PRIVACY POLICY
Effective Date: 7th February 2025
1. Introduction
Welcome to Wise Generation. (“we,” “us,” or “our”). We are committed to protecting your personal data and your privacy. This Privacy Policy explains how we collect, use, process, and disclose your personal information when you use our website (the “Site”) or our services, and it describes your data protection rights. This Privacy Policy applies to both individual candidates and business clients operating in or engaging with the United Kingdom.
This Privacy Policy is compliant with the UK General Data Protection Regulation (“UK GDPR”) and the Data Protection Act 2018. By using our Site or services, you accept the terms of this Policy.
2. Who We Are
Wise Generation Limited
7 Bell Yard, London, WC2A 2JR
We act as a data controller for the personal data we process about candidates and as a data processor or joint controller (as appropriate) when we handle personal data on behalf of our business clients.
3. What Data We Collect
3.1 Candidate Data
When you engage with our services as a candidate, we may collect the following categories of personal data:
Contact Details: Name, email address, postal address, and phone number(s).
Identification Details: Date of birth, nationality, and documentation required under right-to-work checks (such as passport, ID card, visa).
Professional Information: CV or résumé details, education and employment history, certifications, skills, and references.
Job Preferences: Desired salary, geographical location, job type preferences.
Communications: Email correspondence, chat messages, and telephone recordings (if relevant).
Other Relevant Information: Any other personal data you choose to share with us or that is relevant for the recruitment process (for example, professional portfolio or social media profiles).
3.2 Business Client Data
When you or your organisation engage our services for recruitment or staffing, we may collect:
Business Contact Details: Full name, business telephone number, business postal address, and business email address.
Company Information: Company name, registration number, VAT number, invoicing details, billing contact.
Job Requirements: Job descriptions, candidate specifications, salary ranges, recruitment budgets.
Communications: Written correspondence, telephone notes, meeting minutes.
3.3 Website Usage Data
When you visit our Site, we automatically collect certain information through cookies and similar technologies:
Technical Data: IP address, browser type and version, time zone, operating system.
Usage Data: How you interact with our Site (e.g., which pages you visit, how long you stay).
For more information, please refer to our Cookie Policy which explains how we use cookies and how you can manage your cookie preferences.
4. How We Use Your Data
We only use your personal data when the law allows us to. The lawful bases under the UK GDPR for processing your personal data include:
Consent – Where you have given clear consent for us to process your data for a specific purpose (e.g., subscribing to our newsletter).
Contract – To perform a contract with you or to take steps at your request before entering into a contract (e.g., assisting in recruitment processes).
Legal Obligation – Where processing is necessary for compliance with a legal obligation (e.g., right-to-work checks, tax or regulatory obligations).
Legitimate Interests – Where processing is necessary for our (or a third party’s) legitimate business interests (e.g., providing recruitment services) and your interests and fundamental rights do not override those interests.
Below are the primary ways we use your personal information:
4.1 Candidates
Recruitment Services: To match you with suitable roles based on your experience, skills, and preferences, and to share your profile with prospective employers (with your prior consent when required).
Communication: To send updates on job vacancies, interview schedules, and other relevant recruitment information.
Compliance: To conduct right-to-work checks, record-keeping, and to comply with other legal obligations.
4.2 Business Clients
Service Delivery: To provide recruitment services, supply candidate shortlists, facilitate interviews, and manage billing and invoices.
Communication: To manage our relationship with you, including providing updates, handling enquiries, or notifying you of relevant candidates.
Compliance: To comply with legal, tax, and regulatory obligations.
4.3 Website Administration
Site Improvement: To analyse Site usage and improve functionality, user experience, and content.
Security: To maintain the security of our Site and services, including fraud prevention and troubleshooting.
5. How We Share Your Data
We do not sell your personal data. However, we may share your data in the following circumstances:
Prospective Employers: We will share your CV and relevant personal data with prospective employers if you are a candidate, but only after seeking your consent and ensuring the data shared is necessary for the recruitment process.
Service Providers: We use reputable third-party service providers (e.g., hosting providers, IT support, CRM software providers) to help run our business. These providers process your personal data on our behalf and under our instructions.
Legal & Regulatory Authorities: We may disclose your personal data if required by law, court order, or regulatory authority, or to protect our rights and property.
Business Transfers: In the event of a merger, acquisition, or transfer of all or part of our assets, we may transfer your personal data to the relevant third party, subject to confidentiality agreements.
6. International Data Transfers
Where we need to transfer your personal data outside of the UK, we will ensure appropriate safeguards are in place, such as using standard contractual clauses approved by the relevant regulatory bodies. We will take all reasonable steps to make sure your data is treated securely and in accordance with this Policy.
7. Data Retention
We will retain your personal data only for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
Candidates: We typically retain your personal data for up to [time frame, e.g., 2 years] from the date of our last meaningful contact or as required by law.
Business Clients: We typically retain your data for the duration of our business relationship and for up to [time frame, e.g., 7 years] after the business relationship ends, in line with legal and regulatory obligations.
If you wish to have your data erased, please contact us using the details below. We will honour your request unless we are legally required or permitted to retain certain information.
8. Your Rights
Under the UK GDPR and the Data Protection Act 2018, you have certain rights regarding your personal data, including:
Right to be Informed: You have the right to be provided with clear, transparent information about how we use your personal data.
Right of Access: You have the right to request a copy of the personal data we hold about you.
Right to Rectification: You have the right to have inaccurate or incomplete personal data corrected.
Right to Erasure (“Right to be Forgotten”): You can request that we delete or remove your personal data where there is no compelling reason for us to continue processing it.
Right to Restrict Processing: You have the right to “block” or suppress further use of your personal data in certain circumstances.
Right to Data Portability: Under certain conditions, you have the right to receive your personal data in a structured, commonly used, and machine-readable format.
Right to Object: You have the right to object, on grounds relating to your particular situation, to the processing of your personal data where the legal basis is our legitimate interests.
Rights Related to Automated Decision-Making and Profiling: You have the right not to be subject to automated decision-making if it produces legal or similarly significant effects on you.
To exercise any of these rights, please contact us using the details in Section 10. We will respond to your request within one month unless the request is particularly complex, in which case we may extend this period by up to two months.
9. Data Security
We take appropriate technical and organisational measures to ensure the security of your personal data, including:
Encryption: Where appropriate, data is encrypted at rest and in transit.
Access Controls: We limit access to your personal data to those employees, agents, contractors, and other third parties who have a business need to know.
Policies & Training: Our staff are trained on data protection obligations and must adhere to internal policies and procedures.
Despite our efforts, no electronic transmission or storage of data is entirely secure. If you suspect any misuse, loss, or unauthorised access to your personal data, please let us know immediately.
10. Third-Party Links
Our Site may contain links to third-party websites, plug-ins, and applications. Clicking on those links may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. We encourage you to read the privacy policies of every website you visit.
11. Changes to This Policy
We may update this Privacy Policy from time to time. Any changes we make will be posted on this page and, where appropriate, notified to you by email. Your continued use of our Site after any updates will constitute acceptance of those changes.
12. Contact Us
If you have any questions about this Privacy Policy, wish to exercise your rights, or raise a complaint, please contact us at:
Wise Generation Limited
7 Bell Yard, London, WC2A 2JR
You also have the right to lodge a complaint with the UK’s supervisory authority for data protection matters, the Information Commissioner’s Office (“ICO”). For more information, please visit www.ico.org.uk.