Privacy Policy
Who we are and how we process your personal data:
At Morgan Conway (“MC” “we,” “us,” or “our”), value the privacy of our candidates, clients, and website users. The MC entity acting as the Controller of your data will depend on the services we provide to you. We are committed to providing a safe and secure user experience. The information you provide to us or that we collect through various channels, such as our website, written correspondence, conversations, or meetings with our consultants, is used only for the purposes outlined in this Privacy Policy.
Our Privacy Policy aims to inform you about the types of personal data we collect, the purposes for which we use the data, and how we handle it. We strive to fulfill our transparency obligations under the UK GDPR and other applicable laws.
Scope:
- Protecting your personal data is our priority. This privacy policy explains how MPIR processes and safeguards personal data of the following individuals:
- Candidates who register with us for roles managed on behalf of other employers, for roles at Morgan Conway, or through our website, job boards, social media sites, or other sources.
- Prospective candidates.
- Business contacts at our clients and suppliers.
- Users of our websites.
This policy also informs you about your privacy rights, including the right to object to our processing. If you need to contact us, please refer to the “How to contact us” section in this policy.
Personal data we collect:
Candidates:
When you register with us as a candidate for work-finding services, we collect and process your personal data, including but not limited to your name, contact details, information from your CV, current benefits, and expectations for future roles. Where permitted by law, we may also collect health information (e.g., disability information for reasonable work adjustments) and diversity information (e.g., race, ethnic origin, sexual orientation, religion) for equal opportunity monitoring purposes. Additionally, we may collect details of any unspent criminal convictions if required by a client or us for a role application. If you use our website, interact with our emails or sign up for job alerts, we also collect personal data from those interactions. We may obtain personal data about you from third parties, such as referees, former employers, educational institutions, Disclosure and Barring Service, credit reference agencies, publicly available sources (e.g., LinkedIn), and clients to whom we have provided your CV or who have engaged with you as part of a job application.
Prospective Candidates:
We collect personal data about you, including your name, contact details, and professional biographical details obtained from publicly available sources like LinkedIn and social media sites. This information allows us to contact you if we believe you may be interested in our work-finding services in the future. We may also obtain your personal data through another candidate or an employer who recommends you as a contact.
Prospective Business Clients:
To establish commercial relationships with your company, we collect your contact details and data related to your function or position.
Users of our website or apps:
When you visit our website or use our apps, we collect personal data such as your IP address and other device-related data necessary to provide our online content to you. We also gather information about your engagement with our website or apps, including the pages you view. If you contact us, we collect information about your inquiry. We use cookies and similar technologies, as explained in our cookie policy, to collect much of this information.
Clients:
For clients, we collect personal data such as your name, job title, and contact details. We process information about our communications with you, including email interactions and feedback you provide about our candidates. If you provide information about a candidate, we obtain your details from the candidate and keep a record of the data you provide.
Suppliers:
As a supplier, we typically collect your name and contact details as a business contact for your organization.
Providing your personal data:
In certain instances, it will be necessary for you to provide us with personal data in order for us to work together. Failure to provide the requested personal data may result in our inability to provide you with our services.
How we use your personal data:
Candidates:
We utilize your personal data to:
- Provide you with work finding services.
- Facilitate communication with you.
- Enable you to upload your CV and apply for jobs.
- Customize your experience by creating a candidate profile.
- Monitor equality and diversity.
- Provide interviewing and salary advice.
Send you direct marketing materials, such as job opportunities, industry reports, insights, events, promotions, competitions, and other content, in accordance with your marketing choices.
Display targeted and relevant banner advertising on our website and within your social networks, based on your previous interactions with our website, emails, and interactions with our consultants. These ads aim to present you and individuals with similar interests with job opportunities and content we believe will be of interest to you. This processing is carried out using Cookies only if you have previously provided consent.
Prospective Candidates and Business Clients:
We utilize your personal data to:
- Determine if you may have an interest in our services and how we can assist you.
- Contact you to inquire about your interest in our services.
- Users of our website or apps:
- We utilize your personal data to:
- Enhance and personalize your experience while using our website or apps.
- Personalize the advertising you receive from us.
Clients:
We utilize your personal data to:
- Provide recruitment services to you.
- Communicate with you.
- Gather feedback through client satisfaction surveys to improve our services and develop new ones.
- Maintain our business relationship with you.
- Respond to your inquiries.
- Fulfill contractual obligations.
- Establish, exercise, or defend legal claims.
- Conduct direct marketing activities.
Suppliers:
We utilize your personal data to:
- Communicate with you.
- Maintain our business relationship with you.
- Respond to your inquiries.
- Fulfill contractual obligations.
- Establish, exercise, or defend legal claims.
- Conduct direct marketing activities.
You have the option to unsubscribe from receiving marketing communications from us by using the provided unsubscribe methods in the communications we send or by contacting us directly. We have also established a marketing preference center where you can view and manage your marketing preferences, allowing you to opt out of receiving marketing materials from us at any time.
Legal Basis for Processing Your Personal Data:
Under the UK GDPR, we rely on the following legal bases to process your personal data:
(a) Performing a contract: We may process your personal data when it is necessary to fulfill our contractual obligations or take steps at your request to enter into a contract.
(b) Compliance with a legal obligation: We may process your personal data to meet our legal or regulatory obligations.
(c) Legitimate interests: We may process your personal data based on our legitimate interests or the legitimate interests of a third party. These interests include:
- Providing our services to you.
- Responding to your requests and inquiries to maintain effective communication with clients and candidates.
- Optimizing the performance of our website and enhancing the user experience.
- Informing you about our services, such as job opportunities, industry reports and insights, events, promotions, and competitions, as it aligns with our legitimate interest to keep clients and candidates informed.
- Ensuring efficient operations.
- Conducting satisfaction surveys regarding our services.
- Contacting potential business clients to establish commercial relationships, as part of our legitimate interest in maintaining relationships with companies.
We have conducted a legitimate interest assessment to ensure that our interests do not override your interests or fundamental rights and freedoms. If you would like to request this assessment, please contact us using the provided contact details.
(d) Consent: In certain circumstances, we may seek your consent to process your personal data, particularly in managing your marketing preferences or when conducting talent trends surveys. For example, if you register for a job, we may offer you the option to receive similar job alerts. If we process your personal data based on your consent, you have the right to withdraw your consent at any time. Please contact us if you wish to withdraw your consent.
Automated Decision Making:
We do not make decisions based solely on automated processing. Human intervention is always involved before making any decisions.
We engage in two types of profiling based on candidates’ personal data:
- JobMatch: This tool, available on our website, allows candidates to upload their CVs and receive job recommendations based on their skills. However, this profiling does not restrict or exclude access to other jobs and positions.
- Intelligent search within our customer database: We use this feature to filter through CVs when we receive numerous applications for advertised roles. Relevant keywords, such as years of experience or field of practice, are entered to analyze and rank candidates’ suitability for the role. It is important to note that a recruiter verifies this process, ensuring there are no automated decisions.
Please be aware that these profiling activities do not produce significant legal or similar effects on candidates. If you would like further information, please contact us.
Sharing Your Personal Data:
In certain circumstances, we may share your personal data with:
Other companies within our Group: We may share or provide access to your personal data with other entities. These entities, including our recruitment experts and key business members responsible for functions like payroll and IT support, are located worldwide. For example, if it is relevant to your job search or recruitment needs, we may share your personal data with recruiters specialized in Technology and Outsourcing recruitment for the UK market based in the Philippines. Adequate data protection measures are in place for such transfers, based on an intra-group data transfer agreement containing Standard Contractual Clauses (SCCs) approved by the UK Parliament. These SCCs ensure an additional safeguard for cross-border transfers of personal data from the European Economic Area (EEA) to third countries outside the UK and EEA.
The UK recognizes that countries in the EEA provide adequate protection for personal data.
The sharing of personal data within our company serves the following purposes:
(i) Providing essential services centralized within a single entity, such as IT, commercial and sales support services. In this case, these entities access and process your personal data as data processors, following the instructions of the data controller.
(ii) Managing global, regional, or senior executive positions, or the development of key accounts, which may require collaboration among different companies within the group.
(iii) Managing positions that can be fulfilled remotely.
The lawful basis for these processing activities is the performance of contracts with clients and candidates, or the steps necessary to enter into a contract, as well as the legitimate interests of Morgan Conway in delivering its services using internal resources.
Please note that if you register as a candidate in a country different from your original association with Morgan Conway, a unique record will be created for you to avoid duplications and enhance the accuracy of personal data. Morgan Conway will share your personal information as independent data controllers for these purposes.
Other Disclosures:
Furthermore, we may disclose your personal data in the following circumstances:
- When we are legally obligated to do so.
- To law enforcement agencies, regulators, or other government officials.
- To the new owners of the business or their advisors in the event of a reorganization, merger, sale, joint venture, assignment, or other transfer or disposition of all or any part of our business.
Ensuring the Security of Your Personal Data:
We have implemented and maintain appropriate technical and organizational measures to safeguard your personal data against accidental or unlawful destruction, loss, alteration, unauthorized disclosure, or access. Only authorized personnel and third-party service providers who require access to personal data for specific purposes are granted access. These employees and service providers are contractually obligated to treat the information as confidential.
Retention of Your Personal Data:
We will retain your personal data for as long as necessary to fulfill the purpose for which it was collected, which may include ongoing purposes. For instance, if you are a candidate, we will retain your personal data for the duration of our business relationship with you and beyond, as we often support candidates with job placements over an extended period, potentially throughout their careers.
The retention period may vary for different types of personal data. When determining the appropriate retention period, we consider factors such as the purposes for processing your personal data, including any legal, regulatory, accounting, and reporting obligations, the nature and amount of personal data held, and the potential risk of harm from unauthorized use or disclosure.
Regarding personal data processed for direct marketing purposes, we will continue to do so until you request us to stop, and for a short period thereafter (to allow us to implement your request). We also maintain a record indicating that you have requested not to receive direct marketing or that you have requested indefinite processing of your data, in order to respect your preferences.
Your Rights Regarding Your Personal Data:
You have various rights under UK and EU data protection laws. These rights include the right to request a copy of your personal data, to correct, delete, or restrict the processing of your personal data, to receive the personal data you provided to us in a structured, machine-readable format based on a contract or your consent, and to request the transfer (portability) of this data to another controller.
Additionally, you can object to the processing of your personal data in certain circumstances. This applies particularly when we are not obligated to process your personal data for contractual or legal reasons, or when we use the data for direct marketing purposes.
Please note that these rights may be limited. For example, if fulfilling your request would reveal personal data about another individual or infringe upon the rights of a third party (including our rights), or if you request the deletion of information that we are legally required to retain or have compelling legitimate interests in keeping. We will inform you of any relevant exemptions we rely on when responding to your request.
Changes to our Privacy Policy
We may change this privacy policy at any time. If we do so, we will post updates on this site