(A) This Policy
This Policy is provided by Rockpools Global
Resourcing & Consulting Limited (“Rockpools”, “we” or “us”),
and is addressed to individuals outside our organisation with whom we interact,
including (but not limited to) Candidates, Participants, Sources and visitors
to our websites (together, “you”). Defined terms used in this Policy are
explained further in Section (N) below.
For the purposes of this Policy, Rockpools is
the Controller. Contact details are provided in Section (M) below.
Please note that this Policy does not apply to
the Processing by Rockpools of the Personal Data of Rockpools
employees, contractors, secondees, temporary workers or other staff in connection
with the roles they perform for Rockpools. A separate privacy internal policy
governs such Processing.
This Policy may be amended or updated from time
to time to reflect changes in our practices with respect to the Processing of
Personal Data, or changes in applicable law. We encourage you to read this
Policy carefully, and to regularly check this page to review any changes we
might make in accordance with the terms of this Policy. We will notify you of
any significant changes.
(B) Processing your Personal Data
Collection of Personal Data:
We may collect Personal Data about you, such as
your name, address and contact details. Examples of sources from which we may
collect Personal Data include the following:
- We may obtain your Personal Data when you provide
it to us (e.g., where you contact us via email or telephone, or by any other
- We may collect your Personal Data in the ordinary
course of our relationship with you (e.g., if we offer to connect you with our
Clients we may collect your Personal Data that are related to such Client
opportunities, such as your résumé).
- We may receive your Personal Data from other
entities within our corporate group, to the extent that they provide it to us.
- We may collect Personal Data that you manifestly choose
to make public, including via social media (e.g., we may collect information
from your social media profile(s), to the extent that you choose to make your
profile publicly visible).
- We may receive your Personal Data from third
parties who provide it to us (e.g., past employers; referees; and law
- We may, with your prior express written consent,
conduct background checks, in accordance with the protections provided by
- We may collect or obtain Personal Data when you visit
our Rockpools website (a “Site”) or use any features or resources
available on or through a Site. When you visit a Site, your device and browser
will automatically disclose certain information (such as device type, operating
system, browser type, browser settings, IP address, language settings, dates
and times of connecting to a Site and other technical communications
information), some of which may constitute Personal Data.
Creation of Personal Data:
- We may also create Personal Data about you, such as
records of any interviews you attend. This Personal Data helps us to conduct
our operations and manage our workforce.
Personal Data you provide about others:
- In some circumstances, you may provide us with
Personal Data about others. For example, you might act as a Source and provide
comments on a Candidate or Participant. Whenever you provide any such Personal
Data, we rely on you to ensure that you have a lawful basis for providing such
Personal Data to us, and that you have complied with applicable law and with
the terms of this Policy. If you are unable to do so, please refrain from
providing the Personal Data of third parties to us.
Relevant Personal Data: The categories
of Personal Data about you that we may Process include:
- Personal details: given name(s);
preferred name; gender; date of birth / age; nationality; photograph; marital
status; job title; employer entity; department; salary and compensation
details; passport number (where applicable); visa number (where applicable);
and work authorisation number (where applicable).
- Contact details: home address;
work address; home telephone number; work telephone number; work mobile number;
personal mobile telephone number; personal email address; work email address;
and social media profile details.
- Employment records: dates and details of current
and former positions held; details of current and former employers; dates of
employment; job titles; job locations; subject matter experience; and details
of any employment disciplinary issues or incidents.
- Details of referees: details of referees you may
provide, including the relationship that you may have with each such referee,
and the duration for which you have known each such referee.
- Background checks: details revealed by
background checks conducted in accordance with applicable law and subject to
your prior express written consent, including details of past employments,
details of residence, credit reference information, and criminal records
- Views and opinions: your views on Candidates or
Participants, where applicable.
Lawful basis for Processing Personal Data: In Processing
your Personal Data in connection with the purposes set out in this Policy, we
may rely on one or more of the following legal bases:
- we have obtained your prior express consent to the
Processing (this legal basis is only used in relation to Processing that is
entirely voluntary – it is not used for Processing that is necessary or
obligatory in any way);
- the Processing is necessary in connection with any
contract that you may enter into with us;
- the Processing is required by applicable law;
- the Processing is necessary to protect the vital
interests of any individual; or
- we have a legitimate interest in carrying out the
Processing, which is not overridden by your interests, fundamental rights, or
freedoms. Where we rely on this legal basis, our legitimate interests are:
- our legitimate interest in the management and
operation of our business;
- our legitimate interest in the promotion of our
- our legitimate interest in the provision of
services to our Clients.
Processing your Sensitive Personal Data: We do not seek
to collect or otherwise Process your Sensitive Personal Data, except where:
- the Processing is required or permitted by
applicable law (e.g., to comply with our diversity reporting obligations);
- the Processing is necessary for the detection or
prevention of crime;
- the Processing is necessary for the establishment,
exercise or defence of legal rights; or
- we have, in accordance with applicable law,
obtained your prior explicit consent before Processing your Sensitive Personal
Data (as above, this legal basis is only used in relation to Processing that is
entirely voluntary – it is not used for Processing that is necessary or
obligatory in any way).
Purposes for which we may Process your Personal
Data: The purposes for
which we may Process Personal Data, subject to applicable law, include:
- Recruitment activities on behalf of Clients: recruitment
operations; advertising Client opportunities; providing services to our
Clients; enabling Clients to understand which Candidates are interested in
their opportunities; record-keeping; and performing background checks.
- Leadership consulting: providing
leadership consulting services to Clients.
- Provision of services to you: providing our
Sites and other services to you; attending meetings with you; attending
telephone calls with you; and otherwise communicating with you in relation to
- Our Sites: operating and managing our
Sites; providing content to you; displaying advertising and other information
to you; and communicating and interacting with you via our Sites.
- Training: providing you with training
and preparation for interviews.
- Newsletters and other marketing communications: communicating
with you via any means (including via email, telephone, text message, social
media, post or in person) news items and possible opportunities in which you
may be interested.
- Communications and IT operations: management of
our communications systems; operation of IT security; and IT security audits.
- Health and safety: health and safety assessments
and record keeping; and compliance with related legal obligations.
- Financial management: sales; finance;
corporate audit; and vendor management.
- Surveys: engaging with you for the
purposes of obtaining your views on relevant issues and topics.
- Improving our services: identifying
issues with existing services; planning improvements to existing services;
creating new services.
- Future planning: succession and organizational
planning, including budgeting.
(C) Disclosure of Personal Data to
We may disclose your Personal Data to other
entities within our corporate group, for legitimate business purposes
(including providing services to you and operating our Sites), in accordance
with applicable law.
We may also share aggregate demographic
information with our Clients, trusted affiliates and advertisers for the
purposes outlined in this Policy. While we make all reasonable efforts to
ensure that such information is anonymized, it is possible that small amounts
of your Personal Data may be included.
In addition, we may disclose your Personal Data
- legal and regulatory authorities, upon request, or
for the purposes of reporting any actual or suspected breach of applicable law
- our Clients, for the purposes of providing services
to those Clients, in accordance with the provisions of this Policy;
- accountants, auditors, lawyers and other outside
professional advisors, subject to binding contractual obligations of
- third party Processors (such as providers of
background checking services), located anywhere in the world, subject to the
requirements noted below in this Section (C);
- any relevant party, law enforcement agency or
court, to the extent necessary for the establishment, exercise or defence of
- any relevant party for the purposes of prevention,
investigation, detection or prosecution of criminal offences or the execution
of criminal penalties, including the safeguarding against and the prevention of
threats to public security;
- any relevant third party acquirer(s), in the event
that we sell or transfer all or any portion of our business or assets
(including in the event of a reorganization, dissolution or liquidation); and
- our Sites may use third party plugins or content
(e.g., Facebook, Twitter, Google+ and LinkedIn). If you choose to interact with
any such plugins or content, your Personal Data may be shared with the relevant
If we engage a third-party Processor to Process
your Personal Data, the Processor will be subject to binding contractual
obligations to: (i) only Process the Personal Data in accordance with our prior
written instructions; and (ii) use measures to protect the confidentiality and
security of the Personal Data.
(D) International transfer of
Your Personal Information may be stored and/or processed in
countries that do not provide the same level of protection for Personal
Information as the data protection laws of your home country. We take
appropriate steps, where required, to provide appropriate safeguards for
Personal Information to be transferred, including, among others and as
applicable, standard data protection clauses adopted or approved by the European
Commission together with binding and enforceable commitments. Where required by
law, you can request a copy of such safeguards by contacting us as detailed
(E) Data Security
We have implemented appropriate technical and
organisational security measures designed to protect your Personal Data against
accidental or unlawful destruction, loss, alteration, unauthorised disclosure,
unauthorised access, and other unlawful or unauthorised forms of Processing, in
accordance with applicable law. However, no system can be 100% secure, and
so we cannot be held responsible for unauthorised or unintended access that is
beyond our reasonable control.
You are responsible for ensuring that any
Personal Data that you send to us are sent securely.
(F) Data Accuracy
- Your Personal Data that we Process will be kept
accurate and, where necessary, kept up to date. We take every reasonable step
to ensure that:
- From time to time we may ask you to confirm the
accuracy of your Personal Data.
Personal Data that we Process are accurate and, where necessary, kept up
to date; and any of your Personal Data that we Process that are inaccurate
(having regard to the purposes for which they are Processed) are erased or
rectified without delay.
(G) Data Minimisation
We take every reasonable step to ensure that
your Personal Data that we Process are limited to the Personal Data reasonably
required in connection with the purposes set out in this Policy.
(H) Data Retention
We will keep copies of your Personal Data in a
form that permits identification only for as long as is necessary in connection
with the purposes set out in this Policy, unless applicable law permits or requires
a longer retention period.
The criteria for determining the duration for
which we will keep your Personal data are as follows: we will retain your
Personal Data for as long as we have your permission to contact you. Should you
wish to withdraw that permission, you may do so using the contact details
provided in Section (M) below.
(I) Your legal rights
Subject to applicable law, you may have a number
of rights regarding the Processing of your Personal Data, including:
- the right to request access to, or copies of, your
Personal Data that we Process or control;
- the right to request rectification of any
inaccuracies in your Personal Data;
- the right to request, on legitimate grounds:
- erasure of your Personal Data that we Process or
- restriction of Processing of your Personal Data
that we Process or control;
- the right to object, on legitimate grounds, to the
Processing of your Personal Data;
- the right to have your Personal Data transferred to
another Controller, to the extent applicable;
- where we Process your Personal Data on the basis of
your consent, the right to withdraw that consent; and
- the right to lodge complaints regarding the
Processing of your Personal Data with a Data Protection Authority.
This does not affect your statutory rights.
To exercise one or more of these rights, or to
ask a question about these rights or any other provision of this Policy, or
about our Processing of your Personal Data, please use the contact details
provided in Section (M) below.
A cookie is a small file that is placed on your
device when you visit a website (including our Sites). It records information
about your device, your browser and, in some cases, your preferences and
browsing habits. We may Process your Personal Data through cookie technology,
in accordance with our Cookies Policy.
All use of our Sites is subject to our Legal Disclaimer.
(L) Your obligations
If, and to the extent that, you are a Candidate
or Participant, we rely on you to provide us with complete and accurate
Personal Data about you, so that we can provide appropriate services to you and
to our Clients.
If, and to the extent that, you are a Source, we
rely on you to ensure that you are lawfully able to disclose Personal Data to
us, as set out in this Policy.
(M) Contact details
If you have any comments, questions or concerns about
any of the information in this Policy, or any other issues relating to the
Processing of Personal Data by Rockpools, please contact:
Data Controller (please insert in email
- ‘Candidate’ means a candidate, or potential candidate, for a position with a
- ‘Client’ means a client of Rockpools Global Resourcing & Consulting
- ‘Controller’ means the entity that decides how and why Personal Data is
Processed. In many jurisdictions, the Controller has primary
responsibility for complying with applicable data protection laws.
- ‘Data Protection
Authority’ means an independent
public authority that is legally tasked with overseeing compliance with
applicable data protection laws.
- ‘Leadership Assessment’
means any leadership assessment service (including, but not limited to,
any management audit, leadership consulting service, coaching, team
development, team effectiveness analysis, or succession planning) provided
to a Client for the purposes of assessing the leadership potential of its
own Personnel or other individuals selected by the Client.
means any individual participating in a Leadership Assessment.
- ‘Personal Data’ means information that is about any individual, or from which any
individual is identifiable. Examples of Personal Data that we may Process
are provided in Section (B) above.
- ‘Personnel’ means
any current, former or prospective employee, consultant, temporary worker,
intern, other non-permanent employee, contractor, secondee or other
- ‘Process’, ‘Processing’ or ‘Processed’ means anything that is
done with any Personal Data, whether or not by automated means, such as
collection, recording, organisation, structuring, storage, adaptation or
alteration, retrieval, consultation, use, disclosure by transmission,
dissemination or otherwise making available, alignment or combination, restriction,
erasure or destruction.
- ‘Processor’ means any person or entity that Processes Personal Data on behalf
of the Controller (other than employees of the Controller).
- ‘Sensitive Personal Data’ means Personal Data about race or ethnicity, political opinions,
religious or philosophical beliefs, trade union membership, physical or
mental health, sexual life, any actual or alleged criminal offences or
penalties, national identification number, or any other information that
may be deemed to be sensitive under applicable law.
- ‘Source’ means any person that provides any view or opinion regarding the
qualities of any Candidate or Participant, for any purpose, including but
not limited to the suitability of a Candidate or Participant for a
by applicable law, you can contact your local data protection authority with
This website and its content are provided as is
and excludes to the fullest extent permitted by applicable law any warranty,
express or implied, including, without limitation, any implied warranties of
merchantability, satisfactory quality or fitness for a particular purpose.
The functions embodied on, or in the materials
of, this website are not warranted to be uninterrupted or without error. You,
not Rockpools, assume the entire cost of all necessary servicing, repair or
correction due to your use of this website.
Except as specifically stated in our privacy
policy, or elsewhere on this website, or as otherwise required by applicable
law, neither Rockpools, nor its affiliates or other representatives will be
liable for damages of any kind arising out of your use of, your inability to
use, or the performance of this website or the Content whether or not we have
been advised of the possibility of such damages.
We take all reasonable steps to ensure the
accuracy, correctness and reliability of the content, but we make no
representations or warranties as to the accuracy, correctness or reliability of
This website may contain links to other
websites; we are not responsible for any content contained on these websites or
any loss suffered by you in relation to your use of such websites. You waive
any and all claims against Rockpools regarding the inclusion of links to other
websites or your use of those web sites.
Anti-Slavery and Human Trafficking Policy
Rockpools recognise that modern slavery is an international crime and violation of human rights. Its victims are deprived of liberty, via forced and compulsory labour and exploited for personal or commercial gain.
Our purpose is to help shape a better society and we are clear of the important role we play in respecting individuals, promoting fairness and transparency and embedding these principles into the fabric of our culture. We work collaboratively with suppliers and ensure only those who meet our quality and ethical standards form part of our supply chain. Compliance with the Modern Slavery Act 2015 (MSA) and all related good employment practices is a core requirement.
We use the documentation to communicate our policies:
- This Anti – slavery document
- Induction and Training materials to highlight and reinforce our agreed operational and vetting procedures
- Minimum standards agreement form, ensuring all new suppliers confirm compliance with MSA
We have a clear protocol in place vetting candidates we place. The details of specific checks are detailed below:
- Registration of full personal details
- Right to work in the UK
- Face to face interview
- Reference Check – Two references covering the last two employers or assignments
We use a limited range of suppliers and have undertaken a risk assessment to determine whether we or our suppliers are at risk of modern slavery. We have concluded that the risk is low. Before entering into any supplier relationships, we conduct a vetting procedure, which includes reviewing their MSA policies and practices.
We raise awareness amongst all of our staff of the risks of modern slavery through our induction process for new joiners and an annual reminder to all staff.
Responsibility and compliance
The Board of Rockpools has overall responsibility for ensuring that this policy is embedded and complies with our legal and ethical obligations. The Managing Director has responsibility in ensuring that it is implemented as part of our day to day operations.