AP Group (”We”) are committed to protecting and respecting your privacy.
Our Group means our subsidiaries, our ultimate holding company and its subsidiaries, our associated companies as defined in The Companies (Guernsey) Law, 2008 (our Group). The AP Group includes AP Personnel, AP Executive, AP Technical and AP Global Energy. AP Group is an international company operating globally. Our offices include jurisdictions outside European Union which have not been deemed adequate for European Union data protection purposes (namely Singapore). However, please note that we operate global data protection policies, and those offices are required to meet the same standard as our other offices. Details of AP Group entities are provided via this link: https://www.apgroupglobal.com/terms-and-conditions/.
All information is processed in accordance with the Data Protection (Jersey) Law 2018, the Data Protection (Bailiwick of Guernsey) Law 2017 and Data Protection (United Kingdom) Act 2018, the General Data Protection Regulation (EU) (2016/679) (“GDPR”) and Data Protection (Cyprus) Law 2018.
Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.
For the purposes of data protection law in force from time to time, the data controller is:
AP Group Ltd
Second Floor, La Tourgand House,
La Tourgand, Lower Pollet
St. Peter Port,
Guernsey, GY1 1WL
Registered in Guernsey No 25920
Tel.: +1481 715757
Who we are and what we do
We are a recruitment agency and recruitment business as defined in the Employment Agencies and Employment Businesses Regulations 2003 (our business). We also provide the following other services; outsourcing, consultancy and payroll. We collect the personal data of the following types of people to allow us to undertake our business;
Prospective and placed candidates for permanent, contract or temporary roles;
Prospective and live client contacts;
Supplier contacts to support our services;
Employees, consultants, temporary workers;
We collect information to carry out our core business and ancillary activities (“Services”).
Information you give to us or we collect about you.
This is information about you that you give us by filling in forms on this website or by corresponding with us by phone, e-mail, social media or otherwise. It includes information you provide when you register to use our sites, to enter our database, subscribe to our services, attend our events, participate in discussion boards or other social media functions on our sites, enter a competition, promotion or surveys and when you report a problem with our sites.
The information you give to us or we collect about you may include your name, address, private and corporate e-mail address and phone numbers, financial information, compliance documentation, references verifying your qualifications, experience and your right to work, curriculum vitae and photograph, links to your professional profiles as available in the public domains e.g. LinkedIn, Twitter, business Facebook or corporate websites and other special category data such as ethnic background, memberships, physical or mental health or conditions, sexual life and any proceedings related to any offence.
The personal data we collect, store and process may include but is not limited to:
Personal contact details such as: name (your full name, previous names, evidence of change of name), addresses, telephone numbers and email addresses
Date of birth
Marital status and dependents
Next of kin and emergency contact information
Residential qualifications, right to work, visa and/or other proof of eligibility for employment in the applicable jurisdiction
Social security number, National Insurance Number or other national social security identification in the applicable jurisdiction
Bank account details, payroll records and tax status information
Salary, annual leave, pension and benefits information
Job position start and end date
Location of employment or workplace
Photo identification, e.g. passport or driving licence
Recruitment information (including copies of right to work documentation, references and other information included in a CV or cover letter or as part of the application process)
Certificates of an academic and/or any professional qualifications obtained
Employment records (including job titles, work history, working hours, training records and other professional memberships).
Performance information, references (details of employment or educational referees)
Disciplinary and grievance information
Other information contained in your CV or that you choose to provide to us;
Information about your use of information and communications systems
Usage data including information about how you use our website and services
Marketing and communications data including your marketing and communication preferences
User profile data including your username and password, your interests, preferences, feedback and customer survey responses
To provide you with work finding services our recruitment consultants will send you job alert emails matching your job search criteria and preferences. From time to time you may also receive job alerts which our consultants consider you may find interesting.
You can stop receiving these job alerts at any time by clicking on the ‘unsubscribe’ link contained in the job alert email.
In a small number of cases (proportionate to the overall database), we may also collect, store and use the following “Special Categories of Data”:
Information about your health, including any medical conditions, health and sickness records
details of disabilities (where provided by you and relevant)
Information about criminal convictions and offences
We may be obliged to disclose unspent convictions and criminal proceedings to our clients so that they can determine if these are relevant to your suitability for a role within their organisation. This information will be retained for no longer than necessary before being deleted.
Information we collect about you when you visit our websites.
With regard to each of your visits to our sites we may collect 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 versions, browser plug-in types and versions, operating systems and platforms, contact information where this is provided publicly by the software or device you use to access our websites;
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-over’s), methods used to browse away from the page, and any phone number used to call our customer service numbers;
certain personal information including your name and contact information (emails, home address and phone numbers). Depending on the nature of your enquiry or activities on our website, we may also ask for your job search criteria and preferences, employment experience, salary, and other background information together with any login ID and password created by you. You can request us to send you job alerts through the website by completing your job search criteria and preferences. You can stop receiving these job alerts at any time by clicking on the ‘unsubscribe’ link contained in the job alert emails.
Information we obtain from other sources.
This is information we obtain about you from other sources such as social media, corporate websites, job board websites, online CV libraries, your business card, personal recommendations, and events.
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. We may receive information about you from them for the purposes of our recruitment services and ancillary support services.
Any personal information we hold will be bound by this Privacy Notice.
Our Clients and Suppliers
If you are a client or supplier or a potential client or supplier, of goods and services we will collect and process information about individuals in your organisation. We may enter the individual’s name and business email address in to our database as a designated corporate point of contact for that organisation, together with the individual’s other business contact data. Usually the only personal information we process about a corporate contact is the individual’s name for the purposes of contacting the organisation in relation to our services and authorising time sheets or the supplier as a recipient of the supplier’s goods and services. If the individual corporate point of contact is also a registered candidate we may be processing additional personal information for work finding and other purposes as described in this Privacy Notice. The source of a corporate point of contact may be the individual themselves. Or their name and business details may be provided to us by a member of their HR or procurement department or another hiring manager or existing business contact or a candidate we have placed at the organisation. We may also obtain these details from websites, social media and other sources. We may send business to business email marketing to corporate points of contacts. An individual corporate point of contact may ask us at any time to stop sending business marketing emails to their business email address by contacting: email@example.com.
Purposes of the processing and the legal basis for the processing
We use information held about you in the following ways:
To carry out our obligations arising from any contracts we intend to enter into or have entered into between you and us. To provide you with the information, products and services that you request from us or we think will be of interest to you because it is relevant to your career or to your organisation.
To provide you with information about other goods and services we offer that are similar to those that you have already purchased, been provided with or enquired about.
The core services we offer to our candidates and clients is the introduction of candidates to our clients for the purpose of temporary, contract or permanent engagements. However, our services expand to supporting individuals throughout their career and to supporting businesses’ resourcing needs and strategies as well as other ancillary activities (listed below).
Our legal basis for the processing of personal data is our legitimate business interests, described in more detail below, although we will also rely on contract, legal obligations and consent for specific uses of data.
We will rely on contracts if we are negotiating or have entered into a placement agreement with you or your organisation or any other contracts to provide services to you or receive services from you or your organisation.
We will rely on legal obligations if we are legally required to hold information on you to fulfil our legal obligations.
Certain categories of the personal data we collect are mandatory to enable us to fulfil our contractual obligations to you or to others. Some other categories of personal data are required by law. Our clients may also require this personal data, and/or we may need your data to enter into contracts with you. If you decide not to provide us with your personal data, we may be unable to fulfil our contractual obligations and may be unable to provide you with our services or engage you to provide us with services.
Other categories of personal data may be mandatory so that we can provide you with services based on our legitimate interests as a recruitment and other business services provider. Where our legal basis for processing your data is based on legitimate business interests, in certain circumstances you have the right to object to us processing your data on this basis.
Our Legitimate Business Interests
Our legitimate interests in collecting and retaining your personal data are described below:
“Legitimate Interests” means the interests of our company in conducting and managing the business to enable to give you the best service/products and the best and most secure experience.
For example, we have an interest in making sure our marketing is relevant for you, so we may process your information to send you marketing that is tailored to your interests.
It can also apply to processing that is in your interests as well.
As a recruitment business and recruitment agency, we introduce candidates to clients for permanent employment, temporary worker placements or independent professional contracts. The exchange of personal data of our candidates and our clients contacts is a fundamental, essential part of this process.
In order to support our candidates’ career aspirations and our clients resourcing needs, we require a database of candidates and client’s personal data. The database will contain historical information as well as current resourcing requirements.
If the candidate is looking for employment opportunities or has provided their CV information and other personal information on a jobs board, professional networking site or directly to us, we think that it is reasonable to assume that the individual is happy for us to collect and otherwise use this personal data to try and assist them by offering or providing recruitment services. This may include sharing that information with clients, third party suppliers and assessing your skills against the job positions that we are recruiting for. We also think that it is reasonable to expect that as the recruitment process progresses, our clients may want to verify the information that candidates have provided to us such as employment history, education and qualifications or they may want the candidates to complete various testing processes (to the extent that this is necessary, appropriate and in accordance with local laws) to ensure that they can pursue their legitimate business interests to recruit the most appropriate candidates for the roles.
We use candidates data in a way which we believe candidates would expect us to use it, given our legitimate business interests as a recruitment and other services provider. The way in which we process your personal data enables us to provide better services, so this is beneficial to all parties.
The core purpose for which we use information about our clients is to enable us to provide our services. We use your data in a way which we believe you would reasonably expect us to use it, given our legitimate interests as a services provider. We believe that the manner in which we process your information is necessary for the purposes of our legitimate interests as an organisation providing you with these services and does not prejudice your rights and freedoms or legitimate interests.
Referees and emergency contacts provided to us by existing data subjects
If you have been listed as a referee by an existing data subject, we will use your personal data to contact you to verify various details. If you have been listed as an emergency contact by an existing data subject, we will use your personal data to contact you in the event of an accident or emergency affecting that individual. We use the data in a way which we believe you would reasonably expect us to use it given our legitimate business interests as a services provider and an employer.
The main purpose for which we use your data while visiting our websites is to optimise and improve your experience. We use your data in a way which we believe you would reasonably expect us to use it given our legitimate business interests to improve our websites’ performance. There is more information on this in the cookies section below.
To maintain, expand and develop our businesses we record, hold and use the personal information you provide for the purposes of providing you with our core services and ancillary services (the "Purposes"). The Purposes include, without limitations:
storing and processing information to better understand your needs and personalising and improving the websites and our products and services;
to respond to any enquiries you have made;
to conduct surveys or promotions;
contacting you if we change our products and services or terms or if we need to give you notice of those terms;
for the purpose of marketing our other products and services to you (by post, telephone, email or other available methods) unless you indicate or subsequently notify us that you do not wish to receive such materials;
for the prevention of fraud;
for any purpose required by law or regulatory authority;
for our accounting purposes.
We may process your information to protect you against fraud when transacting on our website, and to ensure our websites and systems are secure. When we process your personal information for our legitimate interests, we make sure to consider and balance any potential impact on you (both positive and negative), and your rights under data protection laws. Our legitimate business interests do not automatically override your interests - we will not use your Personal Data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). We do not believe that the manner in which we process your personal data prejudices your rights and freedoms or legitimate interests.
Should we want or need to rely on consent to lawfully process your data we will request your consent in writing, orally, by email or by an online process for the specific activity we require consent for and record your response on our system. Where consent is the lawful basis for our processing you have the right to withdraw your consent to this particular processing at any time.
Certain categories of personal data, such as any health data or data relating to any criminal convictions, are processed on the basis that you have provided your explicit consent for us to do so. You can withdraw this consent at any point by contacting us. We may also use your personal data for marketing purposes. We will require your explicit consent in order for us to send this to you. You can withdraw this consent at any time by clicking the ‘unsubscribe’ button at the bottom of the e-mail or by email request to one of our staff.
Other Uses we will make of your data:
Use of our websites;
to notify you about changes to our services;
to ensure that content from our site is presented in the most effective manner for you and for your computer.
We will use this information:
to administer our sites and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
to improve our sites to ensure that content is presented in the most effective manner for you and for your computer;
to allow you to participate in interactive features of our services, when you choose to do so;
as part of our efforts to keep our sites 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 sites about goods or services that may interest you or them.
We do not undertake automated decision making or profiling. We do 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. The final decision will be made by a person according to the parameters set out by the client and/or candidate. This ensures accuracy and suitability.
Disclosure of your information inside and outside of the EEA
AP Group is part of an international group of companies operating globally.
We may share some of your personal information with our groups companies, including AP Group Recruitment Limited in the UK, AP Executive Sarl, based in Switzerland, and other group companies within or outside the Channel Islands, UK and European Economic Area (EEA), who may use and process your Personal Information for similar purposes as described in this Notice. The data protection laws outside the Channel Islands and Europe may not provide an equivalent level of protection to those in the Channel Islands and in these circumstances, we will take steps to ensure that your Personal Information is adequately protected, secure, kept confidential and that we have a lawful basis for the transfer. This means we may require the third-party recipient to sign the EU Model Contract clauses approved by the European Commission as providing personal data with the same protection that your Personal Information has when it is processed within Guernsey/Jersey/UK/EEA.
We will share your personal information with:
Any member of our group both in the EEA and outside of the EEA.
Selected third parties including:
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 contracts we enter into with them or you;
subcontractors including email marketing specialists, event organisers, payment and other financial service providers and administration support services
advertisers and advertising networks that require the data to select and serve relevant adverts to you and others. We do not disclose information about identifiable individuals to our advertisers, but we will provide them with aggregate information about our users (for example, we may inform them that 500 men aged under 30 have clicked on their advertisement on any given day). We may also use such aggregate information to help advertisers reach the kind of audience they want to target (for example, women based in SW1). We may make use of the personal data we have collected from you to enable us to comply with our advertisers’ wishes by displaying their advertisements to that target audience;
analytics and search engine providers that assist us in the improvement and optimisation of our sites;
credit reference agencies, our insurance brokers, compliance partners and other sub-contractors for the purpose of assessing your suitability for ! roles where this is a condition of us entering into a contract with you.
We will disclose your personal information to third parties:
In the event that we sell or buy any businesses or assets, in which case we will disclose your personal data to the prospective sellers or buyers of such businesses or assets.
If AP Group or substantially all of its assets are acquired by third parties, in which case personal data held by it about its customers will be one of the transferred assets.
The lawful basis for the third-party processing will include:
Their own legitimate business interests in processing your personal data, in most cases to fulfil their internal resourcing needs;
satisfaction of their contractual obligations to us as our data processor;
for the purpose of a contract in place or in contemplation;
to fulfil their legal obligations.
Where we store and process your personal data
The data that we collect from you may/will be transferred to, and stored at, a destination in Guernsey, Jersey, UK, within European Economic Area (”EEA”) and outside the EEA. It may be transferred to third parties outside of the EEA for the purpose of our recruitment services. It will also be processed by staff operating outside the EEA who work for us or for one of our suppliers. This includes staff engaged in, among other things, our recruitment services and the provision of support services. By submitting your personal data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy notice.
All information you provide to us is stored on our secure servers. Any payment transactions will be encrypted using SSL technology. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our sites; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
How we protect your personal data
Information that you provide to us is stored on our or our service providers’ secure servers and accessed and used subject to our security policies and standards, or those agreed with our service providers. We align all our service providers to the strictest data protection policies. Our international service providers (some outside of EEA) will be compliant with EU–US Privacy Shield or have an ISO27001 (an internationally recognised certification of information security in line with best practices).
Everyone at AP Group and any third-party service providers processing personal data on our behalf (for the purposes listed above) are also contractually obligated to respect the confidentiality of personal data.
Alongside our role, please also note that where we have given you (or where you have chosen) a password which enables you to access certain parts of our websites or online services, you are responsible for keeping this password confidential and for complying with any other security procedures that we notify you of. We ask you not to share a password with anyone.
Retention of your data
We understand our legal duty to retain accurate data and only retain personal data for as long as we need it for our legitimate business interests and that you are happy for us to do so. Accordingly, we have a data retention notice and run data routines to remove data that we no longer have a legitimate business interest in maintaining.
We do the following to try to ensure all our data is 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
We segregate our data so that we keep different types of data for different time periods. The criteria we use is to determine whether we should retain your personal data includes:
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 roles.
We are required by law to keep basic information about our candidates, clients and customers (including contracts, evidence of identity, and right to work, financial and transaction data) for up to 7 years from when our relationship ends, for legal, compliance and tax purposes.
If you no longer wish to receive our services you can request us to delete your personal information from our candidate database. When we have deleted your data, we may retain your name and email address on our suppression lists and subject to the services we have provided, continue to retain some of your personal information for our legitimate business purposes described in this notice.
Where there is no retention period stated in law, we determine the appropriate retention period for personal information by considering the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorised users or disclosure of the data, the purposes for which we process it and whether we can achieve those purposes through other means, and the applicable legal requirements.
We may archive part or all of your personal data or retain it on our financial systems only, deleting all or part of it from our main Customer Relationship Manager (CRM) systems. We may pseudonymise parts of your data, particularly following a request for suppression or deletion of your data, to ensure that we do not re-enter your personal data on to our databases, unless requested to do so.
For your information, Pseudonymised Data is created by taking identifying fields within a database and replacing them with artificial identifiers, or pseudonyms.
Our current retention notice is available upon request.
You have the right to ask us not to process your personal data for marketing purposes. We will usually inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third parties for such purposes we will collect express consent from you if legally required to do so prior to using your personal data for marketing purposes.
You can exercise your rights to accept or prevent such processing by checking and ticking certain boxes or indicating on the forms we use to collect your data. You can also exercise your rights at any time by contacting us at firstname.lastname@example.org.
Our sites may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for third party policies. Please check these policies before you submit any personal data to these websites.
The Law provides you with the following rights. To:
Request corrections of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
Request erasure of your personal information (right to be forgotten). This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process and store it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below). 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 information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation (i.e. grounds of public interest, historical or scientific purposes) which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which overrides your rights and freedoms.
Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example, if you want us to establish its accuracy or the reason for processing it.
Request the transfer of your personal information to another party in certain formats, if practicable. Note that this right only applies to information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Make a complaint about the processing of your personal information either with us, with the Office of the Information Commissioner in Jersey (https://oicjersey.org), The Office of the Data Protection Authority in Guernsey (https://odpa.gg), the Information Commissioners Office in the UK (https://ico.org.uk) or the data protection authority in the EU member state of your usual residence or place of work.
Where we have relied on consent to process your personal information, you have the right to withdraw consent at any time.
Access to information - Right of Access
The Law gives you the right to access information held about you. We also encourage you to contact us to ensure your data is accurate and complete. Your right of access can be exercised in accordance with the Law. A Subject Access Request (SAR) should be submitted to email@example.com.
Upon receipt of a SAR, we have a period of one month to adhere to the request (an extension of two further months may be sought by us depending upon the complexity and number of requests submitted by the data subject).
Changes to our Privacy Notice
Any changes we make to our privacy notice in the future will be posted on this page. Please check back frequently to see any updates or changes to our privacy notice.
Questions, comments and requests regarding this privacy notice are welcomed and should be addressed to firstname.lastname@example.org.