Privacy Policy  

This privacy policy applies to jelli Group Limited, company number 10956105 (referred to as “jelli”, “we”, “us” or “our” throughout this privacy policy) 
 
We understand that your privacy is important, and just like you, we care about how your personal data is used. We respect and value the privacy of everyone who works with us, whether you are a candidate, freelancer, agency worker, client or website user. We will only collect and use personal data in a way that is consistent with our obligations, and your rights, under the law. 
 
We are an employment agency and business which provides services to its clients and individuals. We must process personal data (including sensitive personal data) so that we can provide these services – in doing so, we act as a data controller. 
 
You may give your personal details to us directly, such as on an application, registration form, via our website or email, or we may collect them from another source such as a jobs board or a 3rd party. We must have a legal basis for processing your personal data and we will only use your personal data in accordance with this privacy statement. At all times we will comply with current data protection laws. 
 
Please make sure that you read this Privacy Policy carefully. It’s important for everyone that you understand it. 
 
What Is Personal Data? 
Personal data is defined by the Data Protection Legislation as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’. In other words, this is any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as sensitive information, identification numbers, electronic location data, and other online identifiers. 
 
 
Who is the Data controller? 
The data controller responsible for this website is Jelli Group Limited, who can be contacted at Birchin Court, c/o Carrington Accountancy 20 Birchin Lane, London Greater London EC3V 9DU. 
 
This website contains links to third-party websites, which have their own data controllers and privacy policies. This privacy policy applies only to this website. 
 
 
Who Does This Policy Refer To? 
This privacy policy outlines how we protect personal data for: 
Candidates and prospective Candidates, defined as a person who applies for a role or we deem as potential for future roles. 
Freelancer or prospective Freelancers, defined as a person that undertakes a contract to provide a service to our clients for a fixed period but are not employed by our clients. Or we deem them as potential to provide a future service to our clients. 
Agency workers as defined as a person employed through an agency to provide services to our client. 
Clients and prospective clients. 
Suppliers. 
Website users. 
 
(referred to as “you” or “your” throughout this privacy policy). 
 
 
What Data Do We Collect and How Do We Collect It? 
We may collect and hold some or all of the personal and non-personal data as set out in the table below. 
 
 
Data Collected 
How We Collect the Data 
Candidate 
Personal information - first name, last name, title and gender 
Identity information - passport/Visa 
Contact information - including residential address, email address, telephone numbers, social media handles 
Information and images available from public sources 
Work history 
Health e.g. disability (to ensure appropriate work adjustments) 
Diversity, including race, ethnicity, sexual orientation and religion (for equality, diversity and inclusivity monitoring) 
Professional references - if requested by the client 
Communications with us - emails, texts, telephone, WhatsApp 
Interactions with us - e.g. if you open emails and click on links 
Our owned channels such as website registration form and job application page 
Directly from you - your CV, correspondence (verbal and written), documentation provided 
Publicly available profile or in a CV which you have uploaded to one of these sites available to us. Such as (but not limited to) Job boards, LinkedIn and social networking sites. 
Clients who we have shared your CV with and have given feedback 
A former employer or a referee whose details you previously provided to us 
Educational institutions - to check your academic qualifications 
Software providers who we use to support our services 
Freelancer 
Personal information - first name, last name, title and gender 
Identity information - passport/Visa, National Insurance number 
Contact information - including residential address, email address, telephone numbers, social media handles 
Information and images available from public sources 
Work history 
Health e.g. disability (to ensure appropriate work adjustments) 
Diversity, including race, ethnicity, sexual orientation and religion (for equality, diversity and inclusivity monitoring) 
Payment information - bank account details 
Company and professional documents (this may be your own PSC or a nominated umbrella company), certificate of incorporation, VAT certificate, business bank statement and insurance documents. 
Professional references (when requested by the client) 
Clearance documents, criminal checks or a credit check (when applicable) 
Assignment details - rates/salary, IR35 status determination and reason for determination, Key Information Document (KIDS), 
Communications with us - emails, texts, telephone, WhatsApp 
Interactions with us - if you open emails, click on links 
Our owned channels such as website registration form and job application page 
Directly from you - your CV, correspondence (verbal and written), documentation provided such as invoices 
Publicly available profile or in a CV which you have uploaded to one of these sites available to us. Such as (but not limited to) Job boards, LinkedIn and social networking sites. 
Clients who we have shared your CV with and have given feedback 
A former employer or a referee whose details you previously provided to us 
Educational institutions - to check your academic qualifications; 
Software providers who we use to support our services 
Prospective Freelancer 
Personal information - first name, last name, title and gender 
Contact information - including residential address, email address, telephone numbers, social media handles 
Information and images available from public sources 
Work history 
Publicly available profile or in a CV which you have uploaded to one of these sites available to us. Such as (but not limited to) Job boards, LinkedIn and social networking sites. 
A referrer, for example you may be recommended to us by a colleague, friend, supplier or employer 
Agency Worker 
Personal information - first name, last name, title and gender 
Identity information - passport/Visa, National Insurance number 
Contact information - including residential address, email address, telephone numbers, social media handles 
Information and images available from public sources 
Work history 
Health e.g. disability (to ensure appropriate work adjustments) 
Diversity, including race, ethnicity, sexual orientation and religion (for equality, diversity and inclusivity monitoring) 
Professional references (when requested by the client) 
Clearance documents, criminal checks or a credit check (when applicable) 
Assignment details - rates/salary, IR35 status determination and reason for determination, Key Information Document (KIDS), holiday pay, pension contributions 
Communications with us - emails, texts, telephone, WhatsApp 
Interactions with us - if you open emails, click on links 
Our owned channels such as website registration form and job application page 
Directly from you - your CV, correspondence (verbal and written), documentation provided 
Publicly available sources such as (but not limited to) Job boards, LinkedIn and social networking sites 
A referrer, for example you may be recommended to us by a colleague, friend, supplier or employer 
Clients who we have shared your CV with and have given feedback 
A former employer or a referee whose details you previously provided to us 
Educational institutions - to check your academic qualifications; 
Software providers who we use to support our services 
Client 
Personal information - first name, last name, title, job title 
Contact information - including work address, email address, telephone numbers, social media handles 
Information and images available from public sources 
Communications with us - emails, texts, telephone, WhatsApp 
Interactions with us - if you open emails, click on links 
Candidate, freelancer and worker feedback 
Delegate/event information if you have attended a jelli event or 3rd party event where the organiser is able to share information 
Directly from you - correspondence (verbal and written), documentation provided 
Publicly available profile such as (but not limited to) Job boards, LinkedIn and social networking sites. 
3rd party suppliers 
Software providers who we use to support our services 
Prospective 
Client 
Personal information - first name, last name, title, job title 
Contact information - including work address, email address, telephone numbers, social media handles 
Information and images available from public sources 
Communications with us - emails, texts, telephone 
Delegate/event information if you have attended a 3rd party event where the organiser is able to share information 
Publicly available profile such as (but not limited to) LinkedIn and social networking sites 
3rd party suppliers 
A referrer, for example you may be recommended to us by a colleague, friend or supplier 
Software providers who we use to support our services 
Supplier 
Personal information - first name, last name, title, job title 
Contact information - including work address, email address, telephone numbers, social media handles 
Communications with us - emails, texts, telephone 
Publicly available profile such as (but not limited to) LinkedIn and social networking sites 
3rd party suppliers 
A referrer, for example you may be recommended to us by a colleague, friend, client or supplier 
Web user 
Technical information - including IP address, browser type and version, country, operating system 
Engagement information - pages visited, dwell time etc. 
Via Our website and servers. Sometimes data may be collected automatically through these mediums. 
3rd party suppliers such as domain hosts, analytics providers 
How Do We Use Your Personal Data? 
For work seeking activities including but not limited to: 
Storing your details (and updating them) on our database, so that we can contact you in relation to our work seeking services. 
Providing you with our work seeking services and to facilitate the process. 
Assessing data about you against roles, assignments or projects which we think may be suitable for you. 
Sending your information to Clients whom we may introduce you to. 
Speaking to your former employers or clients whom we may seek references from. 
Carrying out assessment and development activities (such as psychometric evaluations or skills tests) 
3rd party organisations e.g. educational institutions (to check academic qualifications), external specialists for skills tests and psychometric evaluations; and 
Any public information sources and third party organisations that we may use to carry out suitability checks e.g. Companies House, DVLA, credit reference agencies and other such organisations. 
Payroll service providers who manage payroll on our/your behalf or other payment intermediaries whom we may introduce you to. 
Carrying out customer satisfaction surveys. 
Database suppliers and digital apps for the storage of personal data to enable us to deliver our services. 
Website and IT system administration providers for the maintenance, update and management of our website. 
Other third party partners or data processors to assist with payment and tax deduction obligations which we may have to abide by from time to time. 
Our insurers or legal advisers. 
Analytics and research providers. 
Government, law enforcement agencies and other regulators e.g the Police, Home Office, HMRC, Employment Agencies Standards Inspectorate (EASI). 
Trade unions. 
 
For marketing activities including but not limited to: 
Marketing our full range of recruitment services (permanent, contract and freelance projects) to you. 
Sending you details of reports, promotions, offers, networking and client events, and general information about the industry sectors which we think might be of interest to you. 
Displaying testimonials from you on the jelli website as a success story (only where we have obtained your express consent to do so). 
Ask for your help with recommending Freelancers or connecting other Candidates with jobs. 
Third party marketing tool suppliers to allow us to manage email shots and newsletters. 
 
What data is collected by third parties on our behalf? 
 
Spoton.net 
Our site is hosted by Spoton.net Limited (registered company number 06139437 in England and Wales). Spoton.net logs all requests in order to determine the causes of reported faults and to detect and block suspicious traffic. The log records the time of the request, your IP address, the requested resource, the referring site (if specified by your browser), and your browser’s user agent string (which will usually include the name and version of your browser and operating system). Log files are deleted after ninety days. 
Lawful basis for processing: Compliance with a legal obligation Why? To comply with the GDPR obligation to implement appropriate technical measures to protect data 
 
Cloudflare 
Our site is served through Cloudflare. Cloudflare helps our site load faster by storing copies of our content in data centres around the world, and defends our site from attacks by logging requests to detect and block suspicious traffic. For more information on how Cloudflare handles the data it collects, see Cloudflare’s privacy policy. 
Lawful basis for processing: Compliance with a legal obligation Why? To comply with the GDPR obligation to implement appropriate technical measures to protect data 
 
Google Analytics 
We use Google Analytics to track visitor interaction with our site in order to produce statistical reports. Google collects details of the pages you view and the time you viewed them, the features of your browser, and your IP address. For more information on how Google handles the data it collects, see Google’s privacy policy. To opt out of Google Analytics tracking on our site, see the Google Analytics section of our cookie policy. To opt out of Google Analytics tracking on all sites, use the Google Analytics Opt-out Browser Add-on. 
Lawful basis for processing: Pursuance of our legitimate interests Why? To allow us to analyse how visitors interaction with our site in order to improve our site and our services 
 
 
Other Ways We Use Your Personal Data 
We will only use your personal data for the purpose(s) for which it was originally collected, unless we reasonably believe that another purpose is compatible with that or those original purpose(s) and need to use your personal data for that additional purpose. If we need to use your personal data for a purpose that is unrelated to, or incompatible with, the purpose(s) for which it was originally collected, we will inform you and explain why. 
 
If we sell, transfer, or merge parts of our business or assets, your personal data may be transferred to a third party. 
 
In some circumstances we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority. We may process this without your knowledge or consent. This will only be done within the bounds of the Data Protection Legislation and your legal rights. 
 
Purpose of Processing and Legal Basis 
We will collect your personal data (which may include sensitive personal data) and will process your personal data for the purposes of providing you with our services. This includes for example, contacting you about job opportunities, assessing your suitability for those opportunities, updating our databases, putting you forward for job opportunities, arranging payments to you and developing and managing our services and relationship with you and our clients. 
 
In some cases we may be required to use your data for the purpose of investigating, reporting and detecting crime and also to comply with laws that apply to us. We may also use your information during the course of internal audits to demonstrate our compliance with certain industry standards. 
 
We must have a legal basis to process your personal data. The legal bases we rely upon to offer our services to you are: 
 
Your consent 
Where we have a legitimate interest 
To comply with a legal obligation that we have 
To fulfil a contractual obligation that we have with you 
 
Consent 
Where you have expressly provided your consent to receive communications from us, for example, emails and updates on new job opportunities or assignments. You can opt-out from receiving these at any time by selecting “unsubscribe” when you receive these communications from us. 
 
In addition, consenting to the use of non-essential cookies on our site is used to make your experience on our site more seamless by, for example but not limited to, remembering pages you have previously visited and automatically generated forms. Cookies are small pieces of text that are stored by your browser. Each cookie has a name and is associated with a particular site. When your browser sends a request to a site (for example, to download a page, image, or video), the computer that responds (known as a server) may tell your browser to set one or more cookies. When your browser makes further requests to the same site it sends the cookies back to the server. This allows the server to remember you as you browse the site, and provide features such as shopping baskets or password-protected areas. For more information on the cookies we use, see our cookie policy. 
 
Legitimate interest 
This is where we have a legitimate reason to process your data, provided it is reasonable and does not go against what you would reasonably expect from us. Where we have relied on a legitimate interest to process your personal data our legitimate interests are as follows: 
 
Managing our database and keeping records up to date; 
Providing our service to you and our clients; 
Contacting you to seek your consent where we need it; 
Responding to requests and enquiries; 
Giving you information about our service, similar products or services that you have used from us recently; and 
Ensuring our service runs smoothly and that we are continuing to improve our services e.g. through surveys. 
 
Legal Obligation 
We have certain legal and contractual requirements to collect personal data (e.g. to comply with the Conduct of Employment Agencies and Employment Businesses Regulations 2003, immigration and tax legislation, and in some circumstances safeguarding requirements.) Certain personal data you provide us with, is necessary for us to fulfil our legal obligations as a business. For example (i) verifying your legal and tax status; (ii) appropriate use of Our Site and services; (iii) preventing fraud and security breaches; and (iv) complying with our tax and accounting obligations where needed. Our clients may also require this personal data, and/or we may need your data to enter into a contract with you. 
 
If you do not give us the personal data we need to collect we may not be able to continue to provide work-finding services to you. 
 
Contractual Obligation 
Your personal data is necessary for us to manage the contractual relationship with you. It enables us to communicate and process any Assignments, Projects or Roles, and keep you updated with any changes to our terms and policies. 
 
 
How Long Do We Hold Your Personal Data For? 
We will retain your personal data only for as long as is necessary for the purpose we collect it. Different laws may also require us to keep different data for different periods of time. For example, the Conduct of Employment Agencies and Employment Businesses Regulations 2003, require us to keep records for at least one year from (a) the date of their creation or (b) after the date on which we last provide you with services. 
 
If you are a freelancer or an agency worker we must also keep your records for as long as is legally required by HMRC and in case of legal claims. This is currently 6 years unless there is a requirement to extend this period. 
 
Where we have obtained your consent to process your data, we will do so in line with our retention policy. Upon expiry of that period the Company will seek further consent from you. Where your consent is not granted or it is withdrawn we will cease to process your data. 
 
 
What are your rights? 
You have the following data protection rights: 
 
The right to be informed about the personal data we process on you; 
The right of access to the personal data we process on you; 
The right to rectification of your personal data; 
The right to erasure of your personal data in certain circumstances; 
The right to restrict processing of your personal data; 
The right to data portability in certain circumstances; 
The right to object to the processing of your personal data that was based on a public or legitimate interest; 
The right not to be subjected to automated decision making and profiling; and 
The right to withdraw consent at any time. 
 
Where you have consented to us processing your personal data you have the right to withdraw that consent at any time by contacting us through the contact details at the end of this policy. Please note that if you withdraw your consent to further processing that does not affect any processing done prior to the withdrawal of that consent, or which is done according to another legal basis. 
 
There may be circumstances where we will still need to process your data for legal or official reasons. Where this is the case, we will tell you and we will restrict the data to only what is necessary for those specific reasons. 
 
If you believe that any of your data that we process is incorrect or incomplete, please contact us and we will take reasonable steps to check its accuracy and correct it where necessary. 
 
 
Securing your Data 
The security of your personal data is essential to us and to protect your data, we take a number of important technical and organisational measures, including the following: 
 
We verify the identity of any individual who requests access to data before granting access. We use Transport Layer Security (TLS, also known as SSL) to encrypt any data you supply to us through our website. Additional technical measures are described at the relevant points in this privacy policy. 
Limiting access to your personal data to those employees, agents, consultants, freelancers, clients and other third parties with a legitimate need to know and ensuring that they are subject to duties of confidentiality and aware of any obligations relating to the use of your personal data by them; and 
Procedures for dealing with data breaches (the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, your personal data) including notifying you and/or the Information Commissioner’s Office where we are legally required to do so. 
 
We use all reasonable efforts to safeguard your personal information. However, you should be aware that the use of email and the Internet is not entirely secure and for this reason we cannot guarantee the security or integrity of any personal information which is transferred from you or to you via email and the Internet. 
If you share a device with others we recommend that you do not select the “remember my details” function when that option is offered. 
 
 
How Can You Access Your Personal Data? 
If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”. All subject access requests should be made in writing and sent to the email or postal addresses shown below. 
 
There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding. 
 
We’ll respond to your subject access request within 14 calendar days and, in any case, not more than one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You’ll be kept fully informed of our progress. 
 
 
How Do I Contact You? 
To contact us regarding your personal data and data protection, including to make a subject access request or a complaint, please contact our Data Protection Officer at: 
 
jelli Group Limited 
Birchin Court 
℅ Carrington Accountants 
Birchin Street 
London 
 
Email: hello@jelligroup.com 
 
You also have the right to raise concerns with the Information Commissioner’s Office on 0303 123 1113 or at https://ico.org.uk/concerns/, or any other relevant supervisory authority if you believe that your data protection rights have not been adhered to. 
 
General 
You may not transfer any of your rights under this Privacy Policy to any other person. In the event someone under the age of 18 accepts this Privacy Policy without consent from someone who has parental responsibility, we shall not be liable for any breach of the Data Protection Legislation relating to the personal data we collect as a result of such use. We may transfer our rights under this Privacy Policy where we reasonably believe your rights will not be affected. 
 
If any court or competent authority finds that any provision of this Privacy Policy (or part of any provision) is invalid, illegal or unenforceable, that provision or part-provision will, to the extent required, be deemed to be deleted, and the validity and enforceability of the other provisions of this Privacy Policy will not be affected. 
 
Unless otherwise agreed, no delay, act or omission by a party in exercising any right or remedy will be deemed a waiver of that, or any other, right or remedy. 
 
This Privacy Policy will be governed by and interpreted according to the law of England and Wales. All disputes arising under the Agreement will be subject to the exclusive jurisdiction of the English and Welsh courts. 
 
Changes to this Privacy Policy 
We may change this Privacy Policy from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection. We recommend that you check this page regularly to keep up-to-date. 
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