Privacy Policy

About us

Leapfrog Limited (“Leapfrog”, “we”, “us”) is a company registered in Guernsey with number 37408. We are registered with the Office of the Data Protection Commissioner in Guernsey, with number 10423. We are a Controller, which means that we are responsible for deciding how we obtain, hold and use your personal data. We are committed to protecting your privacy and confidentiality in accordance with the policies and procedures set out in this Privacy Notice.

General

This Privacy Notice explains how we obtain, use and store personal data about people who contact us or use our services, including our website (“you”, “your”). It applies to personal data existing both during and after your relationship with us, and it is designed to comply with the provisions of the Data Protection (Bailiwick of Guernsey) Law, 2017 (“the Law”). From time to time we may update this Privacy Notice. A copy of the current version of this Privacy Notice may be obtained from our website at www.leapfrogjobs.com.

If you have any questions about this Privacy Notice or any data that we hold about you, please contact our data protection administrator at [email protected].

Personal Data

Personal Data means any information relating to an identified or identifiable living individual. It can include your name, address and contact information such as an email address or telephone number. Also the Candidate reference that we may assign to you (e.g. LF999).

Special Category Data

Special Category Data is data revealing an individual's racial or ethnic origin, political opinion, religious or philosophical belief, trade union membership, genetic data, biometric data, health data, data concerning an individual's sex life or orientation, criminal data and credit scoring data. We will not process any special category data without your explicit consent for the purpose of which it is processed.

The data we process

“Processing” means any operation which is performed on personal data, including the collection, storage, retrieval, use and disclosure of personal data. We process personal data in relation to two types of individuals:

I. Individuals using our services, potentially using our services, or who have used our services (“Candidates”).

II. Individuals who work for businesses or organisations who may employ Candidates introduced by us (“Clients”).

Data concerning Candidates

The personal data we process about Candidates may include the following:
- Name, job title, date of birth, gender, postcode, interests outside work.
- Contact information including email address, telephone numbers, home address. Full CV/employment history details, salary/remuneration history details, educational history, professional and academic qualification certificates.
- Bank details, tax and social security reference numbers, tax coding and other tax information.
- Passport, visas and Right to Work documentation, next of kin and family contact details.
- References, (including contact details for referees).
- Job preferences and work interests.
- Special Category Data (N.B. Previously referred to as “sensitive personal data”) including medical conditions, criminal data (e.g. Police checks), religious belief, race/ethnic origin, political opinions, health.
We may collect personal data from the following sources:
- An application form or CV completed or provided by you.
- Other Candidates who have referred you.
- Clients who have referred you.
- Your telephone, email or personal visit enquiry.
- Social media such as LinkedIn and Facebook.
- Public domain (e.g. Press reports).
- Interviews or meetings.
- Job boards.
- Our website.
We may use personal data for the following purposes:
- Notifying you of potential jobs or opportunities.
- Searching for potential jobs and opportunities for you and assessing your suitability for them.
- Introducing you to Clients as a potential employee or temporary worker.
- Employing you as a temporary worker.
- Providing information to the States of Guernsey, regulatory, and law enforcement agencies in compliance with our legal obligations.
Our legal basis for the processing of personal data is our legitimate business interest as a provider of recruitment consultancy services. In addition we may in some situations rely on contractual or legal obligations, or your specific consent. Details of these situations are described below.
1. Contractual obligations
  We may enter into a contract with you, typically if we employ you as a temporary worker. In these situations we may process any of the information described in 1., with the exception of the Special Category Data. In relation to the processing of any Special Category Data, we will obtain your explicit consent (N.B. See 5. below).
2. Compliance with legal obligations
  If we employ you as a temporary worker we must comply with legal obligations such as Income Tax and Social Security reporting requirements. In addition we may be legally obliged to provide information to statutory and regulatory authorities such as the States of Guernsey Population Management Department.
3. Legitimate business interests
  As a provider of recruitment consultancy services we have a legitimate business interest in processing personal data for purposes including:
  - Accounting and record keeping
  - Dealing with any contractual disputes or legal issues with Clients that may arise in relate to your employment
  - Staff training
  - System requirements (including data backup)
4. Specific consent
  We may process your personal data on the basis that you have consented to us doing so for a specific purpose, for example sending your CV to a potential employer. You may also have consented to receive marketing updates from us. You may withdraw your consent to your data being processed for a specific purpose at any time. This is part of your rights as a data subject (N.B. See Section 6 below, “Your rights”). If you withdraw your specific consent we may still retain and process your personal data in accordance with our legitimate business interests, or in compliance with our legal obligations.
5. Special Category Data
  We do not generally process any Special Category Data other than Credit Scoring Checks and Police Clearance Certificates, which may show details of any criminal convictions or cautions that an individual may have, and details of convictions that you have disclosed to us when completing our Candidate Registration and Application form. Most Guernsey employers (and all employers in the financial services sector) require potential employees to provide evidence of a current Police Clearance Certificate. We will therefore require your explicit consent to us processing any Special Category “criminal data” about you, which means any personal data relating to the commission of any criminal offence by you, as shown on your Police Clearance Certificate or disclosed on the Candidate Registration and Application form. We obtain this consent by your signature on the Candidate Registration and Application form.
  You may disclose to us and require us to process other categories of Special Category Data that you consider we need to know, for example details of trade union membership or your relevant medical history. If you wish to disclose Special Category Data (including criminal data) to us, you should do so by recording it on the signed Candidate Registration and Application form.
6. Our sharing of personal data
  We only share your personal data when we are entitled or obliged to do so. We may share your personal data with:
  - Clients, as necessary for the provision of recruitment consultancy services
  - Regulatory authorities and statutory bodies with whom we are legally obliged to share personal data
  - Our suppliers, such as IT suppliers and cloud storage providers
  - Professional advisers
  - Insurers
7. Automated decisions
  We do not make automated decisions.

Data concerning Clients

The personal data we process about Clients may include the following:
- Name, job title, name of organisation.
- Contact information including email address, telephone numbers, and business address.
- Notes from meetings, telephone conversations and email correspondence.
- Your marketing preferences.
We may collect personal data from the following sources:
- Information you have provided us with for the purpose for the provision of recruitment consultancy services.
- Staff of your organisation (including head office, subsidiaries and associated companies, in Guernsey and elsewhere).
- Candidates who have referred you.
- Clients who have referred you.
- Social media such as LinkedIn.
- Public domain (e.g. Press reports and your website).
- Interviews or meetings.
We may use personal data for the following purposes:
- Notifying you of potential Candidates.
- Providing information to the States of Guernsey, regulatory, and law enforcement agencies in compliance with our legal obligations.
- Retaining records of our business dealings with your organisation.
Our legal basis for the processing of personal data is our legitimate business interest as a provider of recruitment consultancy services. In addition we may in some situations rely on contractual or legal obligations, or your specific consent. Details of these situations are described below:
1. Contractual obligations
  We may enter into a contract or preferred supplier agreement with you. In these situations we may process any of the information described in 1.
2. Compliance with legal obligations
  We must comply with legal obligations such as Income Tax and Social Security reporting requirements. In addition we may be legally obliged to provide information to statutory and regulatory authorities such as the States of Guernsey Population Management Department.
3. Legitimate business interests
  As a provider of recruitment consultancy services we have a legitimate business interest in processing personal data for purposes including:
  - Accounting and record keeping.
  - Dealing with any contractual disputes or legal issues that may arise in relate to the employment or potential employment of Candidates.
  - Staff training.
  - System requirements (including data backup).
4. Specific consent
  We may process your personal data on the basis that you have consented to us doing so for a specific purpose, for example sending you CVs of potential employees. You may also have consented to receive marketing updates from us. You may withdraw your consent to your data being processed for a specific purpose at any time. This is part of your rights as a data subject (N.B. See Section 6 below, “Your Rights”). If you withdraw your specific consent we may still retain and process your personal data in accordance with our legitimate business interests, or in compliance with our legal obligations.
5. Special Category Data
  We do not generally process any Special Category Data concerning Clients. If you wish to disclose Special Category Data to us (e.g. An individual’s medical history), we will require your explicit consent to our processing of that data, including the purpose for which that data is required.
Our sharing of personal data:
We only share your personal data when we are entitled or obliged to do so. We may share your personal data with:
- Candidates, as necessary for the provision of recruitment consultancy services.
- Regulatory authorities and statutory bodies with whom we are legally obliged to share personal data.
- Our suppliers, such as IT suppliers and cloud storage providers.
- Professional advisers.
- Insurers.
Automated decisions
We do not make automated decisions.

Transfer of data to other jurisdictions

This section applies to data concerning both Candidates and Clients.

We may transfer your personal data to a third party in countries outside the country in which it was originally collected for further processing in accordance with the purposes set out above. We may transfer your personal data outside the EEA to accounting and cloud storage service providers based in the USA and elsewhere in the world whose compliance with the EU-U.S. and Swiss-US Privacy Shield Frameworks has been confirmed.

In the event of a sale, merger, liquidation, receivership or the transfer of all or part of our assets to a third party, we may need to transfer your information to a third party. Any transfer will be subject to the agreement of the third party to this Privacy Notice and any processing being in accordance with this Privacy Notice.

Data security

We will implement reasonable technical and organisational security measures in order to prevent unauthorised access to your personal data. You should be aware that the transmission of information via the internet is never completely secure. Whilst we will use reasonable endeavours to keep our own systems secure, we do not have full control over all processes involved in, for example, your use of our website or sending confidential materials to us via email, and we cannot therefore guarantee the security of your information transmitted to us via email or the web.

Data retention

Your personal data will be retained for as long as is reasonably necessary for the purposes listed above or as required by the law.

Your rights

You have numerous rights in relation to your personal data. For further information about your data protection rights please visit the website of the Office of the Data Protection Commissioner, Guernsey, who are our relevant supervisory authority.

Right to make a subject access request (SAR). You may request in writing copies of personal data we hold about you. However, compliance with such requests is subject to certain limitations and exemptions and the rights of others. Each request should make clear that a SAR is being made. There is no charge for making an SAR and the subsequent provision of your data, however, you may be required to submit a proof of your identity, where applicable.
Right to rectification. You may request that we rectify any inaccurate or incomplete personal data.
Right to withdraw consent. You may at any time withdraw you consent to the processing of your personal data by us on the basis of previous consent. Such withdrawal will not affect the lawfulness of processing based on previous consent.
Right to object to processing, including automated processing and profiling. We do not make automated decisions.
Right to erasure. You may request that we erase your personal data. We will comply, unless there is a lawful reason for not doing so. For example, there may be an overriding legitimate ground for keeping your personal data, such as, our archiving obligations that we have to comply with.
Restriction. You may request that we restrict our processing of your personal data in various circumstances. We will comply, unless there is a lawful reason for not doing so, such as, a legal obligation to continue processing your personal data in a certain way.=
Right to data portability. In certain circumstances, you may request the controller to provide a copy of their personal data in a structured, commonly used and machine readable format and have it transferred to another provider of the same or similar services. To the extent such right applies to the services, we will comply with such transfer request. Please note that a transfer to another provider does not imply erasure of the data subject’s personal data which may still be required for legitimate and lawful purposes.
Right to lodge a complaint with the supervisory authority. We suggest that you contact us about any questions or complaints in relation to how we process personal data. However, each data subject has the right to contact the relevant supervisory authority directly, contact details available on their website: www.odpa.gg

Leapfrog Ltd

18 July 2018

Updated 1^st October 2020