EFFECTIVE DATE: 10th July, 2019
If you want to contact FRG or any of its group companies, please click here.
This Privacy Notice sets out the basis on which we collect, store, use and disclose personal data we receive in writing, through our Websites, or through the recruitment services that we provide. It therefore applies to personal data that you provide to FRG telephonically, electronically (including email) and in person.
This information may be updated from time to time, and should be read in the context of any additional specific information such as that provided in privacy policies applicable to specific businesses or local areas as displayed on the relevant Website or distributed to you from time to time.
This Privacy Notice also informs you how we obtain and use information gained by us through your use of the Websites, including by using “cookies” and third party vendors.
Please read the following carefully to understand our views and practices regarding your personal data, how we will treat it and your rights. You can contact FRG’s Chief Privacy Officer (“CPO”) by emailing firstname.lastname@example.org.
This Privacy Notice applies to FRG globally. The first part of the policy is general and applies globally. The second of the Privacy Notice is comprised of country-specific addendums. Please be sure to check the addendums below to see if there is one that applies to your country. In the event of a conflict between the general part of this Privacy Notice and an addendum, the addendum prevails.
2. Who are we?
FRG is a global niche technology recruitment company that operates under the brands listed above. FRG offers recruitment services for permanent hiring and contract or temporary services.
III. Who does this Privacy Notice protect?
This Privacy Notice protects individuals throughout the world who access our Websites or receive recruitment services from us. In addition to candidates who are looking for a new or different job or career, this also includes individuals who are employed by an actual, former or prospective FRG client. An FRG client is one of (a) a business that FRG has contracted with to provide recruitment services or is in the process of doing so, (b) a business that FRG may solicit with the intention of providing recruitment services or (c) a business to whom FRG may provide relevant IT market information.
1) What information will we collect?
Some of the data that we collect and receive from you is personal data which means that it is information that could personally identify you (“Personal Data” or “PII”). The Personal Data that we may collect from all users of our Websites and users of our recruitment services may include any of the following:
Contact details e.g. street address, email address, telephone number;
Education & Qualifications;
Right to work status \ citizenship;
Other information relevant to help us provide recruitment services;
References from past employers; and
For Contract Candidates Only (individuals who are employed by, consult with and/or own an entity recruited by FRG to provide contract or temporary technical professional services to an FRG client (or an FRG client’s client))
In addition to the Personal Data listed above, FRG may collect the following from you:
Tax details and proof of payment and submission;
Commercial insurance information; and
Bank and payment details.
While this information may relate to your company or your employer rather than being your Personal Data, we have listed this information for transparency.
If your provision of Personal Data to FRG is necessary to enter into a contract with your company or your employer, your failure to provide us with accurate Personal Data may result in FRG not being able to offer or render recruitment services to you, your company or your employer.
2) Why do we process your Personal Data?
Generally, we use your Personal Data for our business and activities, and in our efforts to expand and improve our business. Examples include:
All users of the Websites and/or our services
To provide our recruitment services to you, your employer or your company;
To facilitate the recruitment process, including but not limited to:
Qualifying and submitting candidates;
For clients, negotiating FRG terms of business;
Arranging interviews and obtaining feedback;
Negotiating compensation packages; and
Providing post placement follow up.
To assess data about you against vacancies which we judge may be suitable for you;
To enable you to submit your CV/resume to FRG, apply online (including through the Websites) for jobs or to subscribe to alerts about jobs we think may be of interest to you;
To enable us to develop and market other products and services and where you have consented to being contacted for such purposes;
To improve our customer service and to make our services more valuable to you (including tailoring the Websites when you log on to enrich your personal online experience);
To send you electronically or by post surveys, reports, FRG event details, promotions, offers, networking and client events and general information about relevant industry sectors which we think might be of interest to you, where you have consented to being contacted for such purposes (and we will provide you with an opportunity to opt out);
To identify you, and respond to and process your requests for information and provide you with a product or service;
To amend records to remove personal information;
To use your information on an anonymised basis to monitor compliance with our equal opportunities policy, other FRG policies and any legal or compliance requirements;
To use your information on an anonymised basis to create marketing materials such as a salary survey; and
To carry out our obligations arising from any contracts entered into between you and us, and for other everyday business purposes that involve use of Personal Data.
Actual or Prospective Candidates
To help find you or your company a job;
To contact you (permanent hire candidates), your employer or your company (contract candidates) about jobs that FRG is filling or may fill for FRG clients;
To provide you or your company with information about the job market;
To communicate with you (permanent hire candidates), your employer or your company (contract candidates) after you or it has started a job to make sure all is going well or to remedy, or attempt to remedy, any problems;
To answer any questions you have about a job or the job market;
To fulfill any aspect of your employer’s or your company’s contract with FRG (for contract candidates only);
To collect any money due, or allegedly due, to FRG or any FRG client (or FRG’s client’s client);
To obtain or inquire about any property (including computers and confidential business information) owned, or allegedly owned, by FRG or any FRG client (or FRG’s client’s client);
To establish, exercise or defend any legal claims; and
To assist you (permanent hire candidates), your employer or your company (contract candidates) if you are dissatisfied or dislike the job, or any aspect of it.
Individuals who work for FRG clients (i.e. a “client contact”)
To fill an open vacancy at your company or employer;
To contact you about candidates for jobs with whom FRG has a relationship;
To provide you with information about the job market;
To communicate with you after your company or employer has hired/retained an FRG candidate to make sure all is going well and to remedy, or attempt to remedy, any problems;
To negotiate and fulfil any aspect of your company’s or employer’s contract with FRG;
To answer any questions you have about a job or a candidate or your company’s or employer’s contract with FRG;
To resolve any issue with the issuance, payment, collection or enforcement of an FRG invoice;
To collect any property owned by FRG or any FRG candidate;
To establish, exercise or defend any legal claims.
3) Who do we send your Personal Data to?
All users of the Websites and/or our services
To third parties where we have retained them to provide services that we or you have requested or that FRG clients have requested including references, qualifications and background reference checking services and to verify the details you have provided from third party sources.
To third parties to provide data storage, CV/resume parsing, data cleansing and marketing (via email & SMS, standard SMS and text rates may apply) services to FRG where such third parties have agreed to maintain the confidentiality of, and to protect, your Personal Data in accordance with applicable law.
To third parties to assist with credit control and payment management
To third parties, regulatory or law enforcement agencies if we believe in good faith that we are required by law to disclose it in connection with the detection of crime, the collection of taxes or duties, in order to comply with any applicable law or order of a court of competent jurisdiction, in connection with legal proceedings or other similar cause or circumstance.
To FRG affiliates, whose locations can be found at https://www.frankgroup.com/contact in order that they may process your Personal Data in accordance with this Privacy Notice.
In the event of a sale, merger, liquidation, receivership or transfer of all or substantially all of the assets, or a controlling interest in the equity, of FRG (or any of its group companies) provided that such counterparty(ies) to any such transaction agrees to adhere to the terms of this Privacy Notice (or a similar document) and applicable law.
Actual or Prospective Candidates
To FRG clients in order for them to determine if you (permanent hire candidate) or your company or employer (contract candidate) are or may be qualified to fill a vacancy.
Individuals who work for FRG clients (i.e. a client contact)
To candidates in the course of providing your company or employer with recruiting services and to further the recruitment process.
To third parties where we have retained them to provide services that you have requested including candidate skill tests and other testing.
VII. What will FRG do if my Personal Data is breached?
FRG has put in place reasonable technical, administrative and physical safeguards intended to prevent a breach of your Personal Data. That being said, FRG cannot guarantee that your Personal Data will not be breached.
A breach can take many forms, including, without limitation, the loss of your Personal Data or the unauthorized access to, disclosure, modification, copying and transfer of your Personal Data.
Once FRG becomes aware of the breach, FRG will take reasonable steps to isolate the breach, stop the breach, determine the root cause, determine the Personal Data breached, fix the root cause and determine if notice to you and/or the appropriate government agency(ies) is required. FRG will comply with all applicable law in reacting to, and dealing with, a breach of Personal Data.
If you believe, for any reason, that your Personal Data has been breached while in FRG’s care, custody or control, please email FRG immediately at email@example.com.
VIII. Will my Personal Data be transferred to another country?
Yes, FRG may transfer your Personal Data to the categories of third parties described in this Privacy Notice, some of whom are located outside of the country in which you provided your Personal Data to FRG or the country of collection.
If so, FRG will take reasonable steps to ensure that your Personal Data is protected and treated in accordance with this Privacy Notice and local applicable law. The countries where FRG may transfer your Personal Data will have varying levels of data security practices and laws, some of which may be less stringent or protective than your country. FRG will use all reasonable efforts to require that any of its suppliers and vendors who receive your Personal Data are contractually bound to (a) keep your Personal Data confidential and (b) take, at a minimum, reasonable efforts to maintain the privacy and security of your Personal Data.
Under certain circumstances, FRG may share your Personal Data with one or more of its group companies who may be located in a country other than yours or other than the country in which FRG collected your Personal Data. In such cases, FRG will comply with applicable laws and its Intercompany Data Processing Agreements (“DPAs”). The DPAs are incorporated by reference into this Privacy Notice.
1) How long will FRG store my Personal Data for?
We are required by applicable law to store your Personal Data for as long as is necessary to comply with our legal, regulatory and contractual obligations. This period of time will vary based on the law in your country and in the country where FRG stores your Personal Data.
In addition, FRG will keep your Personal Data for the identified purposes until it reasonably believes that it no longer needs it, that there is no reasonable chance that you, your employer or your company will do business with FRG, and there is no reason to believe that we will need the Personal Data for any special circumstances such as the issuance or defence of legal proceedings, audit, investigation or collections.
a) Sending FRG Personal Data over the internet
Your Personal Data is held on servers hosted by us, our internet services providers or third party vendors with whom FRG has a contract. The transmission of information via the internet is not completely secure. Although we will take the efforts set forth in the Privacy Notice to protect your Personal Data, we cannot guarantee the security of any data transmitted through or to our Websites. Any transmission of data by you to us over the internet is at your own risk.
b) How we collect and aggregate information about visitors to our Websites
We also collect information about the way job seekers and visitors use the Websites in order to improve our services, to understand our users better, and to determine aggregate trends, most popular pages, etc. By using the Websites, you agree that we may share de-identified aggregate data with selected third parties to assist with these purposes. We may also undertake marketing profiling to help us identify candidates, clients, or jobs which may be of interest to you. We may process Personal Data that you submit to us through the Websites under one or more of the permissible bases for processing Personal Data set forth in the Privacy Notice.
XII. Technology and Tools
Like many companies, we use technology and tools that tell us when a computer or device has visited or accessed our content. Those tools include services from search engines and other companies that help us to tailor our products and services to better suit our customers and potential customers. Search engines provide facilities to allow you to indicate your preferences in relation to the use of those tools in connection with computers and other devices controlled or used by you.
We also set out further information below about Cookies and Web Beacons.
1) What are cookies?
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 to you based upon the stored information about your last visit. You can normally alter the settings of your browser to prevent acceptance of cookies.
Cookies are used are many, many websites, including FRG’s Websites.
We use “cookies” and plug ins to: (1) make the Websites function properly and as a user would normally expect of a commercial website, (2) monitor Website user traffic patterns and Website usage.; and (3) help us to advertise to you jobs we think you, your company or your employer will be interested in. Our use of these tools helps us to understand how our users use our Websites so that we can develop and improve the design, layout and functionality of the Websites and to provide more efficient and relevant services to you.
C. There are different kinds of cookies with different functions.
The cookies we use are explained below:
Session cookies: these are only stored on your computer during your web session. They are automatically deleted when the browser is closed. They usually store an anonymous session ID allowing you to browse a website without having to log in to each page. They do not collect any information from your computer.
Persistent cookies: a persistent cookie is one 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.
Strictly necessary cookies
These cookies are essential to enable you to use the Websites effectively and therefore cannot be turned off. Without these cookies, the services available to you on our Websites 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.
These cookies enable us to monitor and improve the performance of our Websites. For example they allow us to count visits, identify traffic sources and see which parts of the Websites are most popular. These cookies do not collect information that identifies a visitor, as all information these cookies collect is anonymous and is only used to improve how our Websites work.
These cookies allow our Websites to remember choices you make (such as your user name, language or the region you are in) and provide enhanced features. These cookies can also be used to remember changes you have made to text size, font and other pages of our Websites that you can customise. They may also be used to provide services you have requested such as viewing a video or commenting on a blog.
The FRG Websites use personalisation cookies to help us to advertise jobs that we think may be of interest to you. These cookies are persistent and mean that when you log in, or return to, the particular FRG Website, you may see advertising for jobs that are similar to jobs that you have previously browsed.
For information on how to reject these personalisation cookies, see Section E below
1) Cookies and Plug-ins set by FRG or Third Parties used by FRG
Please note that we use some plug-ins on the Websites that do not collect or give us your PII. For security reasons, we have omitted those plug-ins from the chart below.
Used by us to provide helpful career and hiring advice
Maximum of 100 days
Thrive Quiz Builder
Same as above including the use of quizzes to obtain information from users.
Maximum of 30 days
Email Subscriptions and Newsletters
Used by us to send news articles and features to user. You will only receive these articles and features if you opt in to the service.
Plug in. Does not collect your PII unless you enter your PII.
This is a social media plugin and allows users to share content that they elect to share.
Session cookies expire after browser closure, persistent cookies stay until the user deletes them.