‘legitimate interests’ where it relates to a contract with a client.

Who else will receive your personal data? LIMITED may share your personal information with third parties that facilitate the provision of our service to you, including our Software and other IT Suppliers. Your data will never be shared with third parties for marketing purposes.

If you are a candidate applying for a vacancy, we shall pass your personal information to the relevant client or hiring company (third party). Upon receipt of your personal information, the relevant third party is a joint Data Controller and their use of your information will be governed by their own terms of use and privacy policy.

Our Data Processors including business partners, suppliers and subcontractors will receive your personal data for the performance of any contract we enter into with them or you. Your information accessed by analytics and search engine providers that assist us in the improvement and optimisation of our website, however this is generally shared in a form that does not directly identify you.

In very rare circumstances, personal data may be shared if required in order to obtain professional advice. We will inform you independently and in advance if we believe that disclosure of your personal data is essential to this process.

If we are under a duty to disclose or share your personal information in order to comply with any legal obligation, or in order to enforce or apply our terms of business; or to protect the rights, property, or safety of, our customers, or others, we will let you know, unless prevented by law. This includes exchanging information with other companies and organisations for the purposes of fraud protection.

The information that we collect from you may be transferred to, and stored, in a country outside the European Economic Area (“EEA”). It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers. We only send your data outside the EEA where we have in place a legal agreement which complies with relevant legislation. By submitting your information, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely (e.g. the encryption of data) and in accordance with this privacy policy.

Fortray uses an online chat facility powered by Melu Ltd to deal with your questions quickly 7 days a week. A copy of their data policy can be found here

Who can you complain to?

In addition to sending us your complaints directly to, you can send complaints to our supervisory authority. As LIMITED predominantly handles the personal data of UK nationals, our supervisory authority is the Information Commissioner’s Office. If you believe that we have failed in our compliance with data protection legislation, complaints to this authority can be made by visiting