MBN Recruitment Solutions Limited (“MBN Solutions”) is committed to protecting the confidentiality of information and privacy of our candidates, clients and other users of our websites and services.
This Policy applies to the processing of any and all personal data which is collected by MBN Solutions in relation to your use of our Website or in relation to any services which we may provide to you.
Data Protection Legislation
All organisations that process personal data are required to comply with data protection legislation. Even though the UK left the EU, the GDPR which gives individuals (known as 'data subjects') certain rights over their personal data whilst imposing certain obligations on the organisations that process their data is still applicable in the UK.
MBN Solution is committed to protecting the privacy of our candidates under all applicable data protection legislation, including, but not limited to:
- Data Protection Act 2018;
- The General Data Protection Regulation (EU) 2016/679;
- The Privacy and Electronic Communications (EC Directive) Regulations 2003 (as may be amended by the proposed Regulation on Privacy and Electronic Communications); and
- any legislation that replaces or converts into United Kingdom law, UK GDPR, the General Data Protection Regulation (EU) 2016/679, the proposed Regulation on Privacy and Electronic Communications or any other law relating to data protection, and the processing of personal data and privacy resulting from the United Kingdom leaving the European Union.
The Regulation aims to harmonise data protection legislation across the UK and EU member states, enhancing privacy rights for individuals and providing a strict framework within which commercial organisations can legally operate.
Who We Are And How To Contact Us
MBN Solutions is registered in the UK and is registered with the Information Commissioner's Office. You can contact us at 112 West George Street, Glasgow G2 1PN, or by email at email@example.com
Our Article 27 Representative
Under Article 27 of the GDPR, we have appointed an EU Representative to act as our data protection agent. Our nominated EU Representative is:
Instant EU GDPR Representative Ltd
Adam Brogden firstname.lastname@example.org
Tel +353 15 549 700
INSTANT EU GDPR REPRESENTATIVE LTD
12A Lower Main Street, Lucan Co. Dublin
Throughout this policy the following terms have the following meanings:
- 'consent' means any freely given, specific, informed and unambiguous indication of an individual's wishes, by a statement or by a clear affirmative action, that signifies agreement to the processing of personal data relating to him or her;
- 'data controller' means an individual or organisation which, alone or jointly with others, determines the purposes and means of the processing of personal data;
- 'data processor' means an individual or organisation which processes personal data on behalf of the data controller;
- 'personal data' means any information relating to an individual who can be identified, such as a name, an identification number, location data or an online identifier;
- 'personal data breach' means a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data;
- 'processing' means any operation or set of operations performed on personal data, such as collection, recording, organisation, structuring, storage (including archiving), adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction;
- 'profiling' means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to an individual, in particular to analyse or predict aspects concerning that natural person's performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements.
Collection of Personal Data
When you use or register with https://mbnsolutions.com/, we may ask for certain personal data. The categories of Personal data we may request include your name and contact information (email, address, phone number or CV). Depending on the nature of your enquiry or activities on the website, we may also ask for your job search criteria and preferences, your employment experience, salary, educational history, your skills, references information, background information, expectations and other information contained in your CV.
For candidates who have previously been registered with or worked for MBN Solution, should any of your Personal data change, you should inform MBN Solutions without delay.
We use personal data and other data collected through the website to register you with the website, to provide you with information regarding employment opportunities and career-related information, and to otherwise provide you with requested information or services. MBN Solutions will process your personal data for contract or permanent recruitment requirements and for the purpose of producing statistics and complying with GDPR regulations.
Information about your health and/or court/criminal record is only processed if it is relevant to any registration you may make and this information will only be processed in accordance with the restrictions imposed by law. If you provide MBN Solutions with information about third parties, MBN Solutions will assume that the third party in question has given you permission to do so and to MBN Solutions to collect, to process and to transfer their Personal data to the same extent as yours.
By accepting our Terms & Conditions, you authorize us to use your Personal data to send you automated email messages or marketing materials regarding our services, including employment information. You may opt out of receiving such marketing email messages at any time.
1. Personal data that is collected when you create an MBN Solutions account
When you create an MBN Solutions account, we ask you to provide your email address and name.
- MBN Solutions collects your email address because you use your email address and your password to sign into your account. The legal ground for processing your email address for this purpose is based on MBN Solutions’ legitimate interest in protecting the security of your account.
- If you provide your opt-in consent to receiving marketing information from MBN Solutions, MBN Solutions will also process your email address for the purpose of sending you marketing information about MBN Solutions products and apps. The legal ground for processing your email address for this purpose is your consent. You may withdraw your consent at any time by changing your preferences in your MBN Solutions account or through the unsubscribe link at the bottom of our marketing and newsletter emails. The marketing emails you receive from MBN Solutions are based on the preferences you provide in your MBN Solutions account, the locale indicated by your Internet Protocol (IP) address, and any subscriptions included in your MBN Solutions account. The legal ground for processing this data for this purpose is MBN Solutions’ legitimate interest in reducing the number of marketing emails sent to each particular user by selecting which users receive a particular marketing email rather than sending every marketing email to every user who has consented to receiving marketing emails.
- MBN Solutions also processes your email address to associate it with your MBN Solutions account when you interact with our consultants. The legal ground for this processing is our legitimate interest in providing quality customer support.
2. Personal data that is processed when you communicate with MBN Solutions
When you interact with our consultants via email, telephone, online or in person, we collect personal data, such as your name, mailing address, phone number, email address, contact preferences, CV and other relevant information relating to your work history which you may provide to us for the purposes of us providing out services to you; and information about MBN Solutions events and meetups you participate in. We may also create event logs that are useful in diagnosing usability issues with our website, and capture information relating to the support or service issue. To improve customer service, subject to applicable laws, we may also record and review conversations with our consultants, and analyse any feedback provided to us through voluntary candidate and user surveys. With your consent, our consultants may sign in to your MBN Solutions account, if appropriate, to help troubleshoot and resolve your issue.
We use the personal data we collect from you for the following purposes:
- processing job applications, in partnership with our clients, on whose behalf we are instructed to advertise job vacancies – this means that if you apply for a specific job, we may pass your details on to the relevant client to proceed with the application and you understand that this means you may receive further direct correspondence from them;
- allowing our clients, to understand who is making use of our Website and how their job vacancies are being viewed;
- with candidates’ permission, MBN Solutions may contact candidates directly and confidentially about other potentially suitable opportunities that may be relevant in the future;
- providing you with customer and product support and monitoring the quality and types of support we provide to our users
The legal grounds for processing this information are as follows:
- MBN Solutions’ legitimate interests in providing recruitment services to you and ensuring quality product support;
- to comply with our contractual obligations to you or to any clients to whom you have asked us to pass on your details;
- to comply with any other legal obligations to which we may be subject.
In certain circumstances, we may also request your specific consent to process certain personal data. We will notify you if that is the case.
Our Legal Bases for Processing your Data
MBN Solutions processes personal data in relation to its own staff and candidates and is a data controller for the purposes of the Data Protection Laws.
MBN Solutions will only process personal data where it has a legal basis for doing so:
MBN Solutions requires that you give your consent to the processing of your personal data in relation to MBN Solutions’s recruitment services. We believe this explicit consent is essential for both MBN Solutions and you and ensures both parties clearly understand their rights and the intentions of all involved in the consultation process. This basis for processing is in accordance with Article 6(1)(a) of the GDPR, which states "[you] have given consent to the processing of his/her personal data for one or more specific purposes"
As a recruitment consultancy, it is in both MBN Solutions 's interest and yours, as a candidate, for MBN Solutions to process your information in order to provide you with the most effective and efficient service. This basis for processing is in accordance with Article 6(1)(f) of the GDPR, which states "processing is necessary for the purposes of the legitimate interests pursued by MBN Solutions or by a third party, except where such interests are overridden by the interests or fundamental rights or freedoms of [you] which require protection of personal data."
Disclosures and transfers of personal data
MBN Solutions may disclose Personal data to third parties. The disclosure to third parties would occur in the following circumstances:
- We will disclose personal data to our clients where necessary and appropriate in connection with the provision of staffing services including contract and permanent placements for IT professionals.
- We may disclose Personal data to companies and individuals we employ to perform business functions and services on our behalf. Such functions may include, for example, hosting our Web servers, analyzing data, providing legal, accounting and marketing services.
- We may disclose Personal data to the extent necessary or appropriate to government agencies, advisers, and other third parties in order to comply with applicable laws, the service of legal process, or if we reasonably believe that such action is necessary to
- comply with the law requiring such disclosure;
- protect the rights or property of MBN Solutions;
- prevent a crime or protect national security or
- protect the personal safety of the users or the public.
The data protection laws outside the UK may not provide an equivalent level of protection to those in the United Kingdom, but MBN Solutions will abide by this Statement, as well as any applicable laws, when data is transferred. MBN Solutions will take steps to ensure that such recipients of data transfers are made aware of this Statement and take action to preserve the confidentiality and security of your personal data.
We may disclose personal data about you to others:
- if we have your valid consent to do so;
- to comply with a valid legal order, court order, legal process, or other legal obligation;
- to enforce any of our terms and conditions or policies; or
- as necessary to pursue available legal remedies or defend legal claims.
Transfers of Personal Data
MBN Solutions is a global business. To offer our services, we may need to transfer your personal data to client companies in other countries. When you create an MBN Solutions account, add personal data in your account profile, or upload data to your MBN Solutions account such as your CV, your personal data will be collected and stored on MBN Solutions servers in Scotland, United Kingdom. In the event that we require to transfer any of your personal data outside of the European Economic Area (“EEA”), we will ensure that, in accordance with applicable data protection legislation, there are appropriate technical and organisational safeguards in place, or that a specific derogation applies. Copies of any technical and organisational safeguards which are put in place with any organisation outside of the EEA are available from our Data Protection Officer, whose contact details are set out below.
Categories of Recipients of Personal Data Client Organisations
MBN Solutions is a leading provider of recruitment services to clients around the world. If you apply for a specific job, we will, if appropriate, pass your CV to a client organisation per the description set out above.
Other service providers
MBN Solutions uses cloud services from third parties including Vincere and HubSpot as our sales and marketing CRMs to assist in sending emails, marketing communications and providing our services.
Those services such as HubSpot track the activities associated with these emails, such as whether they were opened, whether links in the emails were clicked on, and whether users click on those links. MBN Solutions uses this data to analyse the level of engagement with its emails. MBN Solutions uses third- party service providers help us better understand usage of MBN Solutions services and the MBN Solutions websites.
If you apply for a job through MBN Solutions, we may add you to our marketing CRM, HubSpot, in order to keep in touch with you about new opportunities and to communicate about other services.
Management and Security of Personal data
MBN Solution takes the responsibility of the management and security of your personal data extremely seriously. And in accordance with the General Data Protection Regulation, MBN Solutions, acting as a data controller and data processor, follows the key principles of data protection. These require that personal data to be:
- Processed lawfully, fairly and in a transparent manner;
- Collected for specified and legitimate purposes and not further processed in a manner that is incompatible with those purposes;
- Adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed;
- Accurate and kept up to date. Every reasonable step will be taken to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay;
- Kept for no longer than is necessary for the purposes for which the personal data are processed;
- Processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures; and that
- MBN Solutions shall be responsible for, and be able to demonstrate, compliance with the principles.
Cookies and Similar Technologies Websites
We use this information to provide better, more relevant content on our site, to measure the effectiveness of advertisements, to identify and fix problems, and to improve your overall experience on our site. We may also engage one or more third-party service providers to provide online advertisements on our behalf. They may use a ‘pixel tag’ or other similar technology to collect information about your visits to sites, and they may use that information to send you targeted advertisements.
If you do not want information collected through the use of these technologies, there is a simple procedure in most browsers that allows you to automatically decline many of these technologies, or to be given the choice of declining or accepting them.
The legal ground for processing this analytical information is our legitimate interest in understanding how our customers interact with our products, apps and websites so we can enhance the user experience and functionality of our products, apps and websites.
Here are examples of third-party providers of analytics and similar services we currently use:
Google: Google Analytics is used to track site statistics and user demographics, interests and behaviour on websites. We also use Google Search Console to help understand how our website visitors find our website and to improve our search engine optimization. Find out more information about how this analytics information may be used, how to control the use of your information, and how to opt-out of having your data used by Google Analytics.
We may also obtain analytics information from social networks that help us measure the effectiveness of our content and advertisements on social networks (e.g., impressions and clicks).
Your Rights under GDPR
Under GDPR, the data subjects has certain important rights. These include (but are not limited) to the following:
- 1. The right of access to the data
- You have the right to obtain confirmation as to whether personal data concerning you is being processed, and, where that is the case, access to that personal data.
- In addition, you have the right to request a copy of the personal data that is being processed.
- 2. The right to have data rectified
- You may request MBN Solutions to rectify any inaccurate or incomplete personal data concerning yourself. If MBN Solutions has given your personal data to any third parties we will tell those third parties that we have received a request to rectify your personal data unless this proves impossible or involves disproportionate effort. Those third parties should also rectify the personal data they hold. However, MBN Solutions is not in a position to audit those third parties to ensure that the rectification has occurred.
- 3. The right to "be forgotten"
- This refers to your right to have your personal data completely deleted from our database, including from any third parties who may have access to that data. Further, the request to "be forgotten" must be as easy as it was to give consent.
- If MBN Solutions has given your personal data to any third parties, it will tell those third parties that we have received a request to erase the personal data, unless this proves impossible or involves disproportionate effort. Those third parties should also rectify the personal data they hold. However, MBN Solutions is not in a position to audit those third parties to ensure that the rectification has occurred.
- It should be noted that where there are legal requirements for MBN Solutions to store data for a certain period of time, related to our business, which includes elements of your personal data, we will not be able to delete that data until after the statutory retention period.
- 4. The right to restrict the processing of your data
- You have the right to ask MBN Solutions to restrict the processing of your personal data where:
- You challenge the accuracy of the personal data we are storing;
- MBN Solutions no longer needs your personal data for the purposes of the processing, but your personal data is required for the establishment, exercise or defence of legal claims; or
- You have objected to processing (on the grounds of a public interest or legitimate interest) pending the verification of whether the legitimate grounds of MBN Solutions override those of the individual.
- 5. The right to Data portability
You have the right to receive the personal data concerning you, which you provided to MBN Solutions, in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller without hindrance from MBN Solutions, where:
- the processing is based on a freely given consent by you, or on a contract to which you are party or in order to take staps at your requests prior to entering the contract, and
- the processing is carried out by automated means.
- 6. The right to object to automated decision making
- MBN Solutions will not subject individuals to decisions based on automated processing that produces a legal effect or a similarly significant effect on the individual, except where the automated decision:
- Is necessary for the entering into or performance of a contract between the data controller and the individual
- Is authorised by law; or
- The individual has given their explicit consent.
- 7. The right to lodge a complaint
- You have the right to object to your personal data being processed based on a public interest or a legitimate interest. You also can object to the profiling of your data based on a public interest or a legitimate interest.
- Upon receiving a claim from you, MBN Solutions shall cease processing unless it has compelling legitimate grounds to continue to process the personal data which override the individual's interests, rights and freedoms or for the establishment, exercise or defence of legal claims.
- You also have the right to object to your personal data being used for direct marketing
If you remain dissatisfied, you can make a complaint about the way we process your personal data to the supervisory authority. If you are resident in the United Kingdom, the relevant supervisory authority is the Information Commissioner’s Office – www.ico.org.uk.
To request access to or rectification, portability or erasure of your personal data, or to delete your MBN Solutions account, visit our Privacy Centre.
If you wish to exercise your right to restrict processing or your right to object to processing, or if you have any queries relating to the processing of your personal data by MBN Solutions, please contact MBN Solutions’ Data Protection Officer at MBN Recruitment Solutions Ltd 112 West George Street, Glasgow G2 1PN or by email at email@example.com.
We request that individuals under 16 not provide personal data to MBN Solutions. If we learn that we have collected the personal data from a child under 16, we will take steps to delete the information as soon as possible.
Retention of Personal Data
We will retain your personal data as long as your MBN Solutions account is considered to be active. In addition, see below under “Your Rights” for a description of your right of erasure.
Contacting us, exercising your information rights and Complaints
We fully comply with Data Protection legislation and will assist in any investigation or request made by the appropriate authorities.
If you remain dissatisfied, then you have the right to apply directly to your competent supervisory authority.
Changes to this Policy