Ashley Hargreeves runs a variety of websites. There's a full list near
the end of this notice (Schedule 1). Where the notice refers
to "Ashley Hargreeves" and "we", it's referring to the particular company that is processing your personal information. This may be as a controller in its own right or as a processor on behalf of one of its clients.
This is our Privacy Notice for all our services. It tells you how we will use and protect any
information we collect in line with the General Data Protection Regulation
(GDPR).
When we process personal data on our clients' behalf, we are acting as a processor.
We collect personal information that our clients instruct us to collect. For more about the type of information we collect and why, scroll down to section 4, "What types of personal information do we collect?". For more specific details about the information we'll
collect about you, please speak with the organisation that requested the services.
The most common use of our services by organisations is recruitment and
employment. Therefore, for convenience, where this notice refers to "our client" or "your
potential employer", it's referring to that kind of organisation.
Who we share your personal information with and why
We share your personal information with:
For more about who we share your information with, please refer to sections 4 and 6.
We don't sell or disclose your personal information to governments, marketing or advertising services, other clients, or anyone else except as outlined in this statement or required by law.
Ashley Hargreeves is committed to protecting individual privacy rights. We hold ourselves to the highest legal and ethical standard for compliance. We strive to be a privacy champion in the human resources technology industry. We value the trust our clients, colleagues, and suppliers place in us, and we work to maintain that trust by building privacy protection into everything we do. We are committed to implementing the six data protection principles that set out our responsibilities as required by Article 5 of the GDPR.
We process personal information in the United Kingdom that we have collected from people around the world, so we may transfer it outside the United Kingdom as follows:
For more about cross-border transfers of personal information, scroll down to section 7, "Do we transfer personal information between countries?".
This statement applies to the collection and processing of personal information, which means information about an identifiable individual (you) that Ashley Hargreeves collects when providing services to our clients.
When we carry out background screening on a client’s behalf, we are acting as a processor under our client’s instructions. Our client, who is acting as a controller, is responsible for deciding the legal basis for your screening. We rely on the client’s legal basis to collect and process your information. We only collect and process your personal data in line with their instructions.
To find out the legal basis our client is relying on for your screening, please refer to their privacy notice.
If necessary, we or our client may ask you for a signed authorisation. We need this because we will be asking third parties (for example, organisations and referees) to share information about you with us. Normally, before third parties will agree to do so, they will require us to prove that our request (on our client's behalf) is made with your knowledge and agreement.
Your authorisation does not alter the legal basis for processing set by our client. Furthermore, if you withdraw or withhold your authorisation, this will not affect our client’s legal basis for screening. However, when our services are used for recruitment and employment purposes, any offer of a role may depend on you successfully undergoing screening. (Screening may also be required under your existing employment contract.) If you do not give your authorisation to screening, this may affect your employment with our client. We are not involved in any decisions about your employment. We take no responsibility for any of our client’s actions regarding the screening process and its outcome.
You may have questions about the consequences of withholding your personal data or withholding or withdrawing your authorisation to screening, or you may wish to know the legal basis our client is relying on. If so, you should contact our client who requested the screening.
When we provide services, our client is generally responsible for the following aspects of collecting and processing personal information:
We are generally responsible for the following aspects of collecting and processing personal information:
When we provide services to a client, we collect your personal information in line with our client's instructions. For more about this, please contact your potential employer.
We collect your personal information through the use of cookies on our secure platforms. For more about cookies, please see section 5, "How do we use cookies?"
We collect information about your activity on our secure platforms to ensure the integrity and security of our systems and the data in our custody. We use it to audit system access and investigate suspicious activity.
Our collection of personal information for security purposes is based on our legitimate interest and legal obligation to ensure we protect personal information in our custody.
Review the list below to see the types of personal information we collect from or on behalf of our clients, along with an explanation of why we collect it and where we collect it from.
Not all background checks require the same level of detail and verification. If you wish to know more about what is required regarding your own background check, we recommend you ask your potential employer.
Type of information |
Reason for collection |
Sources |
Names - current and former | This is how we identify you. If we do not know who you are, we cannot provide services. We may need former names to conduct a full background check, as old records may be held under a former name. |
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Names of your parents - current and former | Some services, especially criminal record checks, require the name of your parents to identify you. |
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Date of birth | Along with your name, this serves to identify you as a unique individual, and is often required for us to perform services. |
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Place of birth | Some services require a place of birth. |
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Sex or gender | Some services require a sex or gender. |
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Address history | Some services, especially criminal record and credit checks, require several years of address history to complete. |
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Contact information | In most cases, we need to know how to get in touch with you. This may include your mailing address, email address and telephone number. If we collect these while providing services for a client, we'll use them only to provide those services and comply with our client's instructions and our legal obligations. We will not contact you for any other reason. |
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Nationality | Some services require your nationality to complete. |
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Fingerprints* | Some services such as criminal records in certain jurisdictions require fingerprints to identify and locate any relevant records. |
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Photograph | Some services require us to collect a photo ID |
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Documents to prove identity or address | We may be asked by our client to verify your identity, or we may be required to do so to complete services. If so, we may collect ID cards or other documents you provide. |
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Government-issued identity numbers (e.g. identity number, social security number, social insurance number, national insurance number, driving licence number, passport number)* | Some services require this information, as records we need to retrieve from third parties are often associated with a government identity number. This may include criminal records, credit files, employment history or driving records. |
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Immigration status (eligibility to work) | Some clients wish to verify potential employees' immigration status in the jurisdiction where they operate. |
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Criminal records and police records* | Some clients wish to review criminal records as part of their screening programme. This may also cover any barred lists, if applicable. |
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Credit or bankruptcy history* | Some clients wish to obtain financial or identity information found in a credit file with a credit reference agency or in public record information. |
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Civil court records | Some clients wish to review litigation history in the civil courts. |
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Tax information* | Some clients wish to use our services to collect tax documents from their employees. |
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Salary/income | Some services may disclose this information to us, and some clients may wish us to verify this information. |
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Property/real-estate information | Some clients wish to use our services to verify the ownership of the house(s) you live in and own as well as details of any current mortgages on it. |
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Appearance on government watch or sanctions lists* | Some clients wish to check for your presence on government watch list or sanctions list. |
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Directorship, shareholding and corporate governance history | Some clients wish to verify current or past involvement with corporations and charities as a director, officer, trustee or shareholder. Some clients also wish to check you are not barred from holding such positions in the future. |
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Employment history | Some clients wish to verify employment or activity history over a period of time. |
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Volunteering history* | Some clients wish to verify volunteering or activity history over a period of time. |
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Education history | Some clients wish to verify education or activity history over a period of time. |
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Gap history | Some clients wish to verify activity history over a period of time. |
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Professional credentials, designations, licences, memberships (this may also include trade union membership*), associations, awards, sanctions or reprimands | Some clients wish to verify your standing as a certain type of professional; participation or completion of professional development courses; or the existence of professional sanctions or reprimands. |
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Opinions about you | Some clients wish to obtain character references about you. Additionally, opinions may be provided during verifications of employment or volunteering. |
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Health information, including results from occupational health assessment, drug test and GP letter* | Some clients wish to test for drug use or health conditions. |
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Driving licence, and driving records | Some clients wish to check your driving licence validity and driving history. |
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Media | Some clients wish us to locate media articles about you, assess your social media activity, or locate any other mentions of you on various web sites such as blogs, forums and more. |
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Other public record information | Some clients wish us to search other public record sources for information. |
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Call recordings | We monitor some phone calls for quality-assurance and training purposes. |
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Your opinions about your experience with Ashley Hargreeves | We may occasionally seek your feedback about your interactions with us to improve the quality of our service. |
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*Items marked with an asterisk may be considered sensitive or may be subject to special protections in some places. We will not collect them in every case. We will not collect them if it is illegal. Where permitted, we will only collect and use them in line with the law. Please scroll down to section 12 to learn more about some of the measures we take to protect personal information.
Types of information, some of which may be personal information, that are logged when you access our secure platforms:We will only use your personal data for the purposes for which we collected it (eg., screening purposes as instructed by our client). Please note we may process your personal data without your knowledge or consent if the law requires it.
If we collect personal information about you for which we act as a controller or a processor, we won’t reuse it for any new purpose that is different from the original purposes for which we collected it, unless one or more of the following is true:
You should contact your potential employer for details of any reuse of your personal information because it relates to personal information where they act as a controller.
Cookies are pieces of information shared between your web browser and a web site. Cookies enable the web site to collect information about your activities and give you a faster and easier experience.
These are the cookies we use:
Name of the cookie |
Purpose of the cookie |
.AshleyHargreevesPortalSecurityBackend | This is used to manage user authentication to our web site. |
PHPMVC_SessionId | This contains a temporary unique identifier for a user's session. It's used to enable the management of session state for each user. |
__AntiXsrfToken | This contains a security token used to prevent cross-site request forgery (XSRF) attacks. |
Portal.Framework.PreferableCultureName | This contains a user's language preference. |
Different cookies have different functions:
Our service platforms, which we use to collect information from you and our clients, do not use third-party cookies. They may use first-party session cookies to track your use of the sites and first-party persistent cookies to remember any preferences you select, such as your location.The major browsers have tried to implement the draft "Do Not Track" (DNT) standard of the World Wide Web Consortium (W3C) in their latest releases. As this standard has not been finalised, our sites are not compatible with DNT and so do not recognise DNT settings.
We use cookies for the following purposes:
Where strictly necessaryCookies are essential to enable you to move around the web site and use its features, such as accessing secure areas of the site. Without them, we could not provide services such as viewing certain areas of the site or using web forms. Cookies do not gather information about you that could be used for marketing or remembering where you have been on the internet.
PerformanceCookies collect information about how visitors use a site, for instance which pages they go to and if they get error messages from web pages. Cookies do not collect information that identifies a person, as all the information they collect is anonymous. We use them to improve how our site works.
FunctionalityCookies allow our site to remember choices you make (such as your language or the region you are in) and provide enhanced features. They can also be used to remember changes you have made to text size, font and other parts of web pages you can customise. They may be used to provide services you have requested such as viewing or commenting on content on the site. The information these cookies collect is usually anonymised.
Please consult your web browser's 'Help' documents for more information about how to turn cookies on and off.
Often, the services we provide require us to find or validate personal information with third-party sources when requested by our client. To do so, we need to provide your personal information to allow the third party to find records about you. We generally provide the information that is required by the third party in the format and through the transmission method of the third party's choosing. This may involve transmitting information through a web site (including API), phone call, email, fax, letter or in person.
When we provide services to a client, communication of your personal information occurs in line with our client's instructions. For more about this, please contact your potential employer.
To provide results to our clientWhen we provide services to a client, we transmit personal information to it, in line with its instructions. Typically, we transmit using our secure web platforms and occasionally by phone, email, fax or mail.
To engage service providers and sourcesMost of our work is done by our employees or authorised personnel who access personal information directly from our systems and whose activities are under our direct control. But we use third-party service providers for certain specialised tasks. These tasks include storage of data, information technology support, and some services we perform for our clients.
All our work relies on collecting data about you from sources described in section 4. It would be impractical to list all service providers and sources here, so instead we have listed types of service provider and sources.
When we provide services to a client, we use service providers in line with our client's instructions. For more about this, please contact your potential employer.
Third-party service providers and sourcesThird party |
Types of information |
Purposes for transfer |
Data storage and delivery providers | All personal information in our custody | Secure data storage and delivery |
IT support services | Personal information in our custody with which we require technical support | Technical support |
Other companies that provide services similar to ours | Personal information required to fulfil services | Provision of services in locations where we do not operate - only used when necessary |
Data aggregators | Personal information required to fulfil services | Provision of services where data is accessible through an intermediate organisation |
Drug-testing labs, General Practitioners (GPs), and occupational health companies | Personal information required to set up and carry out drug screening, occupational health screening or get information from your GP | Provision of drug screening, occupational health screening services, or get information from your GP |
Police, embassies, government departments, courts, and agencies | Personal information required to conduct criminal record searches, verify identity, and identification documents, search court records, get driving, corporate and other public records | Provision of criminal record services, civil court searches, driving, corporate and other public records, and verification of identity |
Credit reference agencies | Personal information required to conduct credit, bankruptcy, court, identity and similar searches | Provision of credit, bankruptcy, court and identity searches and similar services |
Employers, employment agencies, referees, educational institutions, education authorities, professional institutions, licensing authorities, and their recordkeeping service providers | Personal information required to verify employment (including volunteering), qualifications and licences, and to get references | Verification of employment, qualifications and licences, and collecting references |
Your clients, accountant, lawyer, management company or agencies you registered with | Personal information required to verify self-employment, and to get references | Verification of self-employment, and collecting references |
Translation services | Personal information we have received in a language other than what is used to provide the services for which it was collected | Provision of services in the language required by our client |
Postal and courier services | Personal information required to fulfil services | Provision of services where the source of information requires a postal application |
Survey services | Your opinions about our services | Conducting surveys |
Auditors | Personal information in our custody | Audit services of our technology platform, financial records and quality of our services |
We may be asked to communicate personal information to law enforcement agencies, national security agencies, courts or other public bodies in any jurisdiction where we are subject to the law, regardless of where personal information is stored. If we receive a production order, warrant, subpoena or other enforceable demand, we will comply as required by law. If we receive a request to provide information voluntarily, we will consider your interests, our business interests, the interests of our clients, public safety implications and our legal obligations before deciding whether to communicate personal information. In any case if the information in question was collected from or on behalf of a client, we will consult the client before proceeding unless prohibited by law.
We may proactively communicate personal information to law enforcement or other third parties if necessary to investigate or report a violation of the law or a contract, or if otherwise appropriate and permitted by law.
Yes. We store personal information in the United Kingdom. We also use service providers in various other countries, usually to collect or translate information from that service provider's country or region where we need to provide services.
Based on where you have lived, worked and studied, we may need to transfer parts of your personal information to countries that do not have data protection laws equivalent to those of the European Economic Area (for example, Australia, United States, China).
If your personal information is subject to European Union (EU) or Swiss law, we may transfer it outside the EU or Switzerland, relying on one or more of the following legal bases:
In all cases, we will ensure that appropriate safeguards are in place to ensure the protection of your personal information.
Much of the personal information we collect comes directly from you or our client. If you have any concerns about the accuracy of the data processed about you, you should contact your potential employer in the first instance. Our processes for collecting and transcribing personal information are automated as far as possible and subject to rigorous quality controls. Information is updated if it is found to be inaccurate, either through our own audits or after a request for correction received from our clients
We do not make decisions about you, automated or otherwise, and do not try to analyse or predict your behaviour, preferences, interests, health or other personal characteristics. However, we may carry out automated processing on our client's instructions. For more about automated processing of personal information on a client's behalf, please contact your potential employer.
No. We maintain historical statistical data in anonymised, aggregate form for research and analysis. In this form, it is no longer regarded as personal information since it cannot identify you.
We keep personal information that was collected from or on behalf of a client for as long as the client asks us to keep it, or as long as we need to keep it to comply with our legal obligations. To understand how long we will store your personal information, please contact your potential employer.
Ashley Hargreeves takes information security very seriously. As a result, we hold multiple certifications and accreditations following international and British standards.
We have advanced security measures to secure and protect your personal information, such as internal and external firewalls, monitoring and alert systems to prevent and detect intrusion attempts, and 128-bit encryption of data in transit and at rest. Our servers are located in securely managed buildings and networks, and undergo multiple reviews by independent auditors. Our employees access data through secure virtual desktop interfaces. Our online interfaces are encrypted, password-protected and monitored.
We employ equally rigorous physical security policies to prevent physical access to our premises. Our servers and offices, including personal information in hard copy, are kept in access-controlled and monitored environments.
All our employees have been carefully screened to exceed the requirements under British Standard 7858 and have undergone thorough security and privacy training. We restrict access to your personal information to individuals who need it to do their work. Our operations, customer service, account management, finance, quality, vendor management and compliance teams may have regular access to your information. Employees in other departments may access it occasionally as required to provide services, communicate with you and fulfil our legal obligations.
We also enter into contracts with service providers with which we may need to share your personal information. These contracts require service providers to protect your personal information to the same level we do. They also allow us to audit the service providers' compliance with that obligation.
At any time, you can request access to any personal information we collect from you if we are acting as a controller, e.g. if we process your personal information when you access our website. You can ask us to correct any inaccuracies and add comments or explanations to our records about you.
You can also ask about:
Finally, you can ask us not to collect or use your personal information for certain purposes, you can ask us to delete your personal information, or you can ask us to provide your personal information to a third party.
If we act as a processor on behalf of one of our clients, you will need to make any requests for the above directly to your potential employer. Any requests we receive from you that relate to such personal information will be referred to your potential employer.
Depending on which laws apply to your personal information, we or your potential employer may only be able to do some of these things for you. If we are unable to do what you want, we will explain to you your legal rights, the reason for our refusal and any further steps you may take.
We are committed to investigating and resolving complaints about our collection or use of your personal information. To make a complaint - regardless of your location, residency or citizenship - contact us or your potential employer. If you are not satisfied with our resolution of your complaint, you may complain to the Information Commissioner's Office. We are committed to:
Ashley Hargreeves Limited:
For any questions on this notice please contact us at privacy@Ashleyhargreeves.co.uk. For all other queries please use our contact us form.
Our Information Commissioner's Office Registration Number: In Consideration
SCHEDULE 1
WEBSITES
WEBSITE ADDRESS |
SERVICE LOCATION |
STATUS |
ASHLEYHARGREEVES.CO.UK | UK | ACTIVE |