Privacy Policy

Last Reviewed and Updated: 1st October 2024

The following privacy policy applies if you access our services via a web browser.  www.hatch-digital.com (“the Website”) is a jobs site operated by Hatch Digital Skills Ltd

Hatch Digital Skills Ltd is committed to safeguarding the privacy of all our customers, this Privacy Policy outlines how we use the personal information we collect from you, how we process it, your rights in relating to your personal information, and how to contact us or a supervising authority should you need to.

Hatch is a trading style of Hatch Digital Skills Ltd:

Hatch Digital Skills Ltd | Company No: 11973450 | VAT No: 327 1831 11 | Address: 167-169, Great Portland Street, Fifth Floor, London, England, W1W 5PF | ICO: ZA526911

What we do

Registration with and use of the Website for job seekers and companies looking to purchase our services is free.  When you register for a job opportunity, you engage with us to provide you with recruitment services.  The services include us updating you in the process of matching you to relevant vacancies which may be of interest to you.  These updates maybe be communicated to you via email, SMS, telephone, or push notification.  These communications may include job vacancies details and information about third party companies we are acting on behalf of and when you express an interest in the communications you may be taken to the website of our third-party partners without needing to log in to your Hatch account first.

If you do not want to receive that information from us, we give you the opportunity to opt out both as part of the registration process and at any time by updating your contact preferences in your account or by clicking the “unsubscribe” link within any of the communications.

Lawful basis

Legitimate interest.

We operate our Policy subject to the UK’s Data Protection Act 2018 and the UK General Data Protection Regulation (UK GDPR).  We may act as a Data Controller or a Data Processor depending on the services that we are providing you.

We process your personal data when it is in our legitimate interests to do this in order to provide our services.  Our legitimate interests include (but are not limited to); introducing job seekers to third party companies we partner with to fulfil job vacancies or to provide services including training and data validation; communication of job alerts and opportunities; the measures we take in order to ensure security and integrity of the services we provide; promoting, marketing and advertising of our products and services; analysis of our users’ behaviour, activities, preferences and requirements including anonymised social impact data; feedback of existing products and services and the development of new products and services; the handling of customer contacts, queries and complaints; making available the service through the Website to our users (companies we recruit for, job seekers, those interested in learning more about our products and services: the sharing of personal data with our third party partners and suppliers who act as our data processors to enable us to provide our services.

Primarily the lawful basis applied to the collection and processing your information will be our mutual intent to create and fulfil a contract, which will include a reasonable period during which there is relevant contact and marketing activity.

There may be times when a contract is not created, and we may still process personal information for marketing purposes, in these instances we will ask you for consent.

In some circumstances we may have a legal obligation to collect and process your information e.g. detecting, preventing or investigating crime or fraud including working with law enforcement agencies or other governmental departments or services.

On some occasions we may process your personal data with your consent.  When your consent is required, we will clearly indicate this (for example when we share your CV with third party partners we are recruiting for).  You have the right to withdraw your consent at any time.  When you do so, we will cease to process such data.

Our privacy framework

As part of our commitment to ensure your personal information is protected and processed lawfully, we adopt the following privacy principles:

• We will only request and store the personal information we require to provide you with our products and services, including those you may be interested in, or where we have a legal obligation.
• We will only request and store special category personal information, including health and financial information when you request a related service or where we have a legal obligation.
• We will only share information with third parties as set out within this Privacy Policy.
• We will use personal information provided to us in accordance with this Privacy Policy.

The information we collect

The information we collect from you will vary depending on the services we are providing. We may collect and store the following types of personal information:

• The information set out in your CV.
• Information about how you use our websites. Including your IP address, geographical location, browser type, referral source, length of visit and number of page views.
• Information that you provide to us for the purpose of engaging our products and services and when requesting contact from Including name, email address, date of birth, address, and telephone number.
• General identification and contact information for example your name, IP address, residential address, email and telephone details.
• Information required to deliver our training and recruitment products and services, which may include education and employment history, psychometric testing results, your personal and professional interests, and your online presence.
• Marketing preferences.
• Anonymous aggregated statistical information e.g. information related to communicating the social impact of the products and services we offer, including gender, race / ethnicity, preferred pro-noun, age and disability supporting our mission to support equality of opportunity in employment. This data is captured through voluntary disclosure in addition to your consent.
• Special category information required to provide our services, including financial products, and conviction information where required for safeguarding or by law.
• We may also request, but you are not obligated to provide, health information allowing us to facilitate special considerations or adjustments, and gender information allowing us to maintain our equal opportunities policy.
• Any further information that you choose to send to us.

We collect the personal data about you when you register or apply for an opportunity with us.  We also collect personal data throughout our candidate process when you complete data capture forms specific to job opportunities or during interviews.  If you choose to upload a CV, complete an assessment, cover letter, data capture form, personal statement or other similar document or information we will keep that for as long as you want to keep your information with our service or on our website.  We will keep a record of your assessment results and responses.

Special category data

Additional protections exist under data protection law for certain types of information – otherwise called special category data.

We may request special category data in the following circumstances:

• Where our services carry a duty of care to enquire about health conditions that might be relevant. There is no obligation for you to provide health information to us, but it may affect the service we can make available.
• Subject to The Rehabilitation of Offenders Act 1974 (Exceptions) Order 1975 we may ask you to disclose offences related to sexual or violent offences, when your training, placement, or recruitment could bring you into contact with persons under the age of 18 or vulnerable adults.

How do we use your personal information?

Job seekers

By registering with our Website or applying for one of our opportunities it is understood that job seekers are actively soliciting contact from us or from prospective employers about opportunities which match your interests. We will use personal information to:

• Contact you regarding your application or enquiry.
• Provide you with our products and services, including passing necessary information to third parties who form part of the products or We may not be able to provide products or services if you do not disclose the required personal information.
• Given the lawful basis detailed above: provide marketing communications, relating to our business, which are relevant to the product and service engaged by yourself. This may be by post, email, telephone, push notification or similar technology.
• Provide and service financial products, including but not limited to, application for credit, account maintenance, notification of changes to accounts, debt collection, and legally or regulatory required communications.
• Administer our website.
• Provide third parties with statistical information about our users – this information will never be provided in a format which can be used to identify any individual.
• Analyse and profile your information to identify trends and to tailor our communications and services, including preventing you from receiving unwanted material.
• Aggregated or meta data may be used to identify trends and for gap analysis. In these instances, the data will be anonymised and not attributable to an individual.

Information Retention

We will not keep personal information for longer than is necessary. However, the length of time information is retained will depend on the type of information and the contractual relationship we have in place with you. As standard, we retain personal information for up to five years, unless we are otherwise instructed to erase or remove information under your ‘rights to erasure’:

You have the right to have your data erased, without undue delay, by the data controller, if one of the following grounds applies:

1. Where your personal data are no longer necessary in relation to the purpose for which it was collected or processed.
2. Where you withdraw your consent to the processing and there is no other lawful basis for processing the data.
3. Where you object to the processing and there is no overriding legitimate grounds for continuing the processing (see point 6 below).
4. Where you object to the processing and your personal data are being processed for direct marketing purposes (see point 6 below).
5. Where your personal data have been unlawfully processed.
6. Where your personal data have to be erased in order to comply with a legal obligation.
7. Where your personal data have been collected in relation to the offer of information society services (e.g. social media) to a child.

Our record retention policy is regularly reviewed and updated to ensure we anonymise or delete information that is no longer required.

Third parties we work with

Personal information will be shared with third parties where necessary to:

• Fulfil our contract for product and services.
• Service financial agreements.
• Where you have opted in to receive marketing material from our third party partners.

We employ a robust due diligence process when choosing to work with a third-party. This includes ensuring they have the same high standards in processing your information as we do.

We will share your personal data with various parties, in various ways and for various reasons. Primarily we will share your information with prospective employers to increase your chances of securing the job you want. Unless you specify otherwise, we will also share your information with any of our group companies and associated third parties such as our service providers and selected job aggregators where we feel this will help us to provide you with the best possible service and maximise your chances of getting what you want. Our current network of named companies we may share your information with for the purposes of securing you the job you want include giffgaff, Roke, Capgemini, NTT DATA UK, and QinetiQ. This network is subject to change, please contact Hatch for an exhaustive list at any given time. 

Should you require details of any of our third parties and their privacy policies, these can be requested by contacting us at:

enquiries@hatch-digital.com

Technology partners

Our technology and learning management system partners form an integral part of our training and recruitment services.

Our key partners and their privacy policies are:

• TCS iON – Privacy Policy
• Microsoft Learn – Privacy Policy
• UCertify – Privacy Policy
• LinkedIn Learning – Privacy Policy

Additional disclosures

We may disclose information about our customers to any of our employees, officers, agents, suppliers, or subcontractors insofar as reasonably necessary for the purposes set out in this privacy policy.

In addition, we may disclose information in the following circumstances:

• When we are required to do so by law.
• In connection with legal proceedings or prospective legal proceedings.
• To establish, exercise or defend our legal rights (Including providing information to others for the purposes of fraud prevention, anti-money laundering and reducing credit risk).
• For the purposes of litigation.
• To provide regulatory bodies with reports if a breach in regulation occurs (customers will also receive notification of the details being provided prior to submission if there is any identifying data included within the report).

For the purposes of payment processing. We maintain full compliance with the Payment Card Industry Data Security Standard (PCI DSS). More information can be found at: Learn More Here

Third party websites

Our website may contain links to other websites. We are not responsible for the privacy policies or practices of third-party websites.

Information transfer

As part of our services we provide to help you find a suitable job, we may make your personal data available to third parties, direct employers and their agents of business partners.  These parties will also be data controllers of your personal data.  The amount of data we share with these parties depends on the options you select when you create or update your account or the information you provide during our recruitment processes.

We do not directly transfer information outside of the EEA unless it is relevant to our product or service and is confirmed with yourself. Our technology partners may pass encrypted personal information to servers in other countries around the world for the purposes of business continuity, upgrades, and testing. This will mean your personal information may be securely processed on a server located outside the country where you live – please refer to their individual privacy policies for more detail.

Third parties may need to perform additional data processing and data capture as part of their hiring process and their contract with you.  This is separate to any action, consent or information you have taken or provided to Hatch.  This will be in adherence with their privacy policy and will also require your consent.

Credit reference agencies

Depending on your product or service we may, with your consent, perform credit and identity checks with one or more credit reference agencies (“CRAs”). To do this, we will supply your personal information to CRAs, and they will give us information about you. This will include information from your application and about your financial situation and financial history. CRAs will supply to us both public (including the electoral register) and

shared credit, financial situation and financial history information and fraud prevention information. We will use this information to:

• Assess your creditworthiness and whether you can afford the product;
• Verify the accuracy of the data you have provided to us;
• Prevent criminal activity, fraud, and money laundering;
• Manage your account(s);
• Trace and recover debts; and
• Ensure any offers provided to you are appropriate to your circumstances.

We may continue to exchange information about you with CRAs while you have a relationship with us. We will also inform the CRAs about your settled accounts. If you borrow and do not repay in full and on time, CRAs will record the outstanding debt. This information may be supplied to other organisations by CRAs. When CRAs receive a search from us, they will place a search footprint on your credit file that may be seen by other lenders.

If you are making a joint application or tell us that you have a spouse or financial associate, we will link your records together, so you should make sure you discuss this with them and share with them this information before lodging the application. CRAs will also link your records together and these links will remain on your and their files until such time as you or your associate successfully files for a disassociation with the CRAs to break that link.

The identities of the CRAs, their role also as fraud prevention agencies, the data they hold, the ways in which they use and share personal information, data retention periods and your data protection rights with the CRAs are explained in more detail in the Credit Reference Agency Information Notice (This notice is the same across the three agencies):

http://www.experian.co.uk/crain/index.html

Additional information

Cookies

Cookies are small data files that are placed on your computer or mobile device when you visit a website. Cookies are widely used by website owners in order to make their websites work, or to work more efficiently, as well as to provide reporting information.

Cookies set by us are called “first party cookies”. Cookies set by parties other than us are called “third party cookies”. Third party cookies enable third party features or functionality to be provided on or through the Website (e.g., like advertising, interactive content, and analytics). The parties that set these third-party cookies can recognise your computer both when it visits the website in question and also when it visits certain other websites.

We use cookies to provide easier navigation around the sites and gather anonymous analytics information. In some cases, cookies are used to provide functionality within sessions, such as within portals or learning environments. Some cookies are required for technical reasons in order for our websites to operate, and we refer to these as “essential” or “strictly necessary” cookies. Other cookies also enable us to track and target the interests of our users to enhance the experience on our websites.

We use Google Analytics to analyse the use of our websites. Google Analytics generates statistical and other information about website use by means of cookies, which are stored on users’ computers. The information generated relating to our website is used to create reports about the use of the website. Google will store this information. Google’s privacy policy is available at: http://www.google.com/privacypolicy.html

Security of personal information

We always take reasonable technical and organisational precautions to prevent the loss, misuse or alteration of any personal information held on our systems.

We will store all personal information provided to us on our secure (password-protected and firewall-protected) servers. Where we use a third parties to provide, they are subject to additional data security checks which include confirmation the provider is a relevant International Organization for Standardization (ISO) Certificate holder and registered with the ICO. As part of our due diligence process, we always review our third party’s privacy / data security policies prior to engaging them.

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 data transmitted to us in this manner.

Policy amendments

We may update this privacy policy from time to time by posting a new version on our website. You should check this page occasionally to ensure you are happy with any changes. If there is a fundamental change in the way we process your information, or if the lawful basis for our activity as a Data Controller changes, we will contact you directly.

Your rights

You may instruct us to provide you with any personal information we hold about you. Provision of such information is normally free of charge.

You have the right to withdraw consent for us to use your personal information at any time. There may be instances where this is not practical or reasonable; for instance, where we have an ongoing contractual relationship with yourself. However, if for any reason we cannot facilitate a consent withdrawal, we will provide you with an explanation including the lawful basis under which we would continue to use your information.

The above does not include use of your information for marketing activity. If you have consented to receive marketing material, you can remove this consent at any time. To withdraw consent to use your personal information in full or in part, contact us at enquiries@hatch-digital.com

You have the right to raise a complaint about the use of your personal information with the Information Commissioner’s Office. Further details can be found at: https://ico.org.uk/

Updating your information

We have a responsibility to ensure the information we store about you is relevant and up to date. Please let us know if the personal information which we hold about you needs to be corrected or updated.

Contact

If you have any questions about this privacy policy or our treatment of your personal information, please contact us at:

enquiries@hatch-digital.com

Or write to us by post:

Hatch Customer Services

167-169, Great Portland Street

Fifth Floor

London

W1W 5PF

Reviewed: 1st October 2024