PRIVACY POLICY
Precision Global Consulting, Inc. (” We”, “Us”, our “Group”) are committed to protecting and respecting your privacy. This also includes our subsidiaries, our ultimate holding company and its subsidiaries, our associated companies as defined in section 1159 of the UK Companies Act 2006 and under US and Canadian laws. We operate the www.pgcgroup.com website and the Precision platform (hereinafter referred to as the “website”, “Website”, “site”, “Site”, “service” or “Service”)
This notice sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us.
A Note on GDPR
The General Data Protection Regulation (GDPR) (Regulation (EU) 2016/679) is a new regulation which replaces the Data Protection Regulation (Directive 95/46/EC) The Regulation aims to harmonize data protection legislation across EU member states, enhancing privacy rights for individuals and providing a strict framework within which commercial organizations can legally operate.
We welcome GDPR as an opportunity to build a stronger data protection foundation for the benefit of all. Data privacy is an important human right, and in this data-driven world, more than ever, data protection is something that all companies should be paying close attention to.
Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.
For the purposes of data protection legislation in force from time to time the data controller is Precision Global Consulting, Inc. of 98 San Jacinto Blvd, 4th Floor, Austin, TX, 78701.
Our nominated representative is Amy Davies, Managing Director, UK & US. Our Data Protection Officer is Michael Collins, Director.
Who we are and what we do
We are a contingent workforce and human resources management platform. We collect the personal data of the following types of people to allow us to undertake our business:
Prospective and placed candidates for permanent or temporary roles;
Prospective and live client contacts;
Supplier contacts to support our services;
Employees, consultants, temporary workers
Any other contacts necessary to carry out our legitimate business purposes.
We collect information about you to carry out our core business and ancillary activities.
Information you give to us or we collect about you.
This is information about you that you give us by filling in forms on our site or on our software or by corresponding with us by phone, e-mail or otherwise. It includes information you provide when you register to use our site or software, to enter our database, subscribe to our services, attend our events, participate in discussion boards or other social media functions on our site, enter a competition, promotion or survey, and when you report a problem with our site.
The information you give us, or we collect about you may include your name, address, private and corporate e-mail address and phone number, financial information, compliance documentation and references verifying your qualifications and experience and your right to work in the United Kingdom, United States, Canada, or otherwise elsewhere in the world, curriculum vitae and photograph, links to your professional profiles available in the public domain e.g. LinkedIn, Twitter, business Facebook or corporate website, and any other information necessary and essential to our business interests.
Information we collect about you when you visit our website or use our software.
With regard to each of your visits to our site we will automatically collect the following information:
Technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information if applicable, browser type and version, browser plug-in types and versions, operating system and platform;
Information about your visit to through and from out site (including date and time), products you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, and any phone number used to call our customer service number.
Information we obtain from other sources.
This is information we obtain about you from other sources such as LinkedIn, corporate websites, job board websites, online CV libraries, your business card, personal recommendations, and others. In this case we will inform you, by providing you with a link to this privacy notice sending you this privacy notice upon our initial contact with you, the source the personal data originates from and whether it came from publicly accessible sources, and for what purpose we intend to retain and process your personal data.
We are working closely with third parties including companies within our Group, business partners, sub-contractors in technical, professional, payment and other services, advertising networks, analytics providers, search information providers, credit reference agencies, professional advisors and others. We may receive information about you from them for the purposes of our employer of record services and ancillary support services.
We use information held about you in the following ways:
To carry out our obligations arising from any contracts we intend to enter into or have entered into between you and us and to provide you with the information, products and services that you request from us or we think will be of interest to you because it is relevant to your career or to your organization.
To provide you with information about other goods and services we offer that are similar to those that you have already purchased, been provided with or enquired about.
The core service we offer to our candidates and clients is the employment of candidates for the purpose of temporary or permanent engagement. However, our service expands to human resources software licensing, supporting individuals throughout their career, and to supporting businesses’ resourcing needs and strategies. Our legal basis for the processing of personal data is our legitimate business interests, described in more detail below, although we may also rely on contract, legal obligation and consent for specific uses of data. We may rely on contract if we are negotiating or have entered into a placement agreement with you or your organization or any other contract to provide services to you or receive services from you or your organization. We will rely on legal obligation if we are legally required to hold information on you to fulfil our legal obligations. We may in some circumstances rely on consent for particular uses of your data and you will be asked for your express consent, if legally required.
Our Legitimate Business Interests
Our legitimate interests in collecting and retaining your personal data is described below:
As contingent workforce management platform, workers are onboarded to our platform by our clients for permanent employment, temporary worker placements, or independent professional contracts. The exchange of personal data of our candidates and our client contacts is a fundamental, essential part of this process. This includes verification of work authorization, banking details, time worked, and any other data required by federal and state regulations to be collected, verified, and stored by any employer.
In order to support our candidates’ career aspirations and our clients’ resourcing needs we require a database of candidate and client personal data containing historical information as well as current resourcing requirements. To maintain, expand and develop our business we need to record the personal data of prospective candidates and client contacts. To deliver our ancillary services we need to carry out our employer of record services.
Consent
Should we want or need to rely on consent to lawfully process your data we will request your consent orally, by email or by an online process for the specific activity we require consent for and record your response on our system. Where consent is the lawful basis for our processing you have the right to withdraw your consent to this processing at any time.
Other uses we will make of your data:
Use of our website;
to notify you about changes to our service;
to ensure that content from our site is presented in the most effective manner for you and for your computer.
We will use this information:
to administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
to improve our site to ensure that content is presented in the most effective manner for you and for your computer;
to allow you to participate in interactive features of our service, when you choose to do so;
as part of our efforts to keep our site safe and secure;
to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you;
to make suggestions and recommendations to you and other users of our site about goods or services that may interest you or them.
We do not undertake automated decision making or profiling. We do use our computer systems to search and identify personal data in accordance with parameters set by a person. A person will always be involved in the decision-making process.
Cookies
We use cookies and similar tracking technologies to track the activity on our Service and hold certain information. Cookies are files with small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Tracking technologies also used are beacons, tags, and scripts to collect and track information and to improve and analyze our service. You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our service.
Disclosure of your information inside and outside of the EEA
We will share your personal information with:
Any member of our group both in the EEA and outside of the EEA.
clients for the purpose of carrying out our business with them;
candidates for the purpose of arranging interviews and engagements;
clients, business partners, suppliers and sub-contractors for the performance and compliance obligations of any contract we enter with them or you;
subcontractors including email marketing specialists, event organizers, payment and other financial service providers
analytics and search engine providers that assist us in the improvement and optimization of our site;
credit reference agencies, our insurance broker, compliance partners and other sub-contractors for the purpose of assessing your suitability for a role where this is a condition of us entering into a contract with you.
We will disclose your personal information to third parties:
In the event that we sell or buy any business or assets, in which case we will disclose your personal data to the prospective seller or buyer of such business or assets.
If we or substantially all our assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
If we are under a duty to disclose or share your personal data to comply with any legal obligation, or in order to enforce or apply our terms of use or terms and conditions of supply of services and other agreements; or to protect the rights, property, or safety of our company., our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.
The lawful basis for the third-party processing will include:
Their own legitimate business interests in processing your personal data, in most cases to fulfil their internal resourcing needs;
satisfaction of their contractual obligations to us as our data processor;
for the purpose of a contract in place or in contemplation;
to fulfil their legal obligations.
Where we store and process your personal data
The data that we collect from you may/will be transferred to, and stored at, a destination outside the European Economic Area (”EEA”). It may be transferred to third parties outside of the EEA for the purpose of our employer of record services. It may/will also be processed by staff operating outside the EEA who work for us or for one of our suppliers. This includes staff engaged in, among other things, our employer of record services and the provision of support services. By submitting your personal data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy notice.
All information you provide to us is stored on our secure servers. Any payment transactions will be encrypted using SSL technology. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorized access.
Your information, including Personal Data, may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction. If you are located outside United States and choose to provide information to us, please note that we transfer the data, including Personal Data, to United States and process it there. Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of your data and other personal information.
Retention of your data
We understand our legal duty to retain accurate data and only retain personal data for as long as we need it for our legitimate business interests and that you are happy for us to do so.
We do the following to try to ensure our data is accurate:
our software enables you to manage your data and to review whether the details we hold about you are accurate;
prior to making an introduction we check that we have accurate information about you; and
we keep in touch with you so you can let us know of changes to your personal data
We segregate our data so that we keep different types of data for different time periods. The criteria we use to determine whether we should retain your personal data includes:
the nature of the personal data;
its perceived accuracy;
our legal obligations;
whether an interview or placement has been arranged; and
our employer of record expertise and knowledge of the industry by country, sector and job role.
We may archive part or all of your personal data or retain it on our financial systems only, deleting all or part of it from our main Customer Relationship Manager (CRM) system. We may pseudonymize parts of your data, particularly following a request for suppression or deletion of your data, to ensure that we do not re-enter your personal data on to our database, unless requested to do so.
For your information, Pseudonymized Data is created by taking identifying fields within a database and replacing them with artificial identifiers, or pseudonyms.
Our current retention notice is available upon request.
Your rights
You have the right to ask us not to process your personal data for marketing purposes. We will usually inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes and we will collect express consent from you if legally required prior to using your personal data for marketing purposes.
You can exercise your right to accept or prevent such processing any time by contacting us at legal@pgcgroup.com.
Our site may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
The GDPR provides you with the following rights to:
Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
Request erasure of your personal information. This enables you to ask us to delete or remove personal information 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 information where you have exercised your right to object to processing (see below).
Object to processing of your personal information 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. You also have the right to object where we are processing your personal information for direct marketing purposes.
Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
Request the transfer of your personal information to another party in certain formats, if practicable.
Make a complaint to a to a supervisory body which in the United Kingdom is the Information Commissioner’s Office. The ICO can be contacted through this link: https://ico.org.uk/concerns/
Privacy Notice for California Residents
This Privacy Notice for California Residents supplements the information contained in Precision Global Consulting, Inc.’s (PGC) Privacy Policy and applies solely to all employees, contractors, visitors, users, and or similar individuals who reside in the State of California (”consumers” or “you”). PGC adopts this notice to comply with the California Consumer Privacy Act of 2018 (CCPA) and any terms defined in the CCPA have the same meaning when used in this Notice.
Information We Collect: PGC collects information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device (”personal information”). Personal information does not include:Information We Collect: PGC collects information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device (”personal information”). Personal information does not include:
Publicly available information from government records.
Deidentified or aggregated consumer information.
Information excluded from the CCPA’s scope, like:
health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data; personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.
In particular, PGC has collected the following categories of personal information from its consumers within the last twelve (12) months:
A. Identifiers: A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers.
A. Identifiers: A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers.
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).: A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.
C. Protected classification characteristics under California or federal law: Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).
D. Commercial information: Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
E. Internet or other similar network activity: Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.
F. Professional or employment-related information: Current or past job history or performance evaluations.
PGC has NOT collected the following categories of personal information from its consumers within the last twelve (12) months:
A. Geolocation data: Physical location or movements.B. Sensory data: Audio, electronic, visual, thermal, olfactory, or similar information.
C. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)): Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.
D. Inferences drawn from other personal information: Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
PGC obtains the categories of personal information listed above from the following categories of sources:PGC obtains the categories of personal information listed above from the following categories of sources:
Directly from you. For example, from forms you complete on our site or on our software or by corresponding with us by phone, e-mail or otherwise. It includes information you provide when you register to use our site or software, to enter our database, subscribe to our services, attend our events, participate in discussion boards or other social media functions on our site, enter a competition, promotion or survey, and when you report a problem with our site.
Indirectly from you. For example, from observing your actions on our Website during each of your visits through and from out site (including date and time), products you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, and any phone number used to call our customer service number.
From online sources. For example, from other sources such as LinkedIn, corporate websites, job board websites, online CV libraries, your business card, personal recommendations, and others. In this case we will inform you, by providing you with a link to this privacy notice sending you this privacy notice upon our initial contact with you, the source the personal data originates from and whether it came from publicly accessible sources, and for what purpose we intend to retain and process your personal data.
From third parties. For example, companies within our Group, business partners, sub-contractors in technical, professional, payment and other services, advertising networks, analytics providers, search information providers, credit reference agencies, professional advisors and others.
PGC may use or disclose the personal information we collect for one or more of the following purposes:PGC may use or disclose the personal information we collect for one or more of the following purposes:
To fulfill or meet the reason you provided the information such as the verification of work authorization, banking details, time worked, and any other data required by federal and state regulations to be collected, verified, and stored by any employer.
For the purposes of our employer of record services and ancillary support services we need to carry out our employer of record services.
To provide, support, personalize, and develop our Website and services.
To create, maintain, customize, and secure your account with us.
To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
To help maintain the safety, security, and integrity of our Website and services, databases and other technology assets, and business.
For testing, research, analysis, and platform development, including to develop and improve our Website and services.
To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
As described to you when collecting your personal information or as otherwise set forth in the CCPA.
PGC will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.
PGC will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.
Sharing Personal Information.
PGC may disclose your personal information to a third party for the purposes of our employer of record services and ancillary support services. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract. PGC shares your personal information with the following categories of third parties:
Payroll providers.
Employee benefits providers.
Ancillary services providers.
Disclosures of Personal Information for a Business PurposeDisclosures of Personal Information for a Business PurposeIn the preceding twelve (12) months, PGC has disclosed the following categories of personal information for a business purpose:
Category 1: Identifiers.
Category 2: California Customer Records personal information categories.
Category 3: Protected classification characteristics under California or federal law.
Category 9: Professional or employment-related information.PGC discloses your personal information for the purposes of our employer of record services and ancillary support services to the following categories of third parties:
Payroll providers.
Employee benefits providers.
Ancillary services providers.
Children’s Privacy
Our Service does not address anyone under the age of 18 (“Children”). We do not knowingly collect personally identifiable information from anyone under the age of 18. If you are a parent or guardian and you are aware that your Children has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from children without verification of parental consent, we take steps to remove that information from our servers.
Access to information
The Data Protection Act 1998 and the GDPR give you the right to access information held about you. We also encourage you to contact us to ensure your data is accurate and complete.
Your right of access can be exercised in accordance with the Act (and the GDPR once it is in force).
A subject access request should be submitted to legal@pgcgroup.com. No fee will apply once the GDPR comes into force.
Links To Other Sites
Our Service may contain links to other sites that are not operated by us. If you click on a third-party link, you will be directed to that third party’s site. We strongly advise you to review the Privacy Policy of every site you visit. We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.
Legal Requirements
We may disclose your personal data in the good faith belief that such action is necessary to:
To comply with a legal obligation
To protect and defend our rights or property.
To prevent or investigate possible wrongdoing in connection with the service
To protect the personal safety of users of the service or the public
To protect against legal liability
Online Tracking
Please note that our service and website does not support “Do Not Track” browser settings and do not currently participate in any “Do Not Track” frameworks that would allow us to respond to signals or other mechanisms from you regarding the collection of your personal or non-personally identifiable information.
Changes to our privacy notice
Any changes we make to our privacy notice in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our privacy notice.
Contact
Questions, comments and requests regarding this privacy notice are welcomed and should be addressed to legal@pgcgroup.com.