Privacy

This Privacy Policy (“Policy”) sets out the basis on which Testing Circle Limited (trading as Sparta Global), registered in England and Wales with company registration number No: 5597367 and whose registered office is 1 Castle Yard, Richmond, Surrey TW10 6TF (“Testing Circle”,  “us” or “we”) will process the personal data that we collect from you, or that you provide to us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

 

As of the 25th May 2018, the law regarding data protection and how companies record, store and use individuals’ personal data is changing.  Testing Circle Limited (trading as Sparta Global) is committed to protecting and respecting your privacy. We ensure that any data you supply to us is processed with due care, attention and lawfully in accordance with the EU General Data Protection Regulation 2016/679 (“GDPR”). We are therefore updating some of our processes to ensure that we comply.

For the purposes of the GDPR, the Data Controller is Testing Circle Limited.  

 

Personal Data

We will collect Personal Data from you through different avenues but mainly via e-mail, over the telephone and via our forms on the website when you contact us or apply or post a job opportunity on our website.

 

Employee

Where you have been recruited as a member of Testing Circle’s staff, we will collect the following information about you:

Data Collected

Legal Basis

Purpose for Collecting Data

Your full Legal name, telephone number, email address, home address, Curriculum Vitae (and all such personal information contained within), National Insurance Number, bank details, Marital status, Date of Birth

 

Performance of a Contract

 

 

Legitimate interest

Necessary for the performance of your employment contract or to take steps to enter into a contract

Information contained in any employment references or character references where a background screening is required.

Consent

In order to vet new employees as part of the recruitment process prior to employment.

Passport, visa and any documentation relating to the Employee’s right to work.

Compliance with legal obligations

In order to confirm the Employee’s identity and right to work

 

Contractors (Sole Traders)

Where you are a contractor looking for job opportunities:

Data Collected

Legal Basis

Purpose for Collecting Data

Your full Legal name, telephone number, email address, home address, Curriculum Vitae (and all such personal information contained within), and any such additional information as Testing Circle may require from time to time.

 

Legitimate Interest

To store on our database and to share with recruiting companies whose vacancy you have applied for.

 

To share with other Customers who may be interested in your profile in order to discuss and negotiate a contract with us in relation to your services, or enter into a direct contract with you.

 

 

Performance of a Contract

To perform our contractual obligations, and enforce your contractual obligations pursuant to an agreement with you.

 

Contractors (Personal Service Company)

Where you are a contractor providing services under a Personal Service Company looking for job opportunities:

Data Collected

Legal Basis

Purpose for Collecting Data

The PSC’s employee’s name, telephone number, e-mail address, curriculum vitae (and all such information contained within)

 

LTD CO DOCS

Legitimate Interest

To store on our database and to share with recruiting companies whose vacancy you have applied for.

 

To share with other Customers who may be interested in your profile in order to discuss and negotiate a contract with us in relation to your services, or enter into a direct contract with you.

 

To perform our contractual obligations, and enforce your contractual obligations pursuant to an agreement with the PSC for your services.

 

BUSINESS CONTACTS (including Customers and other Suppliers)

Where you are a Customer looking to receive Testing Circle’s services or a Supplier providing Testing Circle with your services.

Data Collected

Legal Basis

Purpose for Collecting Data

Point-of-contact name, e-mail address, telephone number and address

Performance of a Contract

To perform our contractual obligations, and enforce your contractual obligations pursuant to an agreement with you.

 

WEBSITE USERS

We collect your name, company name, e-mail address, phone number (if provided), and any personal information that you may include in your message to us when submitting an enquiry form to us via the Website.

We also collect additional information using cookies and tracking technologies. Please see the section below for more details.

 

Marketing

When you register with Testing Circle you may elect to have information about jobs, marketing, opportunities or other Testing Circle services sent to your email address. Where We do this, We will contact you by electronic means (e-mail or SMS) only if you have consented to such communication.  If you do not want Us to use your data in this way please either (i) tick the relevant box situated on the form on which We collect your data (for example, the registration form); (ii) unsubscribe from our electronic communications using the method indicated in the relevant communication; or (iii) inform Us at any time by contacting Us at the contact details set out below.

 

Other Purposes

We may also use personal information collected about you to let you know about functionality changes to our website or changes to our terms and conditions of use to ensure that content on the Website is presented in the most effective manner for you and for the device(s) you use to access and view the Website

 

 

Sharing of Personal Data

Testing Circle may disclose some of these details (always in accordance with this Privacy Policy) as follows:

  • Where you are a contractor (a sole trader or via a PSC), we may pass your information to our recruiting companies to whom the vacancies relate, or who may be interested in your profile.
  • with any Government or regulatory authority as may be necessary from time to time in order comply with any statutory obligations or regulatory requirements.
  • Where you are a recruiting company registered with us as a Customer, we may share your personal information with applicants who have directly applied to a vacancy on our website, or we feel may fit your requirements.
  • We may pass your information to our third party service providers, agents, subcontractors and other associated  organisations for the purposes of completing tasks and providing services to you on our behalf (e.g: to host our services, to store and maintain your personal information in a secure server, to send you mass communication marketing emails where you have opted to receive such communications from us).

 

We may also disclose your personal data to third parties:

  • in the event that We sell or buy any business or assets, in which case We may disclose your personal data to the prospective seller or buyer of such business or assets; or

 

  • 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; or

 

  • if We are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our Website Terms and Conditions and other agreements or

 

  • to protect Our rights, property, or safety or that of our affiliated entities and our users and any third party We interact with the to provide the Website; or

 

  • in relation to selected third parties only, only to the extent that you have consented to such selected third parties notifying you about certain goods or services, which may be if interest to you.

Other than as set out above, and save insofar as is necessary in order for Us to carry out our obligations arising from any contracts entered into between you and Us, We will not share your data with third parties unless We have procured your express consent to do so.

 

 

Personal Data Storage, Access, Duration & Amendments

 We hold your data on our secure database within the UK/EEA. We take appropriate measures to ensure that any personal data are kept secure, including security measures to prevent personal data from being accidentally lost, or used or accessed in an unauthorised way.   We limit access to your personal data to those who have a genuine business need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.

We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where We are legally required to do so.

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 the Website; 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 long we keep your personal data

Where you (or your company) enter into a contract with Testing Circle, all Personal Data supplied by you in connection with that contract will be retained for the duration of the contract and for 7 years afterwards unless we are required to retain it for a longer period in accordance with any applicable law.

If Testing Circle believes there may be other employment opportunities for you after your initial contract with us has come to an end, we may contact you for your consent to continue holding your Personal Data for a further period of 6 months. We may also keep your data if it is necessary for our internal reporting purposes.

However, if we do not have a legitimate reason and it is no longer necessary to hold your data after your initial contract has ended your data will be deleted.

 

Keeping your data up to date

We will use reasonable endeavours to ensure that your Personal Data is kept up to date. However, it is your duty to inform us of any changes to your Personal Data to ensure that it is kept up to date.

 

Your rights

Under the General Data Protection Regulation you have a number of important rights free of charge. In summary, those include rights to:

•          access to your personal data and to certain other supplementary information that this Policy is already designed to address

•          require Us to correct any mistakes in your information which We hold

•          require the erasure of personal data concerning you in certain situations

•          receive the personal data concerning you which you have provided to Us, in a structured, commonly used and machine-readable format and have the right to transmit those data to a third party in certain situations

•          object at any time to processing of personal data concerning you for direct marketing

•          object to decisions being taken by automated means which produce legal effects concerning you or similarly significantly affect you

•          object in certain other situations to our continued processing of your personal data

•          otherwise restrict our processing of your personal data in certain circumstances

•          claim compensation for damages caused by our breach of any data protection laws.

For further information on each of those rights, including the circumstances in which they apply, see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals’ rights under the General Data Protection Regulation.

If you would like to exercise any of those rights, please:

•          email us at compliance@spartaglobal.com or write to Us at Testing Circle, 4 Copthall Avenue, London EC2R 7DA,

•          let Us have enough information to identify you,

•          let Us have proof of your identity and address (a copy of your driving licence or passport and a recent utility or credit card bill), and

•          let Us know the information to which your request relates.

 

Automated decision making and Profiling

During the application process (Contractors and potential Employees), and where you continue to be on our database for job assignments, we implement an automated decision making process to enable us to identify quickly which candidates meet the minimum criteria for the relevant role. You have the right to object to this automated process, but this will result in increased response times for processing your application.

We may also implement a manual process of profiling you based on your CV in order to identify which candidates might be suitable for a vacancy that you have not directly applied for. We may do this by contacting you via phone and discussing your experience or potentially via email.

 If you would like to object to the above processes please contact us.

Technology related to information collection

Cookies and Anonymous Identifiers.  A cookie is a data file that is created and stored on your computer’s hard drive when you visit our Website.  An “Anonymous Identifier” is a random string of characters that is used for similar reasons as Cookies.  We use Cookies and Anonymous Identifiers to become more familiar with our users through the study of analytics.  Some portions of our site require the use of Cookies for proper function.  Anonymous identifiers can be used where Cookie technology is not available.  You may refuse to accept Cookies by activating the appropriate setting on your web browser.  If you select this setting, you may be unable to access certain parts of our site.  Unless you have adjusted your browser setting so that it will refuse Cookies, we will issue Cookies when you direct your browser to our website.

Third-Party Services related to information collection

Google Analytics.  We have enabled Google Analytics to collect data about our traffic through the use of Google Advertising Cookies and other Anonymous Identifiers.   We use Google Analytics Cookies and other Cookies to compile data to better understand Users and provide Users with a more tailored experience.  You can opt out of Google Analytics by visiting Google’s Opt-Out Browser Add-on website.

Google AdWords.  We use Google AdWords to provide advertisements across the Internet that direct Users to Our Site.  We might also utilise Google’s remarketing technology that enables Users who have shown interest in Our Site to see targeted advertising on sites associated with the Google network.  These ads are typically displayed using Cookie technology.  You can opt out of Google’s use of Cookies by visiting Google’s Ads Settings website.

Facebook and Facebook Pixel and Retargeting.  We use Facebook’s conversion tracking pixel and retargeting service(s) to monitor Users who are redirected to this Site after clicking on a Facebook ad.  This allows Us to monitor Our ads and their effectiveness, as well as to provide advertisements to Users for goods according to their interests.  Facebook explains conversion tracking on its website.

Typeform.  We use Typeform to receive Your information through many of the forms that appear on this Site.  Typeform uses Cookies to store data made available by Your web browser, and it collects usage data, device and application data, referral data, and other information.  To learn more about Typeform’s policies, You can visit its website terms.

MailChimp.  We use MailChimp e-mail marketing services to send mass communication e-mails to Users.  We track how Users open these e-mails and what links they click so that We can better serve customers with products and information that they find relevant.  By agreeing to make a purchase on Our Site, You agree to receive e-mail advertisements, product promotions, and other information from Us.  Upon receiving an e-mail from Us, You may choose to opt-out of future e-mail messages, in accordance with the CAN-SPAM Act of 2003 by clicking the [“opt-out” or “unsubscribe”] option at the bottom of our e-mails and following MailChimp’s simple opt-out procedure.  You can learn more about MailChimp’s privacy policies at its website. By using the website, you consent to allow Testing Circle to use cookies for such purposes.

 OTHER Third-Party Use of Cookies and Other Tracking Technologies.  In addition to the applications listed above, there might be other content or applications on this Website served by third-parties, including advertisers, ad networks and servers, social media websites, content providers, and application providers.  These third parties may use Cookies alone or in conjunction with web beacons or other tracking technologies to collect information about You when You use Our Website.  The information they collect may be associated with Your Personal Information or they may collect information, including Personal Information, about Your online activities over time and across different websites and other online services.  We do not control these third parties’ tracking technologies or how they may be used.  You can learn more about opting out of third-party vendors’ use(s) of Cookies by visiting the “Network Advertising Initiative” website

What can you do if you are not happy with the way that your information has been processed?

If you are dissatisfied with how Testing Circle Limited uses your data you can make a complaint to the supervisory authority in the UK, the Information Commissioner who may be contacted at https://ico.org.uk/concerns/ or telephone: 0303 123 1113.

 

Data Protection Officer Contact Details

Testing Circle’s Data Protection Officer is Victoria Morgan at 4 Copthall Avenue, London, EC2R 7DA.

Victoria is contactable on 0207 048 4022 or via email at compliance@spartaglobal.com

Changes to our privacy policy

We keep our Privacy Policy under regular review and will update accordingly.