Our commitment to your privacy

Maintaining the privacy and protection of our clients’ and employees’ personal information is a key priority for us. That is why Renaissance Resources Ltd trading as Evocation EFL strives to respect and protect your confidentiality by complying with the General Data Protection Regulation (GDPR) and with recognised best practice in this field. We are also registered as a data controller with the Information Commissioner’s Office (ICO) under the UK’s Data Protection Act 1998.

Renaissance Resources Ltd collects personal information on a voluntary basis only. We ensure that you give consent to our data collection, handling and retention processes. You have the right to withhold consent but in some cases this may mean that we decline to work further with you, which is our right.

We take great care of your data and have set up our systems and processes to ensure it is safeguarded and protected at all times. We make sure that we have your consent to the way we use your data, and that you are informed about how your data is used. This policy explains how we handle your data and how we carefully protect it in line with your stated wishes.

There may be instances where we need to make exceptions to our general policies. We will release any personal information about you in order to comply with any judicial or legal process. In addition, we may also release personal information if we reasonably believe there may be a personal threat to you or to other individuals.

Why we hold your data

Renaissance Resources Ltd trading as Evocation EFL operates under UK law as an employment business which engages teachers and other teaching-related staff for temporary placements and assignments. We also operate as an employment agency which provides candidates for permanent positions. We collect your data in order to carry out these functions efficiently and effectively.

We may collect personal data from you as a person to whom we are providing work-finding services or as a person who has become our legal employee. In either case, your data may be shared with a third party as part of the work-finding process, in response to a legally authorised request or action or in order to carry out a criminal record check.

Our collection of your data

We normally collect and hold the following data items:

  • Your full name (forename, middle names, last name(s))
  • Title
  • Date of birth / age
  • Nationality
  • Gender
  • Identification documents (Passport, birth certificate, photocard ID, driving licence)
  • Bank account details (sort code, account number, bank name and address, account name)
  • National Insurance number or equivalent in other countries
  • Phone number – landline and mobile
  • Home address
  • E-mail address
  • Proofs of address
  • CV
  • Disclosure and Barring Service check or overseas police checks
  • P45 from previous employment
  • Referee details and reference(s)
  • Work history
  • Copy of academic qualifications, eg degree/diploma/certificate
  • Copy of sector-specific qualifications, eg CELTA, Trinity TESOL
  • Our contract with you (where issued) and your formal acceptance via signature or email
  • Mail and e-mail correspondence

We may also hold audio clips, and still and moving images, for instance photos provided within a CV or separately; brief audio which demonstrates quality of spoken English; recorded brief interview video, for instance carried out by Skype, or video clips of work history such as extracts from lessons. Recording of audio and/or video is done only with your explicit consent at the time.

For office employees, we may additionally hold –

  • Usernames
  • Passwords
  • User IDs
  • Cookies
  • Browsing history

All data will be held for a reasonable length of time while it supports the objective(s) for which we have obtained it, ie normally to support the work-finding process or for the purpose of employee administration.

Other data which you provide, for instance because you have included it in your CV, will also be held in our systems but will not be part of any structured and systematic database.

Your CV

This is a key document for us. We will hold a copy which you have sent us directly by email, or which you have forwarded to us directly or indirectly from a recruitment website.

If you work with us, we will periodically request you to send us an updated version of your CV. We retain all versions which you provide unless and until your record is removed from our systems.

General use of personal data

Renaissance Resources Ltd holds data on individuals for purposes such as: staff administration, advertising, marketing, public relations, accounts and records, administration and processing of work-seekers’ personal data for the purposes of work-finding services and payroll.

Renaissance Resources Ltd holds data about potential, current and former candidates; potential, current and former staff and employees, as well as businesses who show interest in our services.

Who sees your data

Only designated employees, consultants or agents who need to carry out legitimate business functions are permitted to view your personal information. Furthermore, all our employees are kept up-to-date on our security and priority practices. All employees of Renaissance who violate this policy are subject to disciplinary action, up to and including termination of employment.

How data is processed

The data controllers of Renaissance Resources Ltd obtain, record, hold and might carry out a set of operations on the data such as organising, amending, adapting the data as well as consultation, retrieval and use of the data, disclosing and erasure or destruction of the data. Some data may be processed in accordance with automatic criteria we have set up before it is seen by us. All data processing is carried out using technical and non-technical means such as computer, smartphone or using paper files and it is:

  1. Fairly and lawfully processed in a transparent manner in relation to the data subject
  2. Processed for specified, explicit, legitimate and limited purposes
  3. Adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed
  4. Accurate and reviewed on a regular basis
  5. Not kept longer than necessary for the purposes for which the personal data are processed
  6. Processed in accordance with the data subject’s rights
  7. Kept securely, protected against unauthorised or unlawful processing and against accidental loss, damage or destruction
  8. Not transferred to countries outside the European Economic Area without adequate protection.

Data is held securely on our systems and on cloud-based applications such as Google Drive. We back up the data locally, as well as to the cloud and to off-site systems, in all cases using reputable suppliers and encrypted processes which minimise the risk of data loss.

Except as required by law, we will not pass on any data or information on the following matters, considered as “sensitive personal data,” to any third party without the express written content of the individual:

  • Any offence committed or alleged to be committed
  • Proceedings in relation to any offence and any sentence passed
  • Physical or mental health or condition
  • Racial, ethnic origins, sex life and sexual orientation
  • Political opinions
  • Religious beliefs or beliefs of a similar nature
  • Whether someone is a member of a trade union

Data which we regularly pass to 3rd parties for work purposes

In order to support applications for longterm or permanent positions, we will pass your CV and other supporting information to potential employers such as language schools.

In order to provide you with temporary work as you have requested, we will inform 3rd parties (such as schools) of the following information:

  • Your name
  • Your phone number
  • Your email address
  • Brief relevant details of your known skills and strengths

Data which we pass to 3rd parties when requested for work purposes

When a 3rd party (such as a school) requests it, we will pass them copies of –

  • Your CV
  • Your academic qualifications
  • Your passport
  • Your DBS
  • Your references

We do not undertake to inform you when such data has been passed to a 3rd party.

Data which we pass to 3rd parties for payroll and official purposes

We pass 3rd parties such as HMRC and DWP, Revenue in Ireland and our payroll processing partners, details of –

  • Your name and address
  • Your national insurance number (or equivalent)
  • Your contact details (phone/email)
  • Time worked
  • Pay rate
  • Calculated gross pay, net pay and deductions
  • Your start date/finish date of employment
  • Your bank account details

Data which we pass outside the UK

We pass CV and other candidate information to schools in EU countries where we work, primarily Ireland and Italy. This may include audio/video data and images.

We pass CV and other candidate information to our counterparties in non-EU countries where we work, primarily Saudi Arabia. This may include audio/video data and images.

Our payroll processers based in Mauritius provide inputs and access outputs relating to our Irish payroll data (and associated personal data) but all processing is done in the EU and they do not access the data itself.

Data passed outside the UK is processed securely and contractually in accordance with the terms of Articles 45 and 46 of the GDPR.

Security precautions

From a security point of view, only Renaissance office staff are permitted to add, amend or delete data from our database. All Renaissance staff are responsible for notifying information which is known to be old, inaccurate or out of date. All staff are made aware of the following rules to ensure that adequate security measures are in place. For example:

  • We ensure that our security software is kept up to date to avoid weak spots for hackers to exploit
  • We carry out vulnerability assessments to review and address any changes or new risks in data protection by considering all aspects, such as data storage and remote access for employees, and ensure that policies and procedures are adequate
  • We train staff to be aware of the importance of data security and how to avoid mistakes that could lead to breaches, as we believe that awareness of sensitive data and security is an important part of the company’s culture
  • Computer screens are not left open by individuals who have access to personal data
  • Passwords are not disclosed
  • Email is used with care
  • Personnel files and other personal data is stored in a place in which any unauthorised attempts to access them will be noticed. They are never removed from their usual place of storage without good reason
  • Personnel files are always locked away when not in use and when in use they are not left unattended
  • Any breaches of security are treated as a disciplinary issue
  • Care is taken when sending personal data in internal or external mail
  • Destroying or disposing of personal data counts as processing. Therefore care is taken in the disposal of any personal data to ensure that it is appropriate. For example, sensitive data will be shredded and disposed of securely

References

  • Any request for access to a reference given by a third party must be referred to Martin Richards and is treated with caution even if the reference was given in relation to the individual making the request. This is because the person writing the reference also has a right to have their personal details handled in accordance with the General Data Protection Regulation, and not disclosed without their consent.
  • Therefore when taking up references, we notify the person writing the reference that we may disclose the reference to a third party and/or the individual who is the subject of the reference if they make a subject access request. If a referee informs us that they do not consent to this, then consideration will be given as to whether the details of the individual giving the reference can be deleted so that they cannot be identified. If so the reference may be disclosed in an anonymised form.

Online privacy

Renaissance Resources Ltd trading as Evocation EFL is committed to providing you the opportunity for a positive experience during your visit to our websites and social media pages, while respecting and striving to protect your online privacy.

Our sites may contain links to other sites. We will make every effort to link only to sites that we believe share our high standards and respect for privacy. However, we are not responsible for the content or privacy practices employed by organisations sponsoring these other sites.

We may monitor and analyse traffic patterns. These studies are not linked to any personal information that can identify any individual person.

All personal information you provide to Renaissance is secured on servers with restricted access provided by reputable service providers. We reserve the right to use agents and consultants to perform storage and processing functions. In such instances, we use all reasonable efforts to have these agents and consultants bound by strict confidentiality guidelines, although we cannot be responsible if these agents or consultants violate these guidelines.

We do not place our own cookies on your computer. Sites which we use (eg Google forms) may place their own cookies.

We may release personal information if we reasonably believe there is an attempted breach of the security of our site or if we believe there may be a personal threat to you or to other individuals.

Your rights

If you do provide us with your personal information, or if you contact us with questions or comments, we reserve the right to use your personal information in order to be able to respond to your questions or comments. We reserve the right to file your comments for future reference.

Data subjects are entitled to obtain access to their data on request and after payment of a fee. All requests to access data by data subjects ie staff, members, customers or clients, suppliers, students etc should be referred to –

Martin Richards (Managing Director)

Write to:

Evocation EFL

Bon Marche Centre

241-251 Ferndale Rd

London

SW9 8BJ

E-mail: martin@evocationefl.net

Telephone: +44 20 7274 8441

If you have any questions concerning our policy, please direct them to us at efl@evocationefl.net

January 2020