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Privacy Policy

WHAT IS THE PURPOSE OF THIS DOCUMENT?

SteppingStones Recruitment Ltd (“SteppingStones”) is committed to protecting the privacy and security of your personal information.

This privacy policy describes how we collect, use and maintain information about you, whether we are in the process of helping you find a job; continuing our relationship with you once we have found you a role; providing you with a service; receiving a service from you; using your data to ask for your assistance in relation to our provision of services or if is collected from the users (“User”) of steppingstonesrecruitment.com (“Site”) website.

This Privacy Policy applies to the personal data of our Website Users, Candidates, Clients, Suppliers, and other people whom we may contact in order to find out more about our Candidates or whom they indicate is an emergency contact. Please note we may update this policy at any time. Processing of personal employee information is governed by our Employee Privacy Policy.

This policy applies to the Site and services offered therein and incorporates the requirements of jurisdictionally relevant data protection legislation (including but not limited to the General Data Protection Regulation (the “GDPR”). Your privacy is important to us, and we are committed to protecting and safeguarding your data privacy rights.

SteppingStones is a “data controller”. This means that we are responsible for deciding how we hold and use personal information about you. We are required under data protection legislation to notify you of the information contained in this privacy policy.

It is important that you read this policy, together with any other documentation we may provide on specific occasions when we are collecting or processing personal information about you, so that you are aware of how and why we are using such information.

DATA PROTECTION PRINCIPLES

We will comply with data protection law. This says that the personal information we hold about you must be:

Used lawfully, fairly and in a transparent way.
Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
Relevant to the purposes we have told you about and limited only to those purposes.
Accurate and kept up to date.
Kept only as long as necessary for the purposes we have told you about.
Kept securely.

WHAT KIND OF PERSONAL INFORMATION DO WE COLLECT?

CANDIDATE DATA: In order to provide the best possible employment opportunities that are tailored to you, we need to process certain information about you. We only ask for details that will genuinely help us to help you.

Depending on the relevant circumstances and applicable local laws and requirements, we may collect some or all of the information listed below to enable us to offer you employment opportunities which are tailored to your circumstances and your interests:

Personal contact details such as name, title, addresses, telephone numbers, and personal email addresses.
Age / Date of birth.
Sex / Gender.
Marital status and dependents.
Next of kin and emergency contact information.
Nationality / citizenship / place of birth
Where relevant (depending on nationality and jurisdiction, National Insurance number, Social Security number)
Bank account details, payroll records and tax status information.
Current & historical salary, annual leave, pension and benefits information.
Start date.
Location of employment or workplace.
Copy of identification such as driving licence, passport and/or other identity card.
Recruitment information (including copies of right to work documentation, references and other information included in a resume or cover letter or as part of the application process).
Employment records (including job titles, work history, working hours, training records and professional memberships).
Education details
Performance information.
Disciplinary and grievance information.
Financial information
CCTV footage and other information obtained through electronic means such as swipecard records.
Information about your use of our information and communications systems.
Photographs.
Extra information that you choose to tell us about you.
Extra information that your referees choose to tell us about you.
Extra information that Third Parties may tell us about you, or that we find from other third-party sources such as social media and job sites

We may also collect, store and use the following “special categories” of more sensitive personal information:

Information about your race or ethnicity, religious beliefs, sexual orientation and political opinions.
Where relevant, trade union membership.
Information about your health, including any medical condition, health and sickness records.
Genetic information and biometric data.
Information about criminal convictions and offences.
Please note that the above list of categories of personal data we may collect and use is not exhaustive.

CLIENT DATA: If you are a SteppingStones customer, we need to collect and use information about you, or individuals at your organization, in the course of providing you with our services and/or notifying you of content published by SteppingStones which is likely to be relevant and useful to you.

We generally only need to have your contact details or the details of individual contacts at your organization (such as their names, telephone numbers and email addresses) to enable us to ensure that our relationship runs smoothly. We also hold information relating to your online engagement with Candidate profiles and other material published by SteppingStones, which we use to ensure that our marketing communications to you are relevant and timely. We may also hold extra information that someone in your organization has chosen to tell us.

SUPPLIER DATA: We need a small amount of information from our Suppliers to ensure that things run smoothly. We’ll collect the details for our contacts within your organization, such as names, telephone numbers and email addresses. We’ll also collect bank details, so that we can pay you. We may also hold extra information that someone in your organization has chosen to tell us

PEOPLE WHOSE DATA WE RECEIVE FROM CANDIDATES AND STAFF, SUCH AS REFEREES AND EMERGENCY CONTACTS: In order to provide Candidates with suitable employment opportunities safely and securely and to provide for every eventuality for them and our Staff, we need some basic background information. We only ask for very basic contact details, so that we can get in touch with you either for a reference or because you’ve been listed as an emergency contact for one of our Candidates or Staff members.

WEBSITE USERS: We collect a limited amount of data from our Website Users which we use to help us to improve your experience when using our website and to help us manage the services we provide. This includes information such as how you use our website, the frequency with which you access our website, your browser type, the location you view our website from, the language you choose to view it in and the times that our website is most popular. If you contact us via the website, we will collect any information that you provide to us, for example your resume and/or your name and contact details.

Depending on the type of personal data in question and the grounds on which we may be processing it, should you decline to provide us with such data, we may not be able to fulfil our contractual requirements or, in extreme cases, may not be able to continue with our relationship.

HOW DO WE COLLECT YOUR PERSONAL DATA?

CANDIDATE DATA: We collect Candidate personal data in three primary ways:

1. Personal data that you, the Candidate, give to us;

2. Personal data that we receive from other sources; and

3. Personal data that we collect automatically.

Personal data you give to us

SteppingStones needs to know certain information about you in order to provide a tailored service. This will enable us to provide you with the best opportunities and should save you time in not having to trawl through information about jobs and services that are not relevant to you.

There are numerous ways you can share your information with us. It all depends on what suits you. These may include

Entering your details on the SteppingStones website or via an application form, as part of the registration process;
Leaving a hard copy resume at a SteppingStones recruitment event, career expo or office;
Emailing your resume to a SteppingStones consultant or being interviewed by them;
Applying for jobs through a job aggregator or job board, which then redirects you to the SteppingStones website.

Personal data we receive from other sources

We also receive personal data about Candidate from other sources. Depending on the relevant circumstances and applicable local laws and requirements, these may include personal data received in the following situations:

Your referees may disclose personal information about you;
Our Clients may share personal information about you with us;
We may obtain information about you from searching for potential Candidate from third party sources, such as LinkedIn and other job sites;
If you ‘like’ our page on Facebook or ‘follow’ us on Instagram or Twitter we will receive your personal information from those sites; and
If you were referred to us by a third party or supplier, they may share personal information about you with us.

Personal data we collect automatically

To the extent that you access our website or read or click on an email from us, where appropriate and in accordance with any local laws and requirements, we may also collect your data automatically or through you providing it to us.

CLIENT DATA: We collect Client personal data in three ways:

1. Personal data that we receive directly from you;

2. Personal data that we receive from other sources; and

3. Personal data that we collect automatically.

Personal data that we receive directly from you

We will receive data directly from you in two ways:

Where you contact us proactively, usually by phone or email; and/or
Where we contact you, either by phone or email, or through our consultants’ business development activities more generally.

Personal data we receive from other sources

Where appropriate and in accordance with any local laws and requirements, we may seek more information about you or your colleagues from other sources generally by way of due diligence or other market intelligence including:

From third party market research and by analyzing online and offline media (which we may do ourselves, or employ other organizations to do for us);
From delegate lists at relevant events; and
From other limited sources and third parties (for example from our Candidates to the extent that they provide us with your details to act as a referee for them).

Personal data we collect via our website

PEOPLE WHOSE DATA WE RECEIVE FROM CANDIDATES AND STAFF, SUCH AS REFEREES AND EMERGENCY CONTACTS: We collect your contact details only where a Candidate or a member of our Staff puts you down as their emergency contact or where a Candidate gives them to us in order for you to serve as a referee.

WEBSITE USERS: When you visit our website, there is certain information that we may automatically collect, whether or not you decide to use our services. This includes your IP address, the date and the times and frequency with which you access the website and the way you browse its content. We will also collect data from you when you contact us via the website, for example by using the chat function.

We collect your data automatically via cookies, in line with cookie settings in your browser. If you are also a Candidate or Client of SteppingStones, we may use data from your use of our websites to enhance other aspects of our communications with or service to you.

HOW DO WE USE YOUR PERSONAL DATA?

Having obtained data about you, we then use it in a number of ways.

CANDIDATE DATA: The main reason for using your personal details is to help you find employment or other work roles that might be suitable for you. The more information we have about you, your skillset and your ambitions, the more bespoke we can make our service. Where appropriate and in accordance with local laws and requirements, we may also use your personal data for things like marketing, profiling and diversity monitoring. Where appropriate, we will seek your consent to undertake some of these activities.

We generally use Candidate data in the following ways:

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

We may also use your personal information in the following situations, which are likely to be rare:

Where we need to protect your interests (or someone else’s interests).
Where it is needed in the public interest or for official purposes.
In appropriate circumstances in the future, we may also use Candidate data for Profiling.

As our main area of work is recruitment, we’ve listed below various ways in which we may use and process your personal data for this purpose. Please note that this list is not exhaustive.

Collecting your data from you and other sources, such as LinkedIn;
Storing your details (and updating them when necessary) on our database, so that we can contact you in relation to recruitment;
Providing you with our recruitment services and to facilitate the recruitment process;
Assessing data about you against vacancies which we think may be suitable for you;
Sending your information to Clients, in order to apply for jobs or to assess your eligibility for jobs;
Enabling you to submit your resume, apply online for jobs or to subscribe to alerts about jobs we think may be of interest to you;
Allowing you to participate in specialist online training or testing;
Carrying out our obligations arising from any contracts entered into between us;
Carrying out our obligations arising from any contracts entered into between SteppingStones and third parties in relation to your recruitment;
Facilitating our payroll and invoicing processes;
Carrying out customer satisfaction surveys;
Verifying details you have provided, using third party resources (such as psychometric evaluations or skills tests), or to request information (such as references, qualifications and potentially any criminal convictions, to the extent that this is appropriate and in accordance with local laws);
Complying with our legal obligations in connection with the detection of crime or the collection of taxes or duties; and
Processing your data to enable us to send you targeted, relevant marketing materials or other communications which we think are likely to be of interest to you.

We may use your personal data for the above purposes if we deem it necessary to do so for our legitimate interests.

We may periodically send you information that we think you may find interesting, or to ask for your help with connecting other Candidates with jobs. In particular, we may wish to use your data for the purposes listed below, where appropriate and in accordance with any local laws and requirements. Please note that this list is not exhaustive. To:

enable us to develop and market other products and services;
market our full range of recruitment services to you;
send you details of reports, promotions, offers, networking and client events, and general information about the industry sectors which we think might be of interest to you;
display promotional excerpts from your details on SteppingStones’ website(s) as a success story (only where we have obtained your express consent to do so); and
provide you with information about certain discounts and offers that you are eligible for by virtue of your relationship with SteppingStones.

We need your consent for some aspects of these activities which are not covered by our legitimate interests (in particular, the collection of data via cookies, and the delivery of direct marketing to you through digital channels) and, depending on the situation, we’ll ask for this via an opt-in or soft-opt-in (which we explain further below).

Soft opt-in consent is a specific type of consent which applies where you have previously engaged with us (for example by submitting a job application or resume, or registering a vacancy to be filled), and we are marketing other recruitment-related services. Under ‘soft opt-in’ consent, we will take your consent as given unless or until you opt out. For most people, this is beneficial as it allows us to suggest other jobs to you alongside the specific one you applied for, significantly increasing the likelihood of us finding you a new position. For other types of e-marketing, we are required to obtain your explicit consent.

If you are not happy about our approach to marketing, you have the right to withdraw your consent at any time. In the event that we accidentally recapture your details through public sources in an unconnected marketing campaign we apologize and would ask that in those circumstances you opt out again.

All our marketing is based on what we think will serve our Clients and Candidates best, but we know we won’t always get it right for everyone. We may use your data to show you SteppingStones adverts and other content on other websites, for example Facebook. If you do not want us to use your data in this way, please turn off the “Advertising Cookies” option (please refer to our Cookies Policy). Even where you have turned off advertising cookies, it is still possible that you may see a SteppingStones advert, but in this case it won’t have been targeted at you personally, but rather at an anonymous audience.

We are committed to ensuring that our recruitment processes are aligned with our approach to equal opportunities. Some of the data we may (in appropriate circumstances and in accordance with local law and requirements) collect about you comes under the umbrella of “diversity information”. This could be information about your health, criminal convictions, ethnic background, gender, disability, age, sexual orientation, religion or other similar beliefs, and/or social-economic background. Where appropriate and in accordance with local laws and requirements, we’ll use this information on an anonymised basis to monitor our compliance with our equal opportunities policy. We may also disclose this (suitably anonymized where relevant) data to Clients where this is contractually required or the Client specifically requests such information to enable them to comply with their own employment processes.

Due to the nature of Immigration legislation and other similar requirements in the Cayman Islands, where we are providing a service to you, some ‘sensitive’ personal information will be gathered and processed in order to enable us to provide you with the service whilst meeting local regulatory and legal requirements. We will obtain your explicit consent before we can use it for any other purpose.

If you are not happy about this, you have the right to withdraw your consent at any time.

In more unusual circumstances, we may use your personal data to help us to establish, exercise or defend legal claims.

Although at present, all our recruitment activities involve human-decision making during the process, we may in the future use fully automated technologies such as expert systems or machine learning to complete a Candidate selection process from end-to-end, where appropriate and in accordance with any local laws and requirements.

Where appropriate, we will seek your consent to carry out some or all of these activities. If you do not provide consent to profiling, your application will continue to be reviewed manually for opportunities you apply for, but your profile will not be automatically considered for alternative roles. This is likely to decrease the likelihood of us successfully finding you a new job.

You have the right to withdraw that consent at any time.

CLIENT DATA: The main reason for using information about Clients is to ensure that the contractual arrangements between us can properly be implemented so that the relationship can run smoothly. We use Client information for:

Recruitment Activities;
Marketing Activities; and
To help us to establish, exercise or defend legal claims.

In more detail:

As our main area of work is recruitment, through providing you with Candidates or other services

Storing your details (and updating them when necessary) on our database, so that we can contact you in relation to recruitment activities;
Keeping records of our conversations and meetings, so that we can provide targeted services to you;
Undertaking customer satisfaction surveys; and
Processing your data for the purpose of targeting appropriate marketing campaigns.

We may use your personal data for these purposes if we deem this to be necessary for our legitimate interests.

Subject to any applicable local laws and requirements, we will not, as a matter of course, seek your consent when sending marketing materials to a corporate postal or email address.

If you are not happy about this, you have the right to opt out of receiving marketing materials from us.

In more unusual circumstances, we may use your personal data to help us to establish, exercise or defend legal claims.

SUPPLIER DATA: The main reasons for using your personal data are to ensure that the contractual arrangements between us can properly be implemented so that the relationship can run smoothly, and to comply with legal requirements. We will only use your information:

To store (and update when necessary) your details on our database, so that we can contact you in relation to our agreements;
To offer services to you or to obtain support and services from you;
To perform certain legal obligations;
To help us to target appropriate marketing campaigns; and
In more unusual circumstances, to help us to establish, exercise or defend legal claims.

We may use your personal data for these purposes if we deem this to be necessary for our legitimate interests.

We will not, as a matter of course, seek your consent when sending marketing messages to a corporate postal or email address.

If you are not happy about this, in certain circumstances you have the right to object.

PEOPLE WHOSE DATA WE RECEIVE FROM CANDIDATES AND STAFF, SUCH AS REFEREES AND EMERGENCY CONTACTS: We use referees’ personal data to help our Candidates to find employment which is suited to them. If we are able to verify their details and qualifications, we can make sure that they are well matched with prospective employers. We may also use referees’ personal data to contact them in relation to recruitment activities that may be of interest to them. We use the personal details of a Candidates or Staff member’s emergency contacts in the case of an accident or emergency affecting that Candidates or member of Staff.

We will only use the information that our Candidate gives us about you for the following purposes:

If our Candidates or Staff members put you down on our form as an emergency contact, we’ll contact you in the case of an accident or emergency affecting them; or
If you were put down by our Candidate or a prospective member of Staff as a referee, we will contact you in order to take up a reference. This is an important part of our Candidate quality assurance process and could be the difference between the individual getting a job or not.
If you were put down by our Candidate or a prospective member of Staff as a referee, we may sometimes use your details to contact you in relation to recruitment activities that we think may be of interest to you, in which case we will use your data for the same purposes for which we use the data of Clients.

We may use your personal data for these purposes if we deem this to be necessary for our legitimate interests.

If you are not happy about this, you have the right to object.

WEBSITE USERS: We use your data to help us to improve your experience of using our website, for example by analyzing your recent job search criteria to help us to present jobs to you that we think you’ll be interested in. If you are also a Candidate or Client of SteppingStones, we may use data from your use of our websites to enhance other aspects of our communications with, or service to, you.

WHO DO WE SHARE YOUR PERSONAL DATA WITH?

CANDIDATE DATA: We may share your personal data with various parties, in various ways and for various reasons. Primarily we will share your information with prospective employers to increase your chances of securing the job you want. Unless you specify otherwise, we may also share your information with any of our group companies and associated third parties such as our service providers where we feel this will help us to provide you with the best possible service.

CLIENT DATA: We will share your data to ensure that we provide you with a suitable pool of Candidates and as needed to provide you with our services. Unless you specify otherwise, we may share your information with any of our group companies and associated third parties such as our service providers to help us meet these aims.

SUPPLIER DATA: Unless you specify otherwise, we may share your information with any of our group companies and associated third parties such as our service providers and organizations to whom we provide services.

PEOPLE WHOSE DATA WE RECEIVE FROM CANDIDATES AND STAFF, SUCH AS REFEREES AND EMERGENCY CONTACTS: Unless you specify otherwise, we may share your information with any of our group companies and associated third parties such as our service providers and organizations to whom we provide services.

WEBSITE USERS: Unless you specify otherwise, we may share your information with providers of web analytics services, marketing automation platforms and social media services to make sure any advertising you receive is targeted to you.

ALL DATA: Where appropriate and in accordance with local laws and requirements, we may share your personal data, in various ways and for various reasons, with the following categories of people:

Any of our group companies;
Individuals and organizations who hold information related to your reference or application to work with us, such as current, past or prospective employers, educators and examining bodies and employment and recruitment agencies;
Tax, audit, or other authorities, when we believe in good faith that the law or other regulation requires us to share this data (for example, because of a request by a tax authority or in connection with any anticipated litigation);
Third party service providers who perform functions on our behalf (including external consultants, business associates and professional advisers such as lawyers, auditors and accountants, technical support functions and IT consultants carrying out testing and development work on our business technology systems);
Third party outsourced IT and document storage providers where we have an appropriate processing agreement (or similar protections) in place;
Marketing technology platforms and suppliers;
In the case of Candidates: potential employers and other recruitment agencies/organizations to increase your chances of finding employment;
In the case of Candidates: third party partners, job boards and job aggregators where we consider this will improve the chances of finding you the right job;
In the case of Candidates and our Candidates’ and prospective members of Staff’s referees: third parties who we have retained to provide services such as reference, qualification and criminal convictions checks, to the extent that these checks are appropriate and in accordance with local laws;
If SteppingStones merges with or is acquired by another business or company in the future, (or is in meaningful discussions about such a possibility) we may share your personal data with the (prospective) new owners of the business or company.

HOW DO WE SAFEGUARD YOUR PERSONAL DATA?

We are committed to taking all reasonable and appropriate steps to protect the personal information that we hold from misuse, loss, or unauthorised access. We do this by having in place a range of appropriate technical and organizational measures. These include measures to deal with any suspected data breach.

If you suspect any misuse or loss of or unauthorised access to your personal information, please let us know immediately.

HOW LONG DO WE KEEP YOUR PERSONAL DATA FOR?

If we have not had meaningful contact with you (or, where appropriate, the company you are working for or with) for a period of two years, we will delete your personal data from our systems unless we believe in good faith that the law or other regulation requires us to preserve it (for example, because of our obligations to tax authorities or in connection with any anticipated litigation). After this period, it is likely your data will no longer be relevant for the purposes for which it was collected.

For those Candidates whose services are provided via a third-party company or other entity, “meaningful contact” with you means meaningful contact with the company or entity which supplies your services. Where we are notified by such company or entity that it no longer has that relationship with you, we will retain your data for no longer than two years from that point or, if later, for the period of two years from the point we subsequently have meaningful contact directly with you.

When we refer to “meaningful contact”, we mean, for example, communication between us (either verbal or written), or where you are actively engaging with our online services. If you are a Candidate we will consider there to be meaningful contact with you if you submit your updated resume onto our website or take part in any of our online training. We will also consider it meaningful contact if you communicate with us about potential roles, either by verbal or written communication or click through from any of our marketing communications. Your receipt, opening or reading of an email or other digital message from us will not count as meaningful contact – this will only occur in cases where you click-through or reply directly.

HOW CAN YOU ACCESS, AMEND OR TAKE BACK THE PERSONAL DATA THAT YOU HAVE GIVEN TO US?

Even if we already hold your personal data, you still have various rights in relation to it. To get in touch about these, please contact us. We will seek to deal with your request without undue delay, and in any event in accordance with the requirements of any applicable laws. Please note that we may keep a record of your communications to help us resolve any issues which you raise.

Right to object: If we are using your data because we deem it necessary for our legitimate interests to do so, and you do not agree, you have the right to object. We will respond to your request within 30 days (although we may be allowed to extend this period in certain cases). Generally, we will only disagree with you if certain limited conditions apply. You may object to us processing your personal data where we do so for one of the following four reasons: (i) our legitimate interests; (ii) to enable us to perform a task in the public interest or exercise official authority; (iii) to send you direct marketing materials; and (iv) for scientific, historical, research, or statistical purposes.

The “legitimate interests” and “direct marketing” categories above are the ones most likely to apply to our Website Users, Candidates, Clients and Suppliers. If your objection relates to us processing your personal data because we deem it necessary for your legitimate interests, we must act on your objection by ceasing the activity in question unless:

we can show that we have compelling legitimate grounds for processing which overrides your interests; or
we are processing your data for the establishment, exercise or defense of a legal claim.

If your objection relates to direct marketing, we must act on your objection by ceasing this activity.

Right to withdraw consent: Where we have obtained your consent to process your personal data for certain activities (for example, for our marketing arrangements or automatic profiling), you may withdraw this consent at any time and we will cease to carry out the particular activity that you previously consented to unless we consider that there is an alternative reason to justify our continued processing of your data for this purpose in which case we will inform you of this condition.

Data Subject Access Requests (DSAR): You may ask us to confirm what information we hold about you at any time, and request us to modify, update or delete such information. At this point we may comply with your request or, additionally do one of the following:

we may ask you to verify your identity, or ask for more information about your request; and
where we are legally permitted to do so, we may decline your request, but we will explain why if we do so.

If we provide you with access to the information we hold about you, we will not charge you for this unless your request is “manifestly unfounded or excessive”. If you request further copies of this information from us, we may charge you a reasonable administrative cost where legally permissible. Where we are legally permitted to do so, we may refuse your request. If we refuse your request we will always tell you the reasons for doing so.

Please note that we comply with additional local law requirements regarding data subject access requests and may refuse your request in accordance with such laws in relevant jurisdictions.

Right to erasure: In certain situations (for example, where we have processed your data unlawfully), you have the right to request us to “erase” your personal data. We will respond to your request within 30 days (although we may be allowed to extend this period in certain cases) and will only disagree with you if certain limited conditions apply. If we do agree to your request, we will delete your data but will generally assume that you would prefer us to keep a note of your name on our register of individuals who would prefer not to be contacted. That way, we will minimize the chances of you being contacted in the future where your data are collected in unconnected circumstances. If you would prefer us not to do this, you are free to say so.

Normally, the information must meet one of the following criteria:

the data are no longer necessary for the purpose for which we originally collected and/or processed them;
where previously given, you have withdrawn your consent to us processing your data, and there is no other valid reason for us to continue processing;
the data has been processed unlawfully (i.e. in a manner which does not comply with the GDPR);
it is necessary for the data to be erased in order for us to comply with our legal obligations as a data controller; or
if we process the data because we believe it necessary to do so for our legitimate interests, you object to the processing and we are unable to demonstrate overriding legitimate grounds for our continued processing.

Please note that in certain jurisdictions in which we operate, we comply with additional local law requirements regarding data subject right to erasure and may refuse your request in accordance with local laws.

We would only be entitled to refuse to comply with your request for one of the following reasons:

to exercise the right of freedom of expression and information;
to comply with legal obligations or for the performance of a public interest task or exercise of official authority;
for public health reasons in the public interest;
for archival, research or statistical purposes; or
to exercise or defend a legal claim.

When complying with a valid request for the erasure of data we will take all reasonably practicable steps to delete the relevant data.

Right to restrict processing: You have the right to request that we restrict our processing of your personal data in certain circumstances. This means that we can only continue to store your data and will not be able to carry out any further processing activities with it until either: (i) one of the circumstances listed below is resolved; (ii) you consent; or (iii) further processing is necessary for either the establishment, exercise or defense of legal claims, the protection of the rights of another individual, or reasons of important EU or Member State public interest.

The circumstances in which you are entitled to request that we restrict the processing of your personal data are:

where you dispute the accuracy of the personal data that we are processing about you. In this case, our processing of your personal data will be restricted for the period during which the accuracy of the data is verified;
where you object to our processing of your personal data for our legitimate interests. Here, you can request that the data be restricted while we verify our grounds for processing your personal data;
where our processing of your data is unlawful, but you would prefer us to restrict our processing of it rather than erasing it; and
where we have no further need to process your personal data but you require the data to establish, exercise, or defend legal claims.

If we have shared your personal data with third parties, we will notify them about the restricted processing unless this is impossible or involves disproportionate effort. We will, of course, notify you before lifting any restriction on processing your personal data.

Right to rectification: You also have the right to request that we rectify any inaccurate or incomplete personal data that we hold about you. If we have shared this personal data with third parties, we will notify them about the rectification unless this is impossible or involves disproportionate effort. Where appropriate, we will also tell you which third parties we have disclosed the inaccurate or incomplete personal data to. Where we think that it is reasonable for us not to comply with your request, we will explain our reasons for this decision.

Right of data portability: If you wish, you have the right to transfer your personal data between data controllers. In effect, this means that you are able to transfer your SteppingStones account details to another online platform. To allow you to do so, we will provide you with your data in a commonly used machine-readable format that is password-protected so that you can transfer the data to another online platform. Alternatively, we may directly transfer the data for you. This right of data portability applies to: (i) personal data that we process automatically (i.e. without any human intervention); (ii) personal data provided by you; and (iii) personal data that we process based on your consent or in order to fulfil a contract.

Right to lodge a complaint with a supervisory authority: You also have the right to lodge a complaint with your local supervisory authority.

If your interests or requirements change, you can unsubscribe from part or all of our marketing content (for example job role emails or SteppingStones newsletters) by clicking the unsubscribe link in the email.

If you would like to exercise any of these rights, or withdraw your consent to the processing of your personal data (where consent is our legal basis for processing your personal data), please contact us. Please note that we may keep a record of your communications to help us resolve any issues which you raise.

It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during the period for which we hold your data.

WHO IS RESPONSIBLE FOR PROCESSING YOUR PERSONAL DATA ON THE STEPPINGSTONES WEBSITE?

SteppingStones controls the processing of personal data on its website(s).

HOW DO WE STORE AND TRANSFER YOUR DATA INTERNATIONALLY?

In order to provide you with the best service and to carry out the purposes described in this Privacy Policy, your data may be transferred:

between and within SteppingStones entities;
to third parties (such as advisers or other Suppliers to the SteppingStones business);
to overseas Clients;
to Clients within your country who may, in turn, transfer your data internationally;
to a cloud-based storage provider; and
to other third parties

We want to make sure that your data are stored and transferred in a way which is secure. We will therefore only transfer data where it is compliant with data protection legislation and the means of transfer provides adequate safeguards in relation to your data.

To ensure that your personal information receives an adequate level of protection, we have put in place appropriate procedures with the third parties we share your personal data with to ensure that your personal information is treated by those third parties in a way that is consistent with and which respects the law on data protection.

COOKIES POLICY

A “cookie” is a piece of information that is stored on your computer’s hard drive and which records your navigation of a website so that, when you revisit that website, it can present tailored options based on the information stored about your last visit. Cookies can also be used to analyze traffic and for advertising and marketing purposes.

Cookies are used by nearly all websites and do not harm your system. If you want to check or change what types of cookies you accept, this can usually be altered within your browser settings. We also provide information about this in our Marketing preferences page on the SteppingStones website.

We use cookies to do two things:

to track your use of our website. This enables us to understand how you use the site and track any patterns that emerge individually or from larger groups. This helps us to develop and improve our website and services in response to what our visitors want and need; and
to help us advertise jobs to you that we think you’ll be interested in. Hopefully this means less time for you trawling through endless pages and will get you into the employment you want more quickly.

Cookies are either:

Session cookies: these are only stored on your computer during your web session and are automatically deleted when you close your browser – they usually store an anonymous session ID allowing you to browse a website without having to log in to each page but they do not collect any information from your computer; or
Persistent cookies: a persistent cookie is stored as a file on your computer and it remains there when you close your web browser. The cookie can be read by the website that created it when you visit that website again. We use persistent cookies for Google Analytics and for personalization (see below).

Cookies can also be categorized as follows:

Strictly necessary cookies: These cookies are essential to enable you to use the website effectively, such as when applying for a job, and therefore cannot be turned off. Without these cookies, the services available to you on our website cannot be provided. These cookies do not gather information about you that could be used for marketing or remembering where you have been on the internet.
Performance cookies: These cookies enable us to monitor and improve the performance of our website. For example, they allow us to count visits, identify traffic sources and see which parts of the site are most popular.
Functionality cookies: These cookies allow our website to remember choices you make (such as your user name, language or the region you are in) and provide enhanced features. For instance, we may be able to provide you with news or updates relevant to the services you use. These cookies can also be used to remember changes you have made to text size, font and other parts of web pages that you can customize. They may also be used to provide services you have requested such as viewing a video or commenting on a blog. The information these cookies collect is usually anonymized.
Personalization cookies: These cookies help us to advertise details of potential job opportunities that we think may be of interest. These cookies are persistent (for as long as you are registered with us) and mean that when you log in or return to the website, you may see advertising for jobs that are similar to jobs that you have previously browsed.

How to reject cookies:

If you don’t want to receive cookies that are not strictly necessary to perform basic features of our site, you may choose to opt-out by changing your browser settings.

Most web browsers will accept cookies but if you would rather we didn’t collect data in this way you can choose to accept all, or some, or reject cookies in your browser’s privacy settings. However, rejecting all cookies means that you may not be able to take full advantage of all our website’s features. Each browser is different, so check the “Help” menu of your browser to learn how to change your cookie preferences.

For more information generally on cookies, including how to disable them, please refer to aboutcookies.org. You will also find details on how to delete cookies from your computer.