1. General Information
Arpero Ltd
26 York St, Birmingham, B17 0HG
Registered in England no 09773011
VAT: GB 225 8213 22
Rodger Hill – Rodger.Hill@arperocompany.com
Richard Jones– Richard.Jones@arperocompany.com
Arthur de Oude – arthur.deoude@arperocompany.com
About Arpero
Established in 2014, Arpero has developed over the years in response to our own growing realisation that much of the associate resourcing market within management consulting is reactive, transactional, and run wholly by people who come from the recruitment side of the equation. Our aim is to disrupt these recruitment norms and work with you to fundamentally improve your performance. So think beyond “Where can I get the best consulting associates?” – and start thinking “How can I use flexible next generation resourcing to help my business deliver real competitive advantage?”.
2. Legal / Privacy / Cookie statement
COMPANY PRIVACY NOTICE
Company Name: Arpero Ltd (‘the Company’ or ‘Arpero’)
Company Contact Details: Sharon McDonagh (Data Protection Lead) – sharon.mcdonagh@arperocompany.com
Date Updated: January 14, 2021
This Privacy Policy applies to the personal data of our website users, candidates, clients and suppliers.
Arpero is an associate workforce resourcing solutions business which provides work-finding services to its clients and work-seekers. The Company must process personal data so that it can provide these services – in doing so, the Company acts as a data controller. We will always comply with any applicable data protection laws.
We comply with current requirements to notify our data processing activities to the Information Commissioner’s Office and are registered under number ZA520938.
The Company must have a legal basis for processing your personal data. We will only use your personal data in accordance with the terms of this policy.Personal data means any information relating to an identified or identifiable human being. (An “identifiable natural person” is one who can be identified, directly or indirectly, for example, by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, biometric, mental, economic, cultural or social identity of that person).
In this policy, where we have referred to needing your consent for any processing, we will make sure that the consent:
is specific consent for one or more specified purposes; and
is given by a clear affirmative act establishing a freely given, specific, informed and unambiguous indication of your agreement to the relevant processing of personal data.
1) CATEGORIES OF PERSONAL DATA
i. Candidates: In order to provide you with work-finding services, we need to collect and process certain information about you. The information that we collect may include (but is not limited to) your name, address, email address, telephone number(s), curriculum vitae, employment details, salary information, notice period, qualifications, right to work in the UK, photograph, compliance documents, links to your professional profiles, employment preferences.
ii. Clients: If you are a client of Arpero, we need to collect and process information about you or individuals at your organisation in order to supply candidates to you and to ensure that the contractual arrangements between us can be implemented. The information we collect may include (but is not limited to) your name, job title, email address, telephone number(s), links to your professional profiles, work address details.
iii. Suppliers: If you supply services to Arpero, we will need to retain and process your contact details and contact details of relevant individuals at your organisation to ensure that the contractual arrangements between us can be properly implemented. This information may include (but is not limited to) your name, job title, email address, work address, telephone number(s), company bank details (so that we can pay for services provided).
Sensitive Personal Data: Different rules apply to sensitive or special category personal data where the data concerns race, ethnic origin, politics, religious or philosophical beliefs, trade union membership, genetic or biometric data (such as fingerprints used for identification purposes), health (physical or mental), sex life or sexual orientation. We do not intentionally or knowingly collect this type of information as we do not need it for recruitment purposes. Please do not submit this type of data - any sensitive/special category data supplied, will be deleted.
2) SOURCES OF DATA
i. Information we obtain directly from you: This is personal data that you give us by using the ‘Contact us page’ – www.arperocompany.com (our site), or by corresponding with us by phone, e-mail or otherwise.
ii. Information we obtain from other sources: This is personal data that we obtain about you via other sources such as job boards, LinkedIn, CV libraries, referrals and any other relevant social media sites. We will inform you within 30 days of obtaining your details, by sending you this privacy notice stating the source the personal data originates from.
iii. Our website
- You can send us your personal information via the ‘Contact Us’ page on our website or by applying to a job that is advertised.
- Cookies: www.arperocompany.com (Our site) has a detailed cookie policy
- Our website contains no links to third party sites.
We will only collect personal data to the extent that it is required for the specific purpose notified to individuals about whom we are collecting it and we will keep it only as long as is necessary.
3) PURPOSE OF PROCESSING AND LEGAL BASIS
i. CANDIDATES:
The Company will collect your personal data and will process your personal data for the purposes of considering your CV and providing you with work-finding services. This includes for example, contacting you about engagement opportunities, assessing your suitability for those opportunities, updating our database, putting you forward for engagement opportunities, and developing and managing our services and relationship with you.
In some cases, we may be required to use your data for the purpose of complying with laws that apply to us. We may also use your information during the course of internal audits to demonstrate our compliance with certain industry standards.
The legal bases we rely upon to process your personal data are:
a. Where it is necessary in order to perform a contract
b. Where we have a legitimate interest
c. To comply with a legal/statutory obligation that we have
d. Your consent
For the purposes of processing your personal data our legal bases are:
a. Necessary to perform our contract with you
- We act as an associate workforce recruitment agency as defined under the Employment Agencies Act 1973.We introduce candidates to clients for non-permanent roles - to be engaged directly by the client. The exchange of personal data of our candidates is an essential part of this process. (name, contact details, CV information)
- To deliver updates relevant to our recruitment services we need to contact candidates on a regular basis via email, phone (calls and texts), job alerts and other relevant notifications. (name, contact details)
b. Legitimate Interest:
- We require a database of candidate personal information so that we can contact candidates regarding potential engagement opportunities when they arise. (name, contact details, CV information)
- To ensure that content from our website is presented in the most effective manner for you and for your device (online identifiers, location data and other technical information).
- To allow you to participate in any interactive features of our service, when you choose to do so (online identifiers, location data and other technical information).
c. Statutory/Legal obligation:
As an associate workforce recruitment agency, we are required to collect certain personal data to meet statutory obligations, such as the Conduct of Employment Agencies and Employment Businesses Regulations 2003 – for example, we have to check identity, right to work, suitability for the role, qualifications and experience before submitting your details to our clients. (name, contact details, dates of birth, eligibility to work, employment history)
d. Consent
- We will request your consent, should we need to rely on this legal basis.
- You have the right to withdraw your consent for marketing purposes at any time and can do so by contacting Sharon McDonagh (sharon.mcdonagh@arperocompany.com)
- Where we have relied on consent to send you marketing material, we will retain this consent for a period of no more than 1 year. Upon expiry of that period the Company will seek further consent from you. Where consent is not granted the Company will cease to send you marketing material.
ii. CLIENTS:
The Company will collect and process information about you or individuals at your organisation in order to provide work-finding services. This includes for example, contacting you about engagement specifications, providing relevant candidates for projects, briefings, interview arrangements and to develop and manage our services and relationship with you.
In some cases, we may be required to use your data for the purpose of complying with laws that apply to us. We may also use your information during the course of internal audits to demonstrate our compliance with certain industry standards.
The legal bases we rely upon to process your personal data are:
a. Where it is necessary in order to perform a contract
b. Where we have a legitimate interest
c. To comply with a legal/statutory obligation that we have
d. Contractual obligations
a. Necessary to perform our contract with you
We need client contact information so that we can provide relevant candidates when new engagement opportunities arise, to liaise regarding candidate feedback and interview arrangements, and for engagement briefings. (names, contact details, data relating to relevant roles/incumbent holder of role)
b. Legitimate Interest:
- To ensure that content from our website is presented in the most effective manner for you and for your device (online identifiers, location data and other technical information).
- To allow you to participate in any interactive features of our service, when you choose to do so (online identifiers, location data and other technical information).
c. Statutory/Legal obligation:
As an associate workforce Recruitment agency, we are required to collect certain data to meet statutory obligations, such as the Conduct of Employment Agencies and Employment Businesses Regulations 2003. We cannot supply a candidate to a client unless we have obtained sufficient information from the client to select a suitable candidate for the role which the client is looking to fill – for example, the identity of the client and nature of the client’s business, the position the client is looking to fill including the type of work, location, hours, the experience, training and qualifications which the client considers necessary for a candidate to possess in order to work in the role. (name, contact details)
d. Contractual obligation:
If you are a client of Arpero, we need to collect and process information about you or individuals at your organisation in order to ensure that the contractual arrangements between us can be implemented. (name, contact details)
iii. SUPPLIERS:
For the purposes of retaining supplier information our legal bases are:
a. Legitimate interest
b. Contractual obligation
a. Legitimate Interest:
We need to collect and process information about you or individuals at your organisation to discuss the services that you provide to us. (name, contact details)
b. Contractual obligation:
If you are a supplier of Arpero, we need to collect and process information about you or individuals at your organisation in order to ensure that the contractual arrangements between us can be implemented. (name, contact details)
4) SENSITIVE PERSONAL DATA
Protection for sensitive personal data: Processing of sensitive personal data requires higher levels of protection.We may process sensitive personal data about an individual in the following circumstances:
where that individual has given explicit consent for one or more specified purposes;
5) OTHER ISSUES ABOUT HOW WE USE PERSONAL DATA:
(a) Please note that we may process your personal information for more than one lawful basis depending on the specific purpose for which we are using your data.Please contact us if you need details about the specific legal basis we are relying on to process your personal data – contact details are at the beginning of this policy.
(b) 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.Please contact us if you would like further details of any additional purposes of processing.If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis that allows us to do so.
(c) Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with services).If this happens, we may have to cancel, or be unable to provide, any services you have requested.
(d) Please note that we may process your personal data without your knowledge or consent where required or permitted by law.
(e) We may collect, use and share aggregated data such as statistical or demographic data for any purpose.Aggregated data may be derived from your information 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 website 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 policy.
(f) If you provide us with any personal data relating to relatives, partners or other individuals it is your duty to make such persons aware that their personal data may be shared with us and to provide them with appropriate information about how their personal data may be processed by us.
Automated decision-making takes place when an electronic system uses personal data to make a decision relevant to you without human intervention. We do not envisage that any decisions will be taken about you using automated means, however we will notify you in writing if this position changes.
7) RECIPIENT/S OF DATA
i. CANDIDATES:
The Company will share your personal data with the following recipients:
- The REC (The Recruitment & Employment Confederation) in the event of any internal audits and investigations carried out on the Company to ensure that we are complying with all relevant laws and obligations
- MWN Associates Ltd – our Associate business, should you wish to discuss contract vacancies
- Our remote desktop providers only in the event of a technical issue.
- Our CRM provider only in the event of a technical issue or for database backup purposes
ii. CLIENTS:
The Company will process your personal data with the following recipients:
- Candidates will receive engagement specifications and company information (Arpero will only forward material that has been authorised by the client)
- Candidates will receive interviewer’s name and job title along with interview scheduler name and contact information via interview confirmations.
- The REC in the event of any internal audits and investigations carried out on the Company to ensure that we are complying with all relevant laws and obligations
- Our remote desktop providers only in the event of a technical issue.
- Our CRM provider only in the event of a technical issue or for database backup purposes
iii. SUPPLIERS:
The Company will process your personal data with the following recipients:
- The REC in the event of any internal audits and investigations carried out on the Company to ensure that we are complying with all relevant laws and obligations
- Our remote desktop providers only in the event of a technical issue.
- Our CRM provider only in the event of a technical issue or for database backup purposes.
Transfer of personal data outside of the EEA: We may transfer certain personal data that we hold on individuals to a country outside the UK or the European Economic Area ("EEA"), provided that one of the following conditions applies:
· the country to which the personal data is transferred ensures an adequate level of protection for that individual’s rights and freedoms;
· an individual has given their explicit and informed consent having had the risks explained to them;
· the transfer is covered by one of the derogations set out in the GDPR, including the performance of a contract between us and that individual, or to protect the vital interests of individuals;
· the transfer is legally required on important public interest grounds or for the establishment, exercise or defence of legal claims; or
· the transfer is authorised by the relevant data protection authority where we have checked adequate safeguards exist with respect to the protection of the individual’s privacy, their fundamental rights and freedoms, and the exercise of their rights.
Safeguards: If we use a third party data processor to process personal data on our behalf, we will obtain contractual commitments to safeguard the security of the personal data to ensure that the third party only acts on our instructions when using that personal data and that the third party has in place appropriate technical and organisational security measures to safeguard the personal data.Whenever we transfer your personal data out of the UK or the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
· We may transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
· Where we use service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in the UK and Europe.
· Where we use service providers based in the US, we may transfer data to them if they are part of the Privacy Shield, which requires them to provide similar protection to personal data shared between the UK/Europe and the US.
8) DATA STORAGE/SECURITY
i. Data Storage
Any information collected and processed by Arpero is stored in the following locations:
- On our secure CRM (which can be accessed via our laptops only)
- In our emails (which can be accessed via our laptops and mobile phones only)
- In files on our server (which can be accessed via our laptops only)
ii. Data Security
Our CRM, emails and files are hosted on a secure serverwho work to the ISO 27001 standard for information security. - The server can only be accessed by Arpero staff, who each have a unique username and password.
- Once access to the server has been granted - an additional username and password is required to enter our CRM
- All laptops are password protected and an additional username and password is required to enter our server.
- All mobile phones are password protected. An additional username and password is required to access emails on our phones.
We have put in place internal procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.
9) DATA RETENTION
Arpero will retain your personal data only for as long as is necessary. We regularly review the length of time that personal data is kept, considering the purpose(s) for which the data is being retained and whether we can achieve those purposes through other means, the amount, nature and sensitivity of the data, the potential risk of harm from unauthorised use or disclosure of the data and the applicable legal requirements. Any data that is no longer required is destroyed securely. If we need to keep personal data to comply with legal or statutory requirements, we will minimise the data that is retained.
If you state that you no longer wish to be contacted by Arpero, we will cease all contact and delete your details from our database.
Unsuccessful applicants – please note that if you submit your details for consideration via a job board, our website, directly to us or via any other channels and we deem your application unsuccessful, we will not retain your information.
10) YOUR RIGHTS
Please be aware that you have the following data protection rights:
- The right to be informed about personal data the Company processes relating to you;
- The right of access to your personal data processed by the Company;
- The right to rectification of your personal data;
- The right to erasure of your personal data in certain circumstances;
- The right to restrict processing of your personal data;
- The right to data portability in certain circumstances;
- The right to object to the processing of your personal data that was based on legitimate interest;
- The right not to be subjected to automated decision making and profiling; and
- The right to withdraw consent at any time.
There may be circumstances where the Company will still need to process your data for legal reasons. We will inform you if this is the case. Where this is the case, we will restrict the data to only what is necessary for the purpose of meeting those specific reasons.
If you believe that any of your data that the Company processes is incorrect or incomplete, please contact Sharon McDonagh, sharon.mcdonagh@arperocompany.com and we will check its accuracy and correct it where necessary.Please also contact Sharon to exercise any of the rights explained above.
We aim to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests.In this case, we will notify you and keep you updated.
11) COMPLAINTS OR QUERIES
If you wish to complain about this privacy policy or any of the procedures set out in it please contact: Sharon McDonagh, sharon.mcdonagh@arperocompany.com.
You also have the right to raise concerns with Information Commissioner’s Office on 0303 123 1113 or at https://ico.org.uk/concerns/, or any other relevant supervisory authority should your personal data be processed outside of the UK, if you believe that your data protection rights have not been adhered to.We would, however, appreciate the chance to deal with your concerns before you approach the Information Commissioner's Office, so please contact us in the first instance.
12) UPDATES TO THIS POLICY
We regularly review our privacy policy and update the version on our website, to check that you have the most recent version – please periodically visit: http://www.arperocompany.com/privacy-policy
Where appropriate, we will notify individuals of changes by post or email.Each time you enter or use our website, you agree that the privacy policy current at that time shall apply to all information we hold about you.
This policy was last updated on January 14, 2021.
3. Disclaimers
Copyright Arpero 2020 – All rights reserved
Arpero is not responsible for any errors or omissions, or for the results obtained from the use of this information. All information in this site is provided "as is", with no guarantee of completeness, accuracy, timeliness or of the results obtained from the use of this information..."
4. Terms & Conditions
last updated: January 14, 2021
Any material contained on this website contains general information only and should be relied upon.We reserve the right to update or suspend the website at any time.
Neither the transmission of any material, nor the receipt of any material, is intended to create, nor should such transmission or receipt be taken as creating, a contractual relationship between us (Arpero) and the website visitor (you).
Governing law
Any material on this website resides on a server in the United Kingdom. The law applicable to use of the material and to disputes arising out of the material is the law of England and Wales.
Intellectual property rights in material on this site
Unless indicated to the contrary, copyright or other intellectual property rights in the material on this site is owned by or licensed to Arpero. Except as provided by any relevant legal provision, no part of any of this material may be reproduced, adapted, stored in a retrieval system or transmitted without the prior written permission of the copyright owner. You may do the following with the material on this site, unless otherwise indicated:
· store a reproduction of the material on your local computer for the sole purpose of viewing the material; and print hard copies of the material for informational, non-commercial use.
All other rights are reserved. All trademarks, service marks, trade names and logos contained on this website belong to their respective owners.
Limitations and exclusions
Any liability incurred in relation to material on this website is, to the extent permitted by law, limited to the resupply of the material, or the reasonable cost of having the material resupplied. Under no circumstances will Arpero be liable for any damages for loss of business or other profits arising in relation to your use of the material, or for any incidental, special or consequential damages.
Changes are made periodically to the material, and the material could include technical inaccuracies or typographical errors. Arpero makes no warranties or representations regarding the quality, accuracy, completeness, merchantability or fitness for purpose of any material.
Arpero does not warrant or represent that the material will not cause damage, or is free from any computer virus, malicious software or any other defects or errors.
Arpero is not liable for, and does not endorse, any third party website by which you may have accessed the Arpero website, or which you may access from the Arpero website.You should consider the privacy policy, terms of use and any security features of third party websites.
Accessibility
This website has been designed to be as usable and accessible as possible by a wide variety of users, using a wide variety of devices and browsers to access it.
If you have any queries regarding these terms, please contact us on: sharon.mcdonagh@arperocompany.com
Cookie Policy
Our website at www.arperocompany.com has a separate cookie policy.