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Privacy Policy

Company Name: Site Operative Solutions Ltd

Company Contact details: Maxine Cadwallader – Data Protection Officer

Address: Unit 6, Folkes Farm, Folkes Lane, Upminster. RM14 1TH

Email: maxine.cadwallader@sosgroup.uk

Tel: 01277 849289

SOS AP09: SOS Privacy Policy

Topic: Data protection

Date: 19/08/2026

Version: 04

Site Operative Solutions Ltd are a recruitment business which provides work-finding services to its clients and work-seekers. The Company must process personal data (including sensitive personal data) so that it can provide these services – in doing so, the Company acts as a data controller.

You may give your personal details to the Company directly, such as on an application or registration form or via our website, or we may collect them from another source such as a jobs board. The Company must have a legal basis for processing your personal data. For the purposes of providing you with work-finding services and/or information relating to roles relevant to you we will only use your personal data in accordance with this privacy statement. At all times we will comply with current data protection laws such as UK General Data Protection Regulation (UK GDPR), the Data Protection Act 2018 and the Data (Use and Access) Act 2025,

Contents

1. Collection and use of personal data
a. Purpose of processing and legal basis
b. Legitimate interest
c. Statutory/contractual requirement
d. Special category and criminal offence data
e. Recipients of data

2. Information to be provided when data is not collected directly from the data subject
a. Categories of data
b. Sources of data

3. Overseas transfers

4. Data retention

5. Your rights

6. Login files

7. Links to external sites

8. Sale of the business

9. Data security

10. Changes to this privacy statement

11. Complaints or queries

1. Collection and use of personal data

a. Purpose of processing and legal basis

The Company will collect your personal data (which may include sensitive personal data) and will process your personal data for the purposes of providing you with work-finding 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.
 
Where necessary, we will use your data to carry out any legally required checks such as a Right To Work and Background Checks. Your data may also be used for obtaining references and any other employment-related checks.
 
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. Where we rely on Consent, you  may withdraw this at any time but this does not affect any data processing on a lawful basis. The legal bases we rely upon to offer our work-finding 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

b. Legitimate interest

This is where the Company has a legitimate reason to process your data provided it is reasonable and does not go against what you would reasonably expect from us.  Where the Company has relied on a legitimate interest to process your personal data our legitimate interests may include:
  • Managing our database and keeping work-seeker records up to date;
  • Providing work-finding services to you and our clients;
  • Contacting you to seek your consent where we need it;
  • Complying with applicable legal, regulatory and professional requirements.

c. Statutory/contractual requirement
The Company has 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.)  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 personal data we need to collect we may not be able to continue to provide work-finding services to you.

d. Special category and criminal offence data

Some information we hold, and process may be subject to legal protections.
Special category data may include health information including details of disabilities where this is relevant to workplace adjustments, occupational requirements etc. All special category data is processed in line with relevant clauses of UK GDPR and The Data Protection Act 2018.
 
Where required, we may hold and process information concerning criminal convictions and offences. This information will only be collected and used where it is necessary, lawful and meets guidance from all data protection law.

e. Recipient/s of data

The Company will process your personal data and/or sensitive personal data with the following recipients:
  • Clients (whom we may introduce or supply you to)
  • Former employers whom we may seek references from
  • Payroll service providers who manage payroll on our behalf or other payment intermediaries whom we may introduce you to
  • Other recruitment agencies in the supply chain
  • Providers of background, DBS and Right To Work Checks
  • Departments, regulators and public authorities where required by law

2. Information to be provided when data collected not from the data subject

Categories of data: The Company has collected the following personal data on you:

Personal data: -

  • Name, address, contact number, email address
  • Date of Birth
  • National insurance number
  • Nationality (through right to work check)
  • Qualifications & Competencies
  • References and information obtained from referees
  • Information and details of applications, assignments, payroll and availability.
  • Bank Details (Financial Data)

Sensitive personal data:

  • Health information (including whether you have a disability)
 
Criminal offence data
  • Criminal convictions and offences
  • Information from a background or DBS check

Source of the personal data: The Company sourced your personal data from:

  • You directly
  • Job boards i.e. CV Library, LinkedIn
  • A referee whose details you previously provided to us  
  • Clients and hirers
  • Software providers who we use to support our services including Support on the Spot

This information did not come from a publicly accessible source.

3. Overseas Transfers

The Company will not transfer the information you provide to us to countries outside the European Economic Area (‘EEA’) for the purposes of providing you with work-finding services. The EEA comprises the EU member states plus Norway, Iceland and Liechtenstein.

4. Data retention


The Company 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 work-seeker 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 work-finding services.
 
We must also keep your payroll records, holiday pay, sick pay and pensions auto-enrolment records for as long as is legally required by HMRC and associated national minimum wage, social security and tax legislation. This is currently 3 to 6 years. Any statutory requirements will take precedence over general retention periods.
 
Upon expiry of that period the Company will seek further consent from you. Where consent is not granted the Company will cease to process your personal data and sensitive personal data.

5. Your rights

Please be aware that you have the following data protection rights:

  • The right to be informed about the personal data the Company processes on you;
  • The right of access to the personal data the Company processes 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; and
  • The right to withdraw consent at any time.
 
All rights are subject to conditions under the applicable data protection law, and not all rights will apply in every circumstance
Where you have consented to the Company processing your personal data and sensitive personal data you have the right to withdraw that consent at any time by contacting info@sosgroup.uk  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 the Company 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 the Company processes is incorrect or incomplete, please contact us using the details above and we will take reasonable steps to check its accuracy and correct it where necessary.

You can also contact us using the above details if you want us to restrict the type or amount of data we process for you, access your personal data or exercise any of the other rights listed above.

6. Log Files

We use IP addresses to analyse trends, administer the site, track users’ movements, and to gather broad demographic information for aggregate use.  IP addresses are not linked to personally identifiable information.

7. Links to external websites

The Company’s website may contains links to other external websites. Please be aware that the Company is not responsible for the privacy practices of such other sites.  When you leave our site we encourage you to read the privacy statements of each and every website that collects personally identifiable information.  This privacy statement applies solely to information collected by the Company’s website. 

8. Sale of business


If the Company’s business is sold or integrated with another business your details may be disclosed to our advisers and any prospective purchasers and their advisers and will be passed on to the new owners of the business.
In this scenario, any data processing will be carried out in line with all application data protections laws and where appropriate we will provide required information on changes to how your personal data is processed.

9. Data Security

The Company takes every precaution to protect our users’ information. We have the following in place:

  • Firewalls
  • Encryption
  • Limited access
  • Use of passwords
  • Multi Factor Authentication
  • Staff training
  • Technical and organisational security procedures including Cyber Essentials certification
Only employees who need the information to perform a specific job (for example, consultants, our accounts clerk or a marketing assistant) are granted access to your information.
 
The Company uses all reasonable efforts to safeguard your personal information. However, you should be aware that the use of email/ the Internet is not entirely secure and for this reason the Company cannot guarantee the security or integrity of any personal information which is transferred from you or to you via email/ 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.

If you have any questions about the security at our website, you can email info@sosgroup.uk

10. Changes to this privacy statement

We will update this privacy statement from time to time.  We will publish the updated version on our website with revision details and effective dates.  If we make any material changes, we will notify where required by data protection law.

11. Complaints or queries

If you have any concerns or wish to complain about this privacy notice or any of the procedures set out in it, please contact the DPO viainfo@sosgroup.uk.
 
We will acknowledge your complaint within 30 days of receipt, carry out a thorough investigation and keep you informed of any progress. A full update and outcome will be communicated with you once the investigation is completed and with undue delay.
 
You also have the right to raise concerns with Information Commissioner’s Office (ICO) on 0303 123 1113 or at https://ico.org.uk/concerns/, or any other relevant supervisory authority should your personal data be processed outside of the UK, if you believe that your data protection rights have not been adhered to.
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