Gibbs Hybrid Programme Solutions Consultancy Limited (“Gibbs Consulting”) is committed to protecting the privacy of our consultants and third parties and strives to provide a safe user experience. This Fair Processing Notice describes how we collect and use online data in accordance with the UK GDPR.
By working with Gibbs Consulting, you agree to the collection, use and transfer of your personal data as described in this Fair Processing Notice.
If you do not want your information to be collected, used, and transferred as described by this notice, you may revoke your consent to our Fair Processing Notice. To revoke your consent, please contact us at dataprotection@gibbshybrid.com. If you revoke your consent, we will be required to terminate our contract with you.
Information collected on our sites and applications is stored in the United Kingdom; therefore, your information is subject to UK law only.
This notice applies to information we collect.
We collect information about you when you comply with our onboarding processes and when we are putting you forward to any of our clients. We register you on applicable onboarding platforms, during the initial phase of our relationship with you such as but not limited to Bullhorn, Catalyst, Client Portals and NowWeComply. We collect information directly from you throughout the onboarding process, such as but not limited to contact information, CV and personal information. We may conduct background verification checks along with a criminal background check (subject to applicable law), financial probity check and any other checks as requested by the client. With regards to your sensitive personal information, we will only collect this provided that we have your explicit consent.
We collect information about you using our online portal NowWeComply or Catalyst. This is an interactive portal which allows you to upload information yourself. Our third-party vendor, Autologyx, is responsible for managing the NowWeComply and Catalyst portals and acts as the data processor in this regard.
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with our services). In this case, we may have to cancel the service that you have with us, but we will notify you if this is the case at the time.
We use the information we collect to provide our services, respond to you, and foster a positive user experience.
By contracting with Gibbs Consulting, you have consented for us to use your information in the following way:
• to create a profile for you based on information that you have provided to us, information collected or imported from other sites or applications, or information provided to us by third parties such as your contacts or referees and then we share that profile with third party clients who may be interested in the services that you could provide to them.
You may opt in for us to provide you with the following:
• provision of additional communications, information, newsletters and further job opportunities;
• information on products or services available from Gibbs Consulting;
• disclosure of information to third parties to receive information about opportunities with other clients.
It would be within our legitimate interests to use your profile to share it with our clients.
We may disclose personal data collected pursuant to any assignment of your services, to the client with whom you are placed where we have a legitimate business interest in sharing this information.
We may disclose information if legally required to do so, or at our discretion pursuant to a request from a governmental entity or if we believe, in good faith, after considering your privacy interests and other factors, that such action is necessary to: (a) meet legal requirements or comply with legal process; (b) protect our rights or property; (c) prevent a crime or protect national security; or (d) protect the personal safety of users or the public.
You are responsible for keeping your username and password secret for any online database that we use with you, for example NowWeComply, Catalyst, Bullhorn and ETZ (if applicable).
Gibbs Consulting takes appropriate measures to secure your personal information from accidental loss and unauthorised access, use, alteration or disclosure.
If we decide to materially change the substance of this Fair Processing Notice, we will, where required, contact you via the email address that you maintain in your profile. We will also post those changes through a prominent notice on the site.
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing). You will receive marketing communications from us if you have requested information from us or services from us and you have not opted out of receiving that marketing.
We will get your express opt-in consent before we share your personal data with any company outside the Gibbs Consulting group of companies for marketing purposes.
Opting You can ask us or third parties to stop sending you marketing messages at any time by contacting us at any time.
Change of Purpose We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
You have the right to:
1. Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
2. Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
3. Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing, where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
4. Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party), and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
5. Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
6. Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
7. Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
Your data is submitted to Gibbs Hybrid Programme Solutions Consultancy Limited (“Gibbs Consulting”) and is stored on our systems situated in the United Kingdom with our principal place of business at Cantium House, Railway Approach, Surrey, SM6 0DZ. This is the legal entity that determines the purpose and manner of processing the information gathered by Gibbs Consulting is the data controller of your personal data.
If, at any time, you have questions or concerns about this Fair Processing Notice, please contact us using our Gibbs Consulting website or in writing at our principal place of business, addressing your letter to our Legal Team.
We will use reasonable efforts to promptly answer your question or resolve your problem.
Our contact details are dataprotection@gibbsconsulting.com.
