Privacy Policy

Middleton Croft Limited (trading as Croft & Co) respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from), and tell you about your privacy rights and how the law protects you.

1. Important information and who we are

Privacy policy
This privacy policy gives you information about how Croft & Co collects and uses your personal data belonging to you or your personnel in the context of providing services to you or your business, through your use of the Croft & Co website and through any of the other ways we interact, as set out in more detail in paragraph Error! Reference source not found. below.

Controller
‍Middleton Croft Limited (trading as Croft & Co) is the controller and responsible for your personal data (collectively referred to as Croft & Co, we, us or our in this privacy policy).

2. The personal data we collect about you

Information you give to us or we collect about you.
This is information about you that you give us by filling in forms on our site or by corresponding with us by phone, e-mail or otherwise. It includes information you provide when you register to use our site, to enter our database, subscribe to our services, attend our events, participate in discussion boards or other social media functions on our site, enter a competition, promotion or survey, and when you report a problem with our site.The information you give us or we collect about you may include your name, address, private and corporate e-mail address and phone number, financial information, compliance documentation and references verifying your qualifications and experience and your right to work, curriculum vitae and photograph, links to your professional profiles available in the public domain e.g. LinkedIn, Twitter, business Facebook or corporate website.

Information we collect about you when you visit our website
With regard to each of your visits to our site we may automatically collect some or all of the following information:

technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information if applicable, browser type and version, browser plug-in types and versions, operating system and platform; 
information about your visit, including the full Uniform Resource Locators (URL),clickstream to, through and from our site (including date and time), products you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, and any phone number used to call our customer service number.

Information we obtain from other sources.
This is information we obtain about you from other sources such as LinkedIn, corporate websites, job board websites, online CV libraries, your business card, personal recommendations, and others.We are working closely with third parties including companies within our Group, business partners, sub-contractors in technical, professional, payment and other services, advertising networks, analytics providers, search information providers, credit reference agencies, professional advisors and others. We may receive information about you from them for the purposes of our recruitment services and ancillary support services.

If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of our engagement with you (as set out in our engagement letter and terms of business, and you fail to provide that data when requested, we may not be able to perform the services set out in the engagement letter.

3. How we use your personal data

Legal Basis
The law requires us to have a legal basis for collecting and using your personal data. We rely on one or more of the following legal bases:

Contractual obligations: Where we have negotiated or have entered into a placement agreement with you or your organisation or any other contract to provide services to you or receive services from you or your organisation.
Legitimate interests: As a recruitment business and recruitment agency, it is necessary for our legitimate interests to collect and retain your data, as we introduce clients for permanent employment, temporary worker placements or independent professional contracts. The exchange of personal data of our candidates and client contact details is fundamental to this process. To further support candidates’ aspirations and our clients’ resourcing needs, we require a database of candidate and client personal data. The database will contain historical information as well as current resourcing requirements. To maintain, expand and develop our business we need to record the personal data of prospective candidates and client contacts.
Legal obligation: Where we need to comply with a legal obligation to which we are subject.
Consent: We rely on consent only where we have obtained your active agreement to use your personal data for a specified purpose, for example when we process your data for marketing purposes. Should we want or need to rely on consent to lawfully process your data we will request your consent orally, by email or by an online process for the specific activity we require consent for and record your response on our system.[AC1] [BH2] Where consent is the lawful basis for our processing you have the right to withdraw your consent to this particular processing at any time.

Purposes for which we will use your personal data
We are a recruitment agency and recruitment business as defined in the Employment Agencies and Employment Businesses Regulations 2003 (our business). We collect the personal data of the following types of people to allow us to undertake our business;

Prospective and placed candidates for permanent or temporary roles;
Prospective and live client contacts;
Supplier contacts to support our services;
Employees, consultants, temporary workers;

We collect information about you to carry out our core business and ancillary activities.

We have set out below some additional uses of your data:

To manage our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
To improve our site to ensure that content is presented in the most effective manner for you when you are using your computer or other devices;
To inform you about changes to our service;
To allow you to participate in interactive features of our service, when you choose to do so;
To ensure out site is safe and secure
To measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you;
To make suggestions and recommendations to you and other users of our site about goods or services that may interest you or them.

We do undertake automated decision making or profiling. We use our computer systems to search and identify personal data in accordance with parameters set by a person. A person will always be involved in the decision making process. If automated decision making or profiling is used, we will provide information about how decisions are made, the significance and the consequences of the decision making.

Direct marketing
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).You will receive marketing communications from us if you have requested information from us or purchased goods or services from us and you have not opted out of receiving that marketing.

Third-party marketing
We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

Opting out of marketing
You can ask us or third parties to stop sending you marketing messages at any time by contacting us at any time.

If you opt out of receiving marketing communications, you will still receive service-related communications that are essential for administrative or customer service purposes for example relating to appointment reminders, or checking that your contact details are correct.

4. Disclosures of your personal data

We may share your personal data with the parties set out below for the purposes set out above.

Clients for the purpose of introducing candidates to them;
Candidates for the purpose of arranging interviews and engagements;
Clients, business partners, suppliers and sub-contractors for the performance and compliance obligations of any contract we enter into with them or you;
Subcontractors including email marketing specialists, event organisers, payment and other financial service providers;
Analytics and search engine providers that assist us in the improvement and optimisation of our site;
Credit reference agencies, our insurance broker, compliance partners and other sub-contractors for the purpose of assessing your suitability for a role where this is a condition of us entering into a contract with you;
External companies who provide technical services, such as website hosting or cloud-based IT services;
Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

5. International transfers

Certain of the parties to whom we disclose your personal information as described above may be outside the UK.
Whenever we transfer your personal data out of the UK, we endeavour to do so to countries that have been deemed by the UK to provide an adequate level of protection for personal data. However, this may not always be possible and where we do transfer your personal data to countries which have laws that do not provide the same level of data protection as the UK law, we always ensure that a similar degree of protection is afforded to it by ensuring that transfers are subject to specific standard contractual terms approved for use in the UK which give the transferred personal data the same protection as it has in the UK, namely the International Data Transfer Agreement.

6. Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

7. Data retention

How long will you use my personal data for?
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.In some circumstances you can ask us to delete your data: see paragraph 7 below for further information.In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.We segregate our data so that we keep different types of data for different time periods. The criteria we use to determine whether we should retain your personal data include:

the nature of the personal data;
its perceived accuracy;
our legal obligations;
whether an interview or placement has been arranged; and
our recruitment expertise and knowledge of the industry by country, sector and job role.

We may store and handle your data in the following ways:

We may archive part or all of your personal data, retain it on our financial systems only or delete all or part of the data from our main Customer Relationship Manager (CRM) system.

We may pseudonymise parts of your data, particularly following a request for restriction or erasure of your data, to ensure that we do not re-enter your personal data on to our database, unless requested to do so.

Accuracy of data
We do the following to try to ensure that the data we hold on you is accurate:

our website enables you to manage your data and to review whether the details we hold about you are accurate;
prior to making an introduction we check that we have accurate information about you;
we keep in touch with you so you can let us know of changes to your personal data.

8. Your legal rights

You have rights under data protection laws in relation to your personal data to:

Request access to your personal data (commonly known as a "subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data in certain circumstances. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) as the legal basis for that particular use of your data (including carrying out profiling based on our legitimate interests). In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your right to object.
You also have the absolute right to object any time to the processing of your personal data for direct marketing purposes (see Opting out of marketing in paragraph Error! Reference source not found. for details of how to object to receiving direct marketing communications).
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in one of the following scenarios:
If you want us to establish the data's accuracy;
Where our use of the data is unlawful but you do not want us to erase it;
Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

If you wish to exercise any of the rights set out above, please contact us (see Contact details (paragraph Error! Reference source not found.).

No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it could 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.

9. Contact details

If you have any questions about this privacy policy or about the use of your personal data or you want to exercise your privacy rights, please contact us in the following ways:

Email address: info@croftandco.com
Postal address: Windover House, 26 St Ann St, Salisbury SP1 2DR, United Kingdom
Telephone number: +442045247400

10. Complaints

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

11. Changes to the privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review. [This version was last updated on 11.04.2024. [Historic versions [are archived here: [LINK] OR can be obtained by contacting us]].]It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us, for example a new address or email address.

12. Third-party links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.