The General Data Protection Regulation (GDPR) (Regulation (EU) 2016/679) is a new regulation which replaces the Data Protection Regulation (Directive 95/46/EC) The Regulation aims to harmonise data protection legislation across EU member states, enhancing privacy rights for individuals and providing a strict framework within which commercial organisations can legally operate.
Even though the UK has expressed its intention to leave the EU in March 2019, the GDPR will be applicable in the UK from 25th May 2018. The Government intends for the GDPR to continue in UK law post Brexit and has also introduced a Data Protection Bill to replace the current Data Protection Act in due course.
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 legislation the data controller is Oxiway Ltd. We are registered in England and Wales under company number 08286045 having our registered office at R2-12, R104 Rutherford Appleton Laboratory, Harwell Oxford OX11 0QX
Our nominated representative is Vivek Doraiswamy.
Who we are and what we do
We are a recruitment technology company and we may also from time to time provide services such as consultancy. We collect personal data of the following types of people to allow us to undertake our business;
- 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.
Information you give to us or we collect about you.
We collect and process some or all of the following types of information from you:
- Information that you provide by filling in forms on the www.mevitae.com website (“Website”). This includes information provided at the time of registering to use the Website, subscribing to our Services, posting material or requesting further information or services. We may also ask you for information when you report a problem with the Website.
- If you contact Us, We may keep a record of that correspondence.
- We may also ask you to complete surveys that We use for research purposes, although you do not have to respond to them. 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.
- Details of all actions that you carry out through the Website and of the provision of services to you.
- Details of your visits to the Website including, but not limited to, traffic data, location data, weblogs and other communication data, the site that referred you to our site and the resources that you access.
We collect and process some or all of the following types of information from you:
- 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 in the United Kingdom, 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 will automatically 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 version, browser plug-in types and versions, operating system and platform;
- Information about your visit, including the full Uniform Resource Locators (URL) and how you interact with our site.
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 for the purposes of our recruitment services and ancillary support services.
- We may use different methods to collect data from and about you including through:
- Direct interactions. You may give us your Identity and Contact Data by filling in an online form or by corresponding with us by mail, phone, email or otherwise. This includes personal data you may provide when you:
- Ask us to supply you with a product demonstration;
- apply for a job with us;
- request one of our newsletters; or
- provide us with feedback.
- We may receive Identity and Contact Data about you from public sources.
- We may work closely with third parties and other companies, 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.
- Information we receive from third parties. We may receive personal data about you from employers and potential employers who you apply to with our help, who provide us with feedback and decision outcomes relating to your performance during the recruitment process, during internships and/or work placements.
From time to time we also obtain personal data from other sources as follows:
- names and contact details of Customer personnel who will be added as account members for the Customer’s account, may be added by existing account members;
- names and contact details of individual contacts at prospective Customers from third party data providers and/or public sources, such as social networks, company websites and other online sources.
- Information we receive from third parties when you apply for a position directly with that third party. Many employers use MeVitae’s system in the context of their application processes. This means that when you apply for a position with some employers. Your CV are then passed to MeVitae (only with your consent) to help assess job suitability. The results of MeVitae’s data processing are then passed back to the employer who can link the result to your individual application and further assess your application. If you consent to it when you apply for a position directly with a third party which uses MeVitae’s system, the data which MeVitae receives from employers may also be used by MeVitae for further research purposes (e.g. to identify trends).
Any personal information we hold will be bound by this Privacy Notice.
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 and 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.
- 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 obligation and consent for specific uses of data.
- We will rely on contract if we are negotiating 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.
- We will rely on legal obligation if we are legally required to hold information on to you to fulfil our legal obligations.
- We will in some circumstances rely on consent for particular uses of your data and you will be asked for your express consent, if legally required. Examples of when consent may be the lawful basis for processing include permission to introduce you to a client
Our Legitimate Business Interests
Our legitimate interests in collecting and retaining your personal data is described below:
- In order to support our clients’ resourcing needs we require a database of candidate and client personal data containing historical information as well as current resourcing requirements.
- To maintain, expand and develop our business we need to record the personal data of client contacts.
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. Where consent is the lawful basis for our processing you have the right to withdraw your consent to this particular processing at any time.
Other Uses we will make of your data:
- Use of our website;
- to notify you about changes to our service;
- 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 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 and for your computer;
- to allow you to participate in interactive features of our service, when you choose to do so;
- as part of our efforts to keep our site 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.
Disclosure of your information inside and outside of the 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, 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.
- 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 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 advertisement to that target audience;
- 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.
We will disclose your personal information to third parties:
- In the event that we sell or buy any business or assets, in which case we will disclose your personal data to the prospective seller or buyer of such business or assets.
- If Oxiway Limited or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
- If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, and other agreements; or to protect the rights, property, or safety of our company or our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
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 be transferred to, and stored at, a destination outside the European Economic Area (”EEA”). It may be transferred to third parties outside of the EEA for the purpose of our recruitment services. It may/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. 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 site; 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.
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.
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 party for such purposes and we will collect express consent from you if legally required prior to using your personal data for marketing purposes.
Our site may, from time to time, contain links to 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 these policies. Please check these policies before you submit any personal data to these websites.
The GDPR provides you with the following rights. To:
- Request correction 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. This enables you to ask us to delete or remove personal information 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 information where you have exercised your right to object to processing (see below).
- 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 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.
- 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.
- Make a complaint to a supervisory body which in the United Kingdom is the Information Commissioner’s Office. The ICO can be contacted through this link: https://ico.org.uk/concerns/
Access to information
The Data Protection Act 1998 and the GDPR give 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 Act (and the GDPR once it is in force).
A subject access request should be submitted to [email protected] No fee will apply once the GDPR comes into force.
Changes to our privacy notice
Any changes we make to our privacy notice in the future will be posted on this page and, where appropriate, notified to you by e-mail. 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 [email protected]
While using our Service, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you.
Personally identifiable information may include, but is not limited to:
• information that you provide by filling in forms on the Site such as phone number, postal address and other information ("Personal Information");
• records of your correspondence (if any) with us;
• details of transactions you carry out through the Site; and
• details of your visits to the Site including, but not limited to, traffic data, location data, weblogs and other communication data.
We may collect personal identification information from Users in a variety of ways, including, but not limited to, when Users visit our Site, register on the Site, subscribe to the newsletter, respond to a survey, and in connection with other activities, services, features or resources we make available on our Site. Users may be asked for, as appropriate, name, email address, mailing address.
We will collect personal identification information from Users only if they voluntarily submit such information to us. Users can always refuse to supply personally identification information, except that it may prevent them from engaging in certain Site related activities.
We collect information that your browser sends whenever you visit our Service ("Log Data"). This Log Data may include information such as your computer's Internet Protocol ("IP") address, browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages and other statistics.
Personal Information Storage
We adopt appropriate data collection, storage and processing practices and security measures to protect against unauthorised access, alteration, disclosure or destruction of your personal information, Username, password, transaction information and data stored on our Site. Sensitive and private data exchange between the Site and its Users happens over a SSL secured communication channel and is encrypted.
Where we have given you (or where you have chosen) a password that enables you to access certain parts of the Site, you are responsible for keeping this password confidential. You are responsible for safeguarding the password that you use to access the Service and for any activities or actions under your password, whether your password is with our Service or a third party service. You agree not to disclose your password to any third party. You must notify us immediately upon becoming aware of any breach of security or unauthorised use of your account. If we have reason to believe that there is likely to be a breach of security or misuse of the WebSite, we may require you to change your password or we may suspend your account.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will use our best endeavours to protect your personal data, we cannot guarantee the security of your data transmitted to the Site and any transmission is at your own risk. Once we have received your information, we will use suitable procedures and security features to try to prevent unauthorised access.
Uses Made of the Information
We use information held about you in the following ways:
• to ensure that content from the Site is presented in the most effective manner for you and for your computer to improve customer service;
• To provide feedback and use information in the aggregate to understand how our Users as a group use the services and resources provided on our Site;
• to send periodic emails. We may use the email address to send User information and updates pertaining to their order. It may also be used to respond to their inquiries, questions, and/or other requests. If User decides to opt-in to our mailing list, they will receive emails that may include company news, updates, related product or service information, etc.
• to provide you with information regarding our services that you request from us or which we feel may interest you, where you have consented to be contacted for such purposes.
Personal Information Sharing
We do not sell, trade, or rent Users personal identification information to others. We may disclose your personal information to third parties:
• who help us run the Site, solely for the purposes of running the Site and performing the transactions concluded through the Site. These third parties include (but are not limited to) Google Wallet and PayPal (who are our payment processing service providers);
• if we or substantially all of our assets are acquired by a third party, in which case personal data held by us about our customers will be one of the transferred assets;
We may employ third party companies and individuals to facilitate our Service, to provide the Service on our behalf, to perform Service-related services or to assist us in analysing how our Service is used.
These third parties have access to your Personal Information only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.
Our Service does not address anyone under the age of 13 ("Children").
Protecting the privacy of the very young is especially important. For that reason, we do not knowingly collect personally identifiable information from children under 13, and no part of our WebSite is structured to attract anyone under 13. If you are a parent or guardian and you are aware that your Children has provided us with Personal Information, please contact us. If we discover that a Children under 13 has provided us with Personal Information, we will delete such information from our servers immediately.
Credit and Debit Card Details
Cookies are files with small amount of data, which may include an anonymous unique identifier. They help us to improve the Site and to deliver a better and more personalised service. Cookies are sent to your browser from a Site and stored on your computer's hard drive for record-keeping purposes and sometimes to track information about them. Cookies will in no way cause spam, viruses, or spyware.
We use the following cookies:
Strictly necessary cookies. These are cookies that are required for the operation of our Site. They include, for example, cookies that enable you to log into secure areas of our WebSite, make use of e-billing services or synchronise your login status between the forum section of the Site and the other sections of the Site.
Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around our Site when they are using it. This helps us to improve the way our Site works, for example, by ensuring that Users are finding what they are looking for easily.
The Site uses Google Analytics to help analyse how Users use the WebSite, collecting standard internet log information and visitor behaviour information in an anonymised form from which no User is identifiable. This information is transmitted to Google and processed to compile statistical reports on activity on the Site. These reports allow us to optimise our User experience. Google provide a browser add-on for Users who wish to prevent their data from being used by Google Analytics. Further information is available at https://tools.google.com/dlpage/gaoptout/.
Functionality cookies. Most cookies we use are known as session cookies. It allows us to remember your details during your current visit to the Site and automatically logs Users in if their session cookie has expired. This allows you to navigate away from the Site and then return to the Site in the same browsing session.
Targeting cookies. These cookies record your visit to our Site, the pages you have viSited and the links you have followed. We will use this information to make our Site and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.
Session cookies will expire whenever you close your browser or shut down your computer, and such cookies need not be blocked. Other cookies used for specific purpose will expire when that purpose is no longer required. These are used to recognise you when you return to our Site. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
You can find out more about blocking cookies in specific browsers at http://aboutcookies.org.
You have the right to ask us not to process your personal data for marketing purposes. You can exercise your right to prevent such processing by contacting us at [email protected]
The Site 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 these policies. Please check these policies before you submit any personal data to these WebSites.
Access to Information
The Act gives you the right to access information held about you. Your right of access can be exercised in accordance with the Act. Any access request may be subject to a fee of £10 to meet our costs in providing you with details of the information we hold about you.
Acceptance of Terms
By using this Site, you signify your acceptance of this policy. If you do not agree to this policy, please do not use our Site. Your continued use of the Site following the posting of changes to this policy will be deemed your acceptance of those changes.