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Jonathan Lee Recruitment
 
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 * Data Protection Policy


DATA PROTECTION POLICY



1.            INTRODUCTION

This Data Protection Policy outlines the way in which we manage the data we hold
for our Candidates (“you”), for and about whom it is necessary to hold and
process data in the provision of our recruitment and associated services.

For the purpose of applicable data protection laws (including but not limited to
the General Data Protection Regulation (Regulation (EU) 2016/679) (“GDPR”), the
companies to which this document relates are: Jonathan Lee Recruitment Limited,
Jonathan Lee Contracts Limited, Jonathan Lee Executive Search Limited and
Jonathan Lee Design Services Limited (together, the “Jonathan Lee Group”, “we”
or “us”).

1.1          ABOUT THIS POLICY

The Jonathan Lee Group operates as a data controller of Candidate personal data
under the GDPR, which means we are responsible for deciding how we hold and use
your personal information.  This Data Protection Policy is intended for
individuals applying for work with us as a Candidate.  It makes you aware of how
and why your personal data will be used and how long it will usually be retained
for.  It provides you with certain information that must be provided under the
GDPR, including information about your rights in respect of your personal data.

1.2          CANDIDATES

“Candidates” includes applicants for all roles advertised or promoted by the
Jonathan Lee Group including permanent, contract and interim positions with any
Jonathan Lee Group clients; as well as people who have supplied a speculative CV
to the Jonathan Lee Group not in relation to a specific job.  Individual
contractors, interim consultants and employees of suppliers or other
third-parties put forward for roles with the Jonathan Lee Group’s clients as
part of a managed service provision or otherwise, will also be treated as
Candidates for the purposes of this Data Protection Policy.

1.3          OUR COMMITMENT

The Jonathan Lee Group is committed to presenting Candidates with attractive and
relevant opportunities with organisations that we consider will be relevant to
your career aspirations.  In order to achieve this, it is necessary for us to
process information about you from the various sources we have available to us.
 We will only ask for and use information about you that is necessary for us to
provide you and our clients with the very best levels of service.  There may
also be a need, in providing recruitment services, for us to provide information
to carefully selected suppliers and other 3rd parties in order to meet our
contractual and legal obligations.  Our commitment to you is that we will only
process your personal data to the extent required in order to meet these
objectives.

1.4          GENERAL PRINCIPLES

We will comply with data protection laws and principles in respect of your
personal data, which means that your personal data will be:

 * used lawfully, fairly and in a transparent way

 * collected only for valid purposes that we have clearly explained to you and
   not used in any way that is incompatible with those purposes

 * relevant to the purposes we have told you about and limited only to those
   purposes

 * accurate and kept up to date by us

 * kept only for as long as is necessary

 * kept securely whilst we hold it

2.            WHAT KIND OF DATA WE HOLD ABOUT YOU

Depending on the relevant circumstances and applicable legal and contractual
requirements, we may collect, store and use some or all of the information
listed below to enable us to provide you with candidate services.

TYPES OF GENERAL DATA HELD:

 * Name

 * Age/date of birth

 * Birth number

 * Sex/gender

 * Photograph

 * Marital status

 * Contact details (postal address, email address(es) and telephone number(s))

 * Education details

 * Qualifications, psychometric or other test results

 * Current or previous job title(s)

 * Employment history

 * Emergency contacts and details of any dependants

 * Referee details

 * Immigration status (to determine Right to Work)

 * Nationality/citizenship/place of birth

 * A copy of your driving licence and/or passport/identity card

 * Financial information (i.e. bank account information to facilitate
   remuneration payments)

 * National Insurance Number (Social Security Number) and any other tax-related
   information

 * Details about your current remuneration, pensions and benefits arrangements

 * Your contractual notice period

 * Information on your interests, needs and aspirations regarding future
   employment

 * Additional information that you choose to provide to us in your CV or
   application, during interview or in any subsequent communications between

 * Additional information that your named referees provide to us about you

 * Additional information that our clients may provide to us about you, or that
   we find from other third-party sources

 * IP address

 * The dates, times and frequency with which you access our services

 * CCTV footage if you attend our offices in person


2.2          TYPES OF SENSITIVE DATA HELD:  

Some of the personal data we collect, store and use falls into the following
"special categories" of more sensitive personal information:

 * Information about your race or ethnicity, religious beliefs, sexual
   orientation and political opinions

 * Information about your health, including any medical condition, health and
   sickness records

 * Information about criminal convictions and offence

We will use your particularly sensitive personal information in the following
ways:

 * We will use information about your disability status or medical requirements
   to consider whether we (or our clients) need to provide appropriate
   adjustments during the recruitment process, for example whether adjustments
   need to be made during a test or interview

 * We will use information about your race or national or ethnic origin,
   religious, philosophical or moral beliefs, or your sexual life or sexual
   orientation, to ensure meaningful equal opportunity monitoring and reporting

2.3          INFORMATION ABOUT CRIMINAL CONVICTIONS

We envisage that we may need to process information about criminal convictions
where we have been asked to do so by our clients, or where a particular role
requires a criminal record check.  Where this is the case we will collect
information about your criminal convictions history if we or our client would
like to offer you the position.  We may be required by our client to carry out a
criminal records check in order to confirm that there is nothing in your
criminal convictions history which makes you unsuitable for a particular role.

We have in place appropriate safeguards which we are required by law to maintain
when processing such data.

For additional data we may collect, store and use about you as a website user,
please refer to our website privacy notice and cookie policy.

3.            HOW WE COLLECT DATA ABOUT YOU

We collect Candidate personal data in 3 main ways:

a) Personal data that you provide directly to us

b) Personal data that we receive from other sources

c) Personal data that we collect automatically

3.1          PERSONAL DATA THAT YOU PROVIDE DIRECTLY TO US

You can provide your personal data directly to us in the following ways:

 * By entering your details on the Jonathan Lee Group website as part of our
   online registration process

 * By mailing or delivering by hand a hard copy CV (alone or with a covering
   letter attached) to any Jonathan Lee Group recruitment event or office

 *  By emailing your CV (alone or with a covering letter attached) to a Jonathan
   Lee Group representative

 * By applying for a job through a third-party job aggregator, which then
   redirects you to the Jonathan Lee Group website

 * By entering your personal details into a Jonathan Lee Group microsite

 * By entering your personal details into a social media channel (for example,
   LinkedIn), which then re-directs you electronically to the Jonathan Lee Group
   website

3.2          PERSONAL DATA WE RECEIVE FROM OTHER SOURCES

The following methods outline the ways in which we can receive personal data
about you as a Candidate:

 * Referees may disclose personal information about you in the course of
   providing a professional or personal reference

 * Clients who have previously interviewed or engaged you as a Candidate may
   share personal information about you with us, in the course of providing
   feedback on your performance at interview or during placement

 * If our client asks us to carry out a credit and background check on potential
   Candidates we will use third-party credit reference agencies (based inside
   the EEA) for this purpose where relevant to your application

 * If our client asks us to carry out an ID verification and background check on
   potential Candidates we will use third-party ID verification and screening
   companies (based inside the EEA) for this purpose where relevant to your
   application or to corroborate information you give us directly

 * If our client asks us to carry out a criminal record check we will use
   Criminal Records Services Limited (or another criminal record checking
   organisation based inside the EEA) to obtain information in respect of any
   criminal convictions, where relevant to your application or to a particular
   role    

 * In conducting searches on third-party websites or applications (such as
   Facebook, LinkedIn, Twitter, YouTube or other sites which are based inside
   and outside the EEA) we may obtain publicly available information about you
   as relevant to your application or to a particular role

 * If you ‘like’ or ‘follow’ Jonathan Lee Group pages or posts on social media
   (Facebook, Twitter, LinkedIn, YouTube) we will receive your personal
   information from those sites, which are based outside the EEA

 * We may receive your personal information through a ‘second tier supplier’ who
   shares personal information about you with us.  Where we act as a Managed
   Service Provider (MSP) or Managed Vendor (MV), second tier suppliers (i.e.
   other agencies based [inside OR outside] of the EEA who supply recruitment
   services to us) will refer us your information in order that we may contact
   you about relevant opportunities.  We will always tell you the identity of
   the second-tier supplier that we have obtained your information from when we
   initially contact you in this way.

3.3          PERSONAL DATA WE COLLECT AUTOMATICALLY

 * We may collect personal data about you when you access our website via
   cookies – please see our cookie policy
   
   here for further details

 * We may also collect analytical data about you when you open and click through
   emails we send to you

 * You will not be subject to decisions that will have a significant impact on
   you based solely on automated decision-making

4.            HOW AND WHY WE WILL USE YOUR DATA

We will use the personal information we collect about you for the following
broad purposes (“lawful purposes” under the GDPR):

 * Where we need to perform the contract we have entered into with you

 * Where we need to comply with a legal obligation

 * Where it is necessary for our legitimate interests (or those of a
   third-party) and your interests and fundamental rights do not override those
   interests

 * For some activities, such as marketing communications, where you have given
   your consent.

More specifically we use your personal data for the following purposes: 

 * To assess your skills, qualifications, and suitability for applicable roles

 * To carry out background and reference checks, where applicable

 * To communicate with you about the recruitment process and roles which may be
   relevant or of interest to you

 * To keep records related to our hiring processes

 * To analyse and take steps to improve the services we provide to our clients
   and Candidates

 * To comply with legal or regulatory requirements

4.1          FURTHER INFORMATION ON HOW AND WHY WE WILL USE YOUR DATA

Legitimate Interests

It is in our legitimate interests to decide whether to contact you about
particular roles and/or forward your application to appropriate clients and
assist in taking your application forward.  This is because it is beneficial to
our business to recommend suitable and appropriately qualified Candidates to our
clients and to help match our Candidates to appropriate roles that are relevant
to the Candidate’s wishes.  

We may also provide a prospective employer or client with information you have
provided to us (for example, the results of psychometric or skills tests) or to
confirm your references, qualifications and criminal record, where this is
appropriate and in accordance with EU laws.  We share this type of information
in order to further our legitimate interests as a profit-making business
providing recruitment services to our clients.

We may also contact you more generally to discuss and align your employment
needs and career development with opportunities we can present you with and
relevant information and articles we can provide to you.  This is because it is
in our legitimate interests to ensure that our Candidates are offered relevant,
appropriate opportunities which correspond with their own career aspirations.

We may also from time to time provide the opportunity for you to contribute to
interactive services such as surveys or social media content.  This allows us to
differentiate ourselves as a recruitment provider and compete within our market
and is therefore within our legitimate interests to process your data in this
way. We will always check beforehand that you are happy for us to use your data
in this way. 

We may send you direct marketing material from time to time. The use of your
personal data for this purpose will be proportionate, have a minimal privacy
impact, and will be highly relevant to the service provided. You will always be
given the opportunity to unsubscribe from such material.

Contractual Obligations

We may also need to process your personal information for the purposes of
entering into or performing a contract of employment or contract for services
with you.  This will include carrying out our internal administrative processes
such as payroll processes if we engage you as a contractor/consultant, or in
order to raise invoices.

Legal Obligations

We are required as part of our recruitment process to seek, confirm and hold
certain Right to Work documents about you such as a passport or ID card copy,
proof of address or UK driving licence in order to process you as a Candidate
for a vacancy that could result in your employment within the EU.

We must also comply with our wider legal obligations. We may therefore share
your data in connection with crime detection, tax collection or litigation
activity, whether actual or anticipated.

If You Cannot Provide Any Relevant Data

If you fail to provide information when requested, which is necessary for us to
consider or progress your application (such as evidence of qualifications or
work history), we may not be able to progress your application successfully or
recommend you to our full range of clients.  For example, if one of our clients
requires that employees are subject to a credit check or references for a
particular role and you fail to provide us with relevant details, we may not be
able to take your application further.

5.            HOW WE PROTECT YOUR DATA

We have put in place appropriate security measures to prevent your personal
information from being accidentally lost, used or accessed in an unauthorised
way, altered or disclosed.  In addition, we limit access to your personal
information to those employees, agents, contractors and other third-parties who
have a business need-to-know. They will only process your personal information
on our instructions and they are subject to a duty of confidentiality.

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

6.            SHARING YOUR DATA WITH THIRD-PARTIES

Where appropriate and in accordance with data protection laws, we may share your
personal data with the following third-parties:

 * Any of the companies within the Jonathan Lee Group

 * Individuals and organisations whose details you have provided to us, who hold
   information related to your reference or application to work with us.  This
   will include current, past or prospective employers, educators and examining
   bodies and employment and recruitment agencies, who may be based inside or
   outside of the EEA as applicable

 * Tax, audit, or other legal, governmental or regulatory authorities based
   inside the EEA, when we believe in good faith that the law or other
   regulation requires us to share this data (for example, because of a request
   by a tax authority or in connection with any litigation, anticipated or
   actual)

 * Third-party service providers based inside or outside of the EEA who perform
   functions on our behalf (including external consultants, business associates
   and professional advisers such as lawyers, auditors and accountants,
   technical support functions and IT consultants carrying out testing and
   development work on our business technology systems)

 * Third-party outsourced IT and document storage providers based [inside OR
   outside] of the EEA where we have an appropriate processing agreement (or
   similar protections) in place 

 * Marketing technology platforms and suppliers based [inside OR outside] of the
   EEA

 * Potential employers and other recruitment agencies/organisations based
   [inside OR outside] of the EEA to increase your chances of finding employment
   (provided that you have given your consent)

 * Third-party partners, job boards and job aggregators based [inside OR
   outside] of the EEA if we believe this will benefit your career prospects
   (provided that you have given your consent

 * Managed service providers based [inside OR outside] of the EEA who operate as
   an intermediary between Jonathan Lee Group and its clients

 * Third-parties who we may retain to provide services such as reference,
   qualification and criminal convictions checks, to the extent that these
   checks are appropriate and in accordance with local laws

 * If Jonathan Lee Group or any of its constituent parts merges with or is
   acquired by another business or company in the future (or is in meaningful
   discussions about such a possibility), we may share your personal data with
   the (prospective) new owners of the business or company but will implement
   appropriate technical and organisational measures to protect any data that is
   shared (such as anonymization and the imposition of binding confidentiality
   obligations where appropriate).

If you would like further information about the specific identities of the
third-parties listed above, please contact us at the following email address:
dataprotection@jonlee.co.uk.  To ensure that your personal information is
subject to an adequate level of protection, the Jonathan Lee Group has in place
appropriate procedures with the third-parties we share your personal data with
to ensure that your personal information is treated securely by those
third-parties in a way that is consistent with and which respects the law on
data protection. Our third-party suppliers do not use your personal data for
their own purposes, and we only permit them to process your personal data in
accordance with our instructions.

7.            DATA RETENTION PERIOD

7.1          CANDIDATES WHO DO NOT BECOME CONTRACTORS/CONSULTANTS

We will delete your personal data within 6 months following the second
anniversary of our last meaningful contact with you individually or the entity
through which you or your services were engaged.  Your personal data will be
deleted from all of our systems unless we believe in good faith that the law or
other regulation requires us to preserve it.  Examples of reasons to retain your
personal data may include compliance with tax authority requirements or in
connection with any anticipated legal claim or litigation.  After this period,
your data will no longer be relevant for the purposes for which it was collected
and it will be securely destroyed in accordance with applicable laws and
regulations.

"Meaningful contact" with Candidates will include any of the following:

 * Communication between the Jonathan Lee Group and you, the Candidate (verbal,
   written or via online services).  This includes any communication relating to
   vacancies you wish to be considered for or which we consider you suitable for

 * Communication by you submitting your CV, application form and/or covering
   letter to us through any channel

 * Communication by you clicking through links included in emails or other
   electronic messages received such as marketing communications

 * Receiving, opening or reading of an email or other digital message from us,
   without taking any further action, will not count as meaningful contact.

7.2          CANDIDATES WHO BECOME CONTRACTORS/CONSULTANTS

For those Candidates who are placed in a contract position, and therefore become
a consultant engaged via a third-party company or other entity, the relationship
changes to a contractual one.  As a result we will retain your data for six
years (or longer, if required by statute or other regulation).  Your data and
that relating to the company or other third-party entity through which you
supply services, will be deleted within six months of the sixth anniversary of
the termination or expiry of our contractual relationship with the entity
through which you supply your services (or longer as required by statute or
other regulation).

If, after six years following the termination or expiry of our contractual
relationship, we continue to have meaningful contact with you as a Candidate
(for example if you continue to wish to be considered for contract or permanent
recruitment opportunities), we will continue to retain the data relating to you
and the company or other third-party entity through which you supply services
while we maintain meaningful communication with you.  We will delete your data
within 6 months following the second anniversary of our last meaningful contact
with you.

"Meaningful contact" with contractors/consultants will include any of the
following:

 * Communication between the Jonathan Lee Group and you, the
   contractor/consultant/Candidate and/or the company or entity that supplies
   your services (verbal, written or via online services).  This communication
   includes contractual, payment or compliance related matters.  It also
   includes communication relating to vacancies you wish to be considered for or
   for which we consider you suitable, should you wish to remain as a Candidate
   (either directly or via a third-party company or other entity) during or
   after your contractual relationship with us comes to an end

 * Communication by you submitting your CV, application form and/or covering
   letter to us through any channel

 * Communication by you clicking through links included in emails or other
   electronic messages received such as marketing communications

 * Receiving, opening or reading of an email or other digital message from us,
   without taking any further action, will not count as meaningful contact.

Meaningful contact with you means meaningful contact as described above, either
with you directly or, where applicable, with the company or entity which
supplies your services.  Where we are notified by such company or entity that it
no longer has that relationship with you, we will delete your data within 6
months of the second anniversary of our last meaningful contact with the company
or third-party entity through which you supply services; or, if later, within
six months following the second anniversary of our last meaningful contact
directly with you.

8.            YOUR RIGHTS IN RESPECT OF YOUR PERSONAL DATA

Under the GDPR, as an EU citizen or individual within the EU you retain various
rights in respect of your data under certain circumstances, even after you have
provided it to us.

To get in touch about these rights, please contact us.  We will seek to deal
with your request without undue delay, and in any event within one month
(subject to any extensions to which we are lawfully entitled).  Please note that
we may keep a record of your communications to help us resolve any issues which
you raise.

8.1          RIGHT TO OBJECT TO PROCESSING

You have the right to object to us processing your personal data in certain
circumstances.  This right is most likely to be enforceable by you where we are
processing data for one of the following reasons:

 * To exercise our legitimate interests

 * To enable us to perform a task in the public interest or exercise official
   authority (for example, where required to provide information to law
   enforcement agencies and/or governmental bodies such as HMRC)

 * To send you direct marketing materials 

8.1.1      CANDIDATE DATA PROCESSING IN THE FURTHERANCE OF LEGITIMATE INTERESTS 

The GDPR states that we can process your data where it "is necessary for the
purposes of the legitimate interests pursued by [us] or by a third-party, except
where such interests are overridden by the interests or fundamental rights or
freedoms of [you] which require protection of personal data."

The activities identified in Section 4 above (HOW AND WHY WE WILL USE YOUR DATA)
are undertaken for our legitimate interests to help us to provide you with a
professional, personalised, and effective service.  You do, however, have the
right to object to us processing your personal data on this basis.  If your
objection relates to us processing your personal data on the basis of legitimate
interests, we must act on your objection by ceasing the activity in question
unless:

 * we can demonstrate that we have compelling legitimate grounds for processing
   the data which overrides your interests

 * we are processing your data for the establishment, exercise or defence of a
   legal claim

8.1.2      CANDIDATE DATA PROCESSING FOR DIRECT MARKETING

If your objection relates to direct marketing, we will act on your objection by
ceasing this activity.

8.2          RIGHT TO WITHDRAW CONSENT FOR PROCESSING

Where you have provided your consent for us to process your personal data for
certain activities (for example, to contact you about potential roles that may
be of interest to you, or for marketing activities), you may withdraw this
consent at any time and we will cease to carry out the specific activity that
you previously consented to unless we consider that there is an alternative
reason to justify our continued processing of your data. If this is the case we
will inform you of the reason(s) for our continued processing.

If you have posted your CV or other related personal information publicly on a
job board or professional networking site, we understand that you have given
your consent via your application on the job board or networking site for
Jonathan Lee Group to collect and otherwise use your personal data in order to
contact you to offer or provide recruitment services to you.  We will review
your publicly posted information to assess your skills, qualifications and other
relevant information provided in relation to the vacancies we are sourcing
Candidates for.  If we consider you may be suitable for a potential role we will
share your information with prospective employers, but we will never pass your
details to a prospective employer without your explicit consent.

8.3          RIGHT TO REQUEST ACCESS – DATA SUBJECT ACCESS REQUESTS (DSARs)

You may ask us to confirm what information we hold about you at any time, and to
provide a copy of the personal data we hold. In order to process your request we
may need to verify your identity and ask for additional information regarding
your request.  If we provide you with access to the information we hold about
you, we will not charge you for this unless your request is "manifestly
unfounded or excessive".  If you request further copies of this information from
us, we may charge you a reasonable administrative fee where legally permissible.
 Where we are legally permitted to do so, we may refuse your request.  If we
refuse your request we will inform you of our reasons for doing so.

8.4.         RIGHT TO ERASURE OF DATA 

You have the right to request that we erase your personal data in certain
circumstances.  Normally, a valid request must meet one of the following
criteria:

 * The data is no longer necessary for the purpose for which we originally
   collected and/or processed it

 * You have withdrawn your consent to us processing your data and there is no
   other valid reason for us to continue processing

 * The data has been processed unlawfully (i.e. in a manner which does not
   comply with the GDPR)

 * It is necessary for the data to be erased in order for us to comply with our
   legal obligations as a data controller

 * For any processing carried out for our legitimate interests, you have
   objected to the processing and we are unable to demonstrate overriding
   legitimate grounds for our continued processing

We are legally entitled to refuse to comply with your request where our
continued processing is necessary for one of the following reasons: 

 * to exercise a right of freedom of expression and information

 * to comply with legal obligations or for the performance of a public interest
   task or exercise of official authority

 * for public health reasons in the public interest

 * for archival, research or statistical purposes

 * to exercise or defend a legal claim

When complying with a valid request for the erasure of data we will take all
reasonably practicable steps to delete the relevant data.

8.5          RIGHT TO RESTRICT FURTHER PROCESSING OF DATA

You have the right to request that we restrict our processing of your personal
data in certain circumstances. This means that we can only continue to store
your data and will not be able to carry out any further processing activities
with it until either:

i)       one of the circumstances listed below is resolved

ii)      you consent to further processing

(iii)    further processing is necessary for another reason (i.e. for the
establishment, exercise or defence of legal claims, for the protection of the
rights of another individual, or for reasons of important public interest)

You are entitled to request that we restrict the processing of your personal
data in the following circumstances:

 * Where you dispute the accuracy of the personal data that we are processing
   about you.  In this case, our processing of your personal data will be
   restricted for the period during which the accuracy of the data is verified

 * Where you object to our processing of your personal data for our legitimate
   interests.  Under these circumstances, you can request that the data
   processing be restricted while we verify our grounds for processing your
   personal data

 * Where our processing of your data is unlawful, but you would prefer us to
   restrict our processing of it rather than erasing your data from our systems
   altogether

 * Where we have no further need to process your personal data but you require
   the data to continue to be stored in order to establish, exercise, or defend
   legal claims

If we have shared your personal data with third-parties, we will notify them
about the restricted processing unless this is impossible or involves
disproportionate effort on our part. We will, notify you before lifting any
restriction on processing your personal data.

8.6          RIGHT TO RECTIFICATION OF DATA

You have the right to request that we rectify any inaccurate or incomplete
personal data that we hold about you.  If we have shared this personal data with
third-parties, we will notify them about the rectification and ask them to
correct their records unless this is impossible or involves disproportionate
effort. Where appropriate, we will also tell you which third-parties we have
disclosed the inaccurate or incomplete personal data to.  Where we think that it
is reasonable for us not to comply with your request, we will explain our
reasons for this decision.

8.7          RIGHT OF DATA PORTABILITY

If you wish, you have the right to ask us to transfer your personal data between
data controllers.  To allow you to do so, we will provide you with your data in
a commonly used machine-readable format that is password-protected so that you
can transfer the data to another provider. Please note that this right of data
portability does not apply to all data we hold about you, but applies to:

i)     personal data that we process automatically (i.e. without any human
intervention)

ii)     personal data provided by you

iii)    personal data that we process based on your consent or in order to
fulfil a contract

8.8          RIGHT TO LODGE A COMPLAINT WITH A SUPERVISORY AUTHORITY

You also have the right to lodge a complaint with your local supervisory
authority, which in the UK is the Information Commissioner’s Office.

9.            EXERCISING YOUR RIGHTS AND FURTHER INFORMATION

If you would like to exercise any of these rights, or withdraw your consent to
the processing of your personal data (where consent is our legal basis for
processing your personal data), details of how to contact us can be found here.
 Please note that we may keep a record of your communications to help us resolve
any issues which you raise.

You may unsubscribe from direct marketing communications and SMS messaging at
any time by clicking the “Unsubscribe” link in each message.

It is important that the personal information we hold about you is accurate and
current.  Please keep us informed if your personal information changes during
the period for which we hold your data.

10.          INTERNATIONAL TRANSFERS OF YOUR DATA

In order to ensure you are presented with the best service possible, your data
may be transferred:

 * between and within Jonathan Lee Group entities and offices

 *  to third-parties, including advisers or other suppliers to the Jonathan Lee
   Group

 * to overseas clients

 * to clients within the UK or EEA who may, in turn, transfer your data
   internationally

 * to our cloud-based storage provider

 * to other third-parties who may be based outside of the EEA

We will only transfer data outside of the EEA (i.e. the Member States of the
European Union, together with Norway, Iceland and Liechtenstein) where it is
compliant with data protection laws and the means of transfer provides adequate
safeguards in relation to your data, for example:

 * By way of data transfer agreement, incorporating the current standard
   contractual clauses approved by the European Commission for the transfer of
   personal data by data controllers in the EEA to data controllers and
   processors in jurisdictions without adequate data protection laws

 * By ensuring that any US-based organisations we transfer data to have signed
   up to the EU-US Privacy Shield Framework for the transfer of personal data
   from the EEA to the United States of America (or ensuring that any equivalent
   framework agreement is in place in respect of other jurisdictions)

 * By transferring your data to a country whose data protection laws have been
   found to be adequate by the European Commission

 * Where you have expressly consented to the data transfer (having been informed
   of any relevant risks involved)

Please contact us here if you would like further information about the specific
mechanism used by us when transferring your personal data outside of the EEA.

TERM OF CONVENIENCE

This document applies to:

Jonathan Lee Recruitment Limited (company number 3724865) ICO registration
number Z4897240

Jonathan Lee Contracts Limited (company number 2796676) ICO registration number
Z6874342

Jonathan Lee Design Services Limited (company number 01357821) ICO registration
number ZA195457

Jonathan Lee Executive Search Limited (company number 08571640) ICO registration
number ZA008732



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