Privacy Policy & Terms & Conditions

Introduction

This notice tells you what to expect when C P Marine UK Ltd uses your personal data.

It does not provide exhaustive detail of all aspects of our collection and use of personal data but we are happy to provide any additional information or explanation needed.

Any requests for this should be sent to mydata@cpmarineuk.com.

This privacy notice applies to information we collect about:

• visitors to www.cpmarineuk.com;
• Registered employers and job applicants;

Links to other websites

This privacy notice does not cover the links within this site linking to other websites. We encourage you to read the privacy statements on the other websites you visit.

Changes to this privacy notice

We keep our privacy notice under regular review. This privacy notice was last updated on 25th May 2018.

Who is C P Marine UK Ltd?

C P Marine UK Ltd is a limited company registered in England & Wales No 06638869 and our address is:

PO Box 314, Hull. HU10 7WG

C P Marine UK Ltd is a crewing and shore based marine recruitment agency providing a dedicated service connecting seafarers to shipping companies and also placements to shore based marine positions.

This website (http://www.cpmarineuk.com/) allows job seekers to view the vacancies we have on offer and register their details with us to be forwarded on to suitable recruiters.

It also allows employers and job seekers to register their details with us.

Our use of personal data on this website is aimed at helping us achieve these aims and to provide both job seekers and recruiters with the best service and experience we can.

Data Controller

C P Marine UK Ltd acts as a data controller, should you have any questions or concerns about our personal data policies or practices, please e-mail. mydata@cpmarineuk.com

Your Rights

The European Union’s General Data Protection Regulation provides you with certain rights. A good explanation of them (in English) is available on the website of our National Privacy Regulator, the Information Commissioner’s Office.

In the UK you have rights as an individual under the Data Protection Bill 2018 which you can exercise in relation to the information we hold about you.

You can read more about these rights here – https://ico.org.uk/for-the-public/is-my-information-being-handled-correctly/

A right to information and access

You have the right to know whether C P Marine UK Ltd is processing your personal data and to have access to the personal we may have about you.

You may also request information about: the purpose of the processing; the categories of personal data concerned; who we might have shared the data with; what the source of the information was (if you didn’t provide it directly to us); and how long it will be stored for.

Reasonable access to your personal data will be provided at no cost upon request made to C P Marine UK Ltd at mydata@cpmarineuk.com.

To make sure we do not disclose your information to someone else, we may ask you to provide information to confirm your identity. This may include asking you to provide identification documents.

If access cannot be provided within 30 days, C P Marine UK Ltd will provide you with a date when the information will be provided.

If for some reason access is denied, C P Marine UK Ltd will provide an explanation as to why access has been denied.

A right to correct

You have a right to correct the information we hold about you if it is inaccurate. Where we need to investigate the accuracy of the data, you have the right to request we restrict our use of that data e.g. not sharing it with employers etc.

A right to erasure

You may request that we erase the data we hold about you; but this is not an absolute right and is subject to exceptions. Where we have a lawful reason to retain your data even when you request we delete it, you have the right to restrict our use of your data to that reason only.

You can exercise this right by contacting us at the details earlier in this notice or through any of the means advertised on our website.

A right to object to the use of your personal data for direct marketing

You can stop direct job alerts from us in the following ways:

• Notify your usual contact that you no longer wish to receive.
• Contact us using any of the contact details in this notice or published on our website

Please note that you may continue to receive communications for a short period while our systems are fully updated.

A right to not be subject to automated decision making

You have the right to object to a decision which has been made solely by automated reasons. Essentially, this right allows you to request that the decision is reviewed by a human. We do not employ any automated decision making although some of the employers we pass your information to may do so. Please contact the employer concerned if you require any more information.

A right to data portability

When technically feasible, C P Marine UK Ltd will-at your request-provide your personal data to you or transmit it directly to another controller in a commonly used, machine readable format e.g. csv.

A right to complain

You have a right to lodge a complaint with the appropriate data protection authority if you have concerns about how we use your personal data.

In the UK this is the Information Commissioner’s Office – www.ico.org.uk/concerns.

The reasons we can lawfully use your data

We only use your personal data when we have a lawful basis to do so.

Data Protection legislation sets out a number of these, but the ones we most commonly use are:

Consent

In many situations, we collect and use your personal data with your consent.

Performance of a Contract

There are situations where we need to use your personal data in order to provide the service you have asked us for (or to allow others to do so on our behalf).

Legal Obligation

If the law requires us to, we may need to collect and process your data. e.g. to establish your right to work in the UK or other locations or to provide the information required by various international immigration services or national security agencies in connection with a visa etc.

Legitimate interest

We may use your personal data to pursue our legitimate businesses interests in a way which might reasonably be expected as part of running our business as long as it does not materially impact your interests, rights and freedoms.

These legitimate business interests can include:

• enhancing, modifying, personalising or otherwise improving our services and communications for the benefit of our customers and users.
• understanding how people interact with our websites
• determining the effectiveness of our marketing and services.

This can also apply to uses which are in your interests and those of others such as those which

• identify and prevent fraud or other illegal activity
• enhance the security of our network and information systems

You have the right to object to our processing of your personal data for our Legitimate Interests at any time.

Please contact us if you have any further questions about our use of your data in our legitimate interests.

When do we collect your personal data?

• When you visit any of our websites.
• When you register with us including when, as a job seeker, you send us a copy of your CV.
• When you engage with us on social media.
• When you contact us by any means with queries, complaints etc or ask our staff to help you.

What happens if you don’t give us your data?

You can enjoy our website without giving us your personal data.

However, some personal data is needed so we can supply you with the services and information you have purchased or requested.

What personal data do we collect, why and how do we use it?

We will make it clear when we collect personal data and will explain what we intend to do with it. e.g. when you register with us the form you use to sign up has a link to this Privacy Notice.

Some examples of when we may collect and use your personal data are given in general terms below.

Contact Information

We collect your name, address and email contact telephone numbers. This information is required in order to create an account.

How we use it

We use this information to keep in touch with you and provide the services you have asked us to such as putting you in touch with an appropriate employer (as a job seeker) or passing CVs and applications to you as an employer.

We may also use your contact information to send you survey and feedback requests to help improve our services. These messages will not include any promotional content and our legitimate interest to do this is to help make our products or services more relevant to you as an existing user.

Biographical Information

Job Seekers:Full record of sea service and Seaman Book details, Current role and Job title, details of any Certificates of Competency or Licences held, courses attended and certificates obtained, hours done with various DP systems, details of employment referees, languages spoken. This may also include any other details our clients may ask for.

Employers: Your position within the company you represent.

How we use it

Job Seekers: We use this information to create a profile to match you to suitable vacancies with the employers who have engaged us. We then forward that profile to the appropriate employer(s) so they can take over the rest of the recruitment process. We do this to provide you with the service you have asked us to and in our joint legitimate interest to provide you with the best career progression opportunities we can.

Employers: We use this as part of our record of your company to ensure that applications are forwarded to the appropriate person within an organisation.

Financial information

Job Seekers: We don’t ask you for bank or payment card details, but may ask you to provide details of your minimum salary or day rate expectation as part of creating your profile and dialogue.

Employers: We may record information about how you choose to pay our fees.

How we use it

Job Seekers: We use this information as part of your profile which recruiters can see either when you apply for a job or when we forward your profile to them. This is part of our providing the service you have asked us to.

Employers: We use this information in our legitimate business interest in providing a smooth invoicing process, maintaining our accounting records and preventing fraud.

Data about your preferences

Job Seekers: The type of role you are looking for, vessel type, desired location, desired salary, tour of duty preferences, desired contract type.

Employers: details of the candidates you require e.g. roles, level of experience, availability etc

How we use it

Job Seekers: We use this information to provide you with the job placement services you ask us to. We also use this information in our legitimate business interests to provide you with alerts about roles you may be interested in.

Employers: We use this information to provide you with the candidate sourcing services you ask us to. We also use this information in our legitimate business interests to provide you with alerts about candidates you may be interested in.

Sensitive data

This is data about your racial or ethnic origin, health data, sex life or sexual orientation, political opinions or affiliations, religious or philosophical beliefs, genetic or biometric data.

Job seekers: We do not ask for or need any of this type of data for our own purposes. We may however ask for copies of your photographic identity documents and certain information such as health information or blood group where required by an employer as part of their screening process. We will obtain your consent to gather and share this information or ask you to provide it direct to the employer.

We also ask for information about your place of birth, nationality, language proficiency and rights to work in various locations.

Please be aware that you make this data available to employers if you choose to upload a CV which contains this type of information. Please ensure your CV contains only information you are happy to share with recruiters who may view your profile before you upload it.

Employers: We do not ask for or need any of this type of data.

How we use it

Job Seekers: Including where we gather your medical certificate or photo id information with your consent, we gather this information because it is part of the assessment of your suitability for a role and is information required under legislation in certain areas e.g. establishing your right to work in certain jurisdictions.

Your contacts with us

Details of your contact with us online, by email, telephone, the postal service or by using one of our apps. Your contact details including social media username(s).

How we use it

To respond to your queries and complaints. We need to use the information we hold about you to respond. We may also keep a record of your contacts with us to inform any future communication with you. We do this on the basis of our contractual obligations to you and our legitimate interests in providing you with a good level of service and understanding how we can improve our service based on your experience.

The data of children

We only collect the information we need to provide career services to registered job seekers over the age of 18.

We do not attempt to solicit or knowingly receive information from children under 16.

Technical Data that identifies you and how you use

http://www.cpmarineuk.com

Your IP address, login information, browser type and version, session ID, time zone setting, browser plug-in types, geolocation information, operating system and version.

The pages you visit, the path you take through our site, page load times, errors you receive, how long you stay on our pages, what you do on those pages, how often, details of jobs viewed or applied for and any search terms you entered etc

This information is normally gathered using cookies in your web browser. Learn more about our use of cookies and similar technologies.

How we use it

We use this information in our legitimate business interests such as improving and personalising our website and online services and to protect our business and the information we hold from fraud and other illegal activities.

The use of your data for marketing purposes

We do not carry out marketing for any services other than:

Job Seekers: details of roles we have available.

Employers: details of job seekers we have registered who are looking for a new role.

We may use your contact information to send you relevant, personalised communications by post in relation to available roles and job seekers. We’ll do this on the basis of our legitimate business interest in providing recruitment and career services to you.

You can withdraw your consent or object to our using your contact details to market to your business in our legitimate interests at any time.

You can withdraw your consent at any time as described earlier in this notice.

How we protect your personal data

We maintain physical, technical and administrative safeguards to protect your personal data.

We restrict access to your personal data to clients who need that information to perform their role and help provide services to you.

Finally, our clients are aware of our privacy policy requested to keep your personal information secure and confidential in line with this Privacy Policy.

Please contact us if you have any questions about the security measures we have in place.

How long will we keep your personal data?

We’ll only keep your personal data for as long as is necessary for the purpose for which it was collected and to comply with applicable law or resolve disputes. This means we set retention periods for all the personal data we collect.

When that retention period has passed, your data will either be completely deleted in a secure manner or anonymised e.g. by aggregation with other data in a non-identifiable way for statistical analysis and business planning purposes.

Some examples of customer data retention periods:

Job Seekers

We keep your account, the information you have provided in your profile and details of employers we forwarded your information to for as long as you remain active with us and we are trying to place you in a role.

Once we have successfully placed you, where possible, we will make a note on our records of the date your contract ends and where appropriate, subject to further roles being available, then, we may look to contact you at that point.

If we have not been able to place you (or you source a contract elsewhere) we will keep your profile on our active register for up to two years or subject to other additional legal obligations. Then we can look to contact you over that period to establish your employment status and whether we have any suitable roles for you.

Once we have had no contact from you for two years we will delete all your personal information but we may retain some of your profile in an anonymised format in order to inform our business planning and research.

Depending on the roles we put you forward for or place you in, there are circumstances where we have a legal obligation under national legislation to keep your details for longer than the above but this is information we can provide you with on request.

You can, as described earlier in this notice, ask us to delete your information at any time.

Employers

We keep your account and the information you have provided in your profile for as long as we have an active business relationship with you.

After our business relationship ends we will retain your information and information about your business transactions with us for up to six years to comply with our legal obligations such as those to HMRC.

After this point we may retain details of your relationship with us in an anonymised format in order to inform our business planning and research.

Who do we share your personal data with?

We do not reveal your personal data to third-parties unless:

• you request or authorise it (e.g. when you apply for a job);
• the information is provided to comply with the law (for example, to comply with a court order), enforce an agreement we have with you, or to protect our rights, property or safety, or the rights, property or safety of our employees or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction;
• the information is provided to our sub-contractors, agents, vendors or service providers who perform functions on our behalf; or
• to address disputes, claims, or to persons demonstrating legal authority to act on your behalf.

Examples of the kind of third parties we work with

All: IT, software and SaaS companies who support our website and other business systems.

Job Seekers: Employers, National immigration and security services

Employers: Job Seekers, HMRC, National immigration and security services

Sharing your data with third parties for their own purposes:

We may, from time to time, expand, reduce or sell C P Marine UK Ltd and this may involve the transfer of divisions or the whole business to new owners. If this happens, your personal data will, where relevant, be transferred to the new owner or controlling party, under the terms of this Privacy Notice.

Where your personal data may be processed

We always opt to have your data stored in the UK or EU where possible. This includes instances where a vendor offers a choice of storage locations but where the EU option is more expensive.

However, due to the global nature of the roles we source, we will need to share your personal data with third parties and suppliers outside the European Economic Area (EEA).

C P Marine UK Ltd transfers personal data outside the EEA only:

• to countries where there is an adequacy decision in place i.e. the EU has formally determined that there is a sufficient level of protection in place under that nation’s data protection laws; or
• where the recipient is certified under an internationally recognised privacy framework which helps to ensure your protection; or
• with your consent; or
• to perform a contract with you; or
• to perform a contract with another in your interests; or
• to fulfil a compelling legitimate interest of C P Marine UK Ltd in a manner that does not outweigh your rights and freedoms.

Any transfer of your personal data will follow applicable laws and we will always treat your personal information in line with the principles of this Privacy Notice.

This includes measures such as imposing contractual obligations on the recipient with respect to how they treat your data.

If you would like more information about how we protect your rights and freedoms when transferring your data outside the EEA, please contact our Data Protection Officer.

Protecting your data transferred

Due to the international nature of the service we provide, we are not always able to ensure that the data protection legislation in place in the country your data is transferred to provides the same level of protection as the EU.

We will however, help to protect your rights and freedoms by passing only the minimum data necessary to provide the prospective employer with enough details to consider you for the role advertised or for them to make independent contact with you where appropriate.

ICO Checklist

What to provide

We provide individuals with all the following privacy information:

• The name and contact details of our organisation.
• The name and contact details of our representative (if applicable).
• The contact details of our data protection officer (if applicable).
• The purposes of the processing.
• The lawful basis for the processing.
• The legitimate interests for the processing (if applicable).
• The categories of personal data obtained (if the personal data is not obtained from the individual it relates to).
• The recipients or categories of recipients of the personal data.
• The details of transfers of the personal data to any third countries or international organisations (if applicable)
• The retention periods for the personal data.
• The rights available to individuals in respect of the processing.
• The right to withdraw consent (if applicable).
• The right to lodge a complaint with a supervisory authority.
• The source of the personal data (if the personal data is not obtained from the individual it relates to).
• The details of whether individuals are under a statutory or contractual obligation to provide the personal data (if applicable, and if the personal data is collected from the individual it relates to).
• The details of the existence of automated decision-making, including profiling (if applicable).

When to provide it

• We provide individuals with privacy information at the time we collect their personal data from them.

If we obtain personal data from a source other than the individual it relates to, we provide them with privacy information:

• within a reasonable of period of obtaining the personal data and no later than one month;
• if we plan to communicate with the individual, at the latest, when the first communication takes place; or
• if we plan to disclose the data to someone else, at the latest, when the data is disclosed.

How to provide it

We provide the information in a way that is:

• concise;
• transparent;
• intelligible;
• easily accessible; and
• uses clear and plain language.

Changes to the information

• • We regularly review and, where necessary, update our privacy information.

If we plan to use personal data for a new purpose, we update our privacy information and communicate the changes to individuals before starting any new processing.

Best practice – drafting the information

• We undertake an information audit to find out what personal data we hold and what we do with it.
• We put ourselves in the position of the people we’re collecting information about.
• We carry out user testing to evaluate how effective our privacy information is.

Best practice – delivering the information

When providing our privacy information to individuals, we use a combination of appropriate techniques, such as:

• a layered approach;
• dashboards;
• just-in-time notices;
• icons; and
• mobile and smart device functionalities.