Privacy Notice
Lucid Support Services Ltd (Reg No 04419473)
This Privacy Notice sets out the basis on which Lucid Support Services Limited will process personal information
provided to us, this information is also referred to as ‘personal data’.
We take our obligations in respect of the privacy of personal data very seriously and we will only process personal
information as detailed in this notice, unless we inform you otherwise. In order to ensure that the personal data
we hold is accurate and up to date, we request that you inform us of any relevant changes to the personal
information we hold about you.
We help individuals to find project-based work and we are also an employer. Our core business activity is
employment services, we assist individuals in finding project-based work with our hirer clients, whether this is
directly or through supply by us, and we assist hirers in introducing or supplying the staff or contractors that they
require. We also recruit staff to work for us to provide our employment services. For the purposes of this Privacy
Notice, our commercial activities and services for individuals and businesses are referred to as ‘Employment
Services’, and our actual or potential hiring customers are referred to as ‘Clients’.
Our Data Protection Officer can be contacted on dpo@lucid-support.com
If you do not wish us to process personal data in accordance with this policy, then please do not provide it to us,
please refer to Section 4 ’Your rights ‘, in respect of data that we already hold, or which we receive from third
parties.
Section 1: This section applies to individuals wishing to use or using our Employment Services or
looking for a role to work with us (‘a Candidate’):
The personal data we collect or receive includes the following as applicable:
• Name
• Address
• Email and other contact details
• Date of birth
• Job history (including information relating to placements through us)
• Educational history, qualifications & skills
• Visa and other right to work or identity information
• Passport
• Limited Company details (including certificates, banking, insurances etc.)
• Bank details
• National insurance and tax (payroll) information
• Next of kin and family details
• Contact details of referees
• Personal information relating to hobbies, interests and pastimes
• Information contained in references and pre-employment checks from third parties
• Other sensitive personal information such as health records (see ‘Sensitive Personal Data’ section below)
• Your marketing preferences
We may obtain your personal data from the following sources (please note that this list is not exhaustive):
• You (e.g. a Curriculum Vitae, application or registration form)
• A client
• Other candidates
• Online jobsites
• Marketing databases
• The public domain
• Social Media
• At interview
• Conversations on the telephone or video conferencing (which may be recorded)
• Notes following a conversation or meeting
• Our websites and software applications
Where you are a Candidate and we have obtained your personal data from a third party such as an online job board,
it is our policy to advise you of the source when we first communicate with you.
How we will use your personal data:
The processing of your personal information may include:
• Collecting and storing your personal data, whether in manual or electronic files
• Notifying you of potential roles or opportunities
• Assessing and reviewing your suitability for job roles
• Introducing and/or supplying you to actual or potential Clients
• Engaging you for a role with us or with our Clients including any related administration e.g. timesheets and
payroll
• Collating market or sector specific information and providing the same to our Clients
• Sending information to third parties with whom we have or intend to enter into arrangements which are
related to our Employment Services
• Providing information to regulatory authorities or statutory bodies, and our legal or other professional
advisers including insurers
• To market our Employment Services
• Retaining a record of our dealings
• Establishing quality, training and compliance with our obligations and best practice
• For the purposes of backing up information on our computer systems
Why we process your personal data:
1. Entering into and performing a contract with you:
To provide our Employment Services, we may enter into a contract with you, and/or your limited company, and/or
a third party. In order to enter into a contract we will need certain information, for example your name and address.
A contract will also contain obligations on both your part and our part and we shall process your data as is necessary
for the purpose of those obligations. For example, in order to process payroll, a national insurance number and
bank details will be required.
2. Compliance with legal obligations (regulatory and statutory obligations):
We must comply with a number of statutory provisions when providing our Employment Services, which
necessitate the processing of personal data. These include the Conduct of Employment Agencies and Employment
Businesses Regulations 2003, which amongst other things requires us to:
• Verify your identity
• Assess your suitability for an external job role
• Maintain records for specific periods
Where we engage a person to work for us (whether directly or as supplied to a Client), there are other statutory
obligations that must be complied with including payroll, tax, social security, HMRC reporting requirements, and
any other law or regulation.
We are also required to comply with statutory and regulatory obligations relating to business generally, for example
complying with tax, bribery, fraud/crime prevention and data protection legislation, and co-operating with
regulatory authorities such as HMRC or the Information Commissioner’s Office.
3. Our legitimate interests (carrying on the commercial activity of Employment Services):
In providing our Employment Services, we will carry out some processing of personal data which is necessary for
our legitimate interests, which include:
• Retaining records of our dealings and transactions and where applicable, use such records for the purposes
of:
– establishing compliance with contractual obligations with Clients or suppliers
– addressing any query or dispute that may arise including establishing, exercising or defending any legal
claims
– protecting our reputation
– maintaining a backup of our system, solely for being able to restore the system to a particular point in the
event of a system failure or security breach
– evaluating quality and compliance including compliance with this Privacy Notice
– determining staff training and system requirements
• Using your personal data to:
– assess suitability and contact you regarding potential opportunities and/or our services
– collate market information or trends including providing analysis to potential or actual Clients
– source potential opportunities or roles as part of our Employment Services
– personalise your experience and our offering, whether via our website or otherwise
This means that for our commercial viability and to pursue these legitimate interests, we may continue to process
your personal data for as long as we consider necessary for these purposes.
4. Consent to our processing of your data:
We may process your personal data on the basis that you have consented to us doing so for a specific purpose, for
example, if you apply for a specific role you may have consented to our processing of the data that has been
provided for the purpose of progressing your application and considering your suitability for that role. In other cases
you may have provided your written or verbal consent to the use of your data for a specific reason.
You may withdraw your consent to our processing of your personal information for a particular purpose at any
stage. However, please note that we may continue to retain, or otherwise use your personal information thereafter
where we have a legitimate interest or a legal or contractual obligation to do so. Our processing in that respect will
be limited to what is necessary in furtherance of those interests or obligations. Withdrawal of consent will not have
any effect on the lawfulness of any processing based on consent before its withdrawal.
What if we obtain your personal data from a third party?
Part of our business activity involves researching information relating to individuals for the purposes of filling job
roles. This may include obtaining personal data from online sources, for example we may obtain information from
social media sites such as LinkedIn and job boards,some information being publicly available but others being from
sites or providers to which we subscribe. From time to time we may also receive personal information about you
from hiring organisations, colleagues and former employers, or from persons for whom you have provided services
or been otherwise engaged.
Where information from third party sources is of no use to us, or where you have notified us that you do not want
us to provide you with services, we shall discard it, however we may maintain a limited record in order to avoid the
duplication of process. Where we consider that information may be of use to us in pursuance of the provision of
our Employment Services, any processing will be in accordance with this Privacy Notice. You do have the right to
object to processing, please see Section 4 ‘Your rights’.
Sensitive Personal Data (SPD)
Sensitive personal data is information which is intensely personal to you and is usually irrelevant to our
consideration of your suitability for a job role. Examples of SPD include information which reveals your political,
religious or philosophical beliefs, sexual orientation, race or ethnic origin, or information relating to your health.
Regardless of the basis for your dealings with us, we request that you do not provide us with any sensitive personal
data unless absolutely necessary. However, to the extent that you do provide us with any sensitive personal data,
such as data which you choose to share with us in conversation, we shall only use that data for the purposes of our
relationship with you or for the provision of our Employment Services. This will be for one or more of the following
reasons:
• You have explicitly consented to the processing
• For the purpose of our assessment of your suitability for job roles or working capacity
• Where processing is necessary for the purpose of obligations or rights under employment, social security or
social protection law
• To maintain records of our dealings to address any later dispute, including but not limited to the
establishment, exercise or defence of any legal claims
Who we share personal data with:
We shall not share your personal information unless we are entitled to do so. The categories of persons with whom
we may share your personal information include:
• Individuals, hirers and other third parties necessary for the provision of our Employment Services
• Any regulatory authority or statutory body pursuant to a request for information or any legal obligation
which applies to us
• Parties who process data on our behalf, which may include
o outsourced payroll providers
o IT support
o storage service providers including cloud
o background screening providers
• Legal and professional advisers
• Insurers
Automated decisions
We may use software to review the personal data of individuals recorded on our database, or who have applied for
specific roles. The software may determine suitability for a specific role via targeted questions relating to the role,
and/or may identify and select individual personal information according to the stored characteristics. For example,
the software may enable us to quickly identify individuals from our database who have specific skills, e.g. an
engineer and exclude individuals whose characteristics do not match particular requirements of a job role.
Where we use software to assist us with our assessment of your suitability for a particular job role and you consider
that any such assessment has been made wrongly or incorrectly, you may ask for an explanation.
Section 2: This section applies where you are an individual working for a third party with whom we
have dealings. For example, a client or a payroll company.
We may collect your personal data in the course of our dealings and this may include the following:
• Your contact information, which may include your full name, job role, contact telephone number and email
• Your statements and opinions about candidates and/or other personnel e.g. a reference
• Information relating to our relationship with you or the party for whom you work including records of any
meetings or discussions
• Your marketing preferences
We may obtain your personal data from the following sources (please note that this list is not exhaustive):
• You, including where you have provided us with your contact details or other information for the purposes
of using our Employment Services
• Staff or other representatives of the organisation you represent
• Candidates
• Marketing databases
• Social media
• The public domain
• Conversations, with you or others, on the telephone or video conferencing (which may be recorded) or in
meetings
• Notes following a conversation, with you or others, or meetings you attend
How we will use your personal data:
We will process your personal data in the context of our dealings with the third party for whom you work and as
part of our Employment Services. Processing may include:
• Collecting and storing your personal data, whether in manual or electronic files
• Using the data to communicate with you
• Sending information to third parties with whom we have or intend to enter into arrangements which are
related to our Employment Services
• Actions necessary to further any obligation on us pursuant to a contract between ourselves and the third
party you work for
• Collating market or sector specific information and providing the same to our clients
• Providing information to regulatory authorities or statutory bodies and our legal or other professional
advisers including insurers
• Retaining records of our dealings with you and the organisation whom you represent
• Establishing quality, training and compliance with our obligations and best practice
Why we process your personal data:
1. Compliance with legal obligations (regulatory and statutory obligations)
We must comply with a number of statutory provisions when providing our Employment Services, which
necessitate the processing of personal data. These include the Conduct of Employment Agencies and Employment
Businesses Regulations 2003, which amongst other things requires us to assess suitability of candidates and obtain
information from Clients.
We are also required to comply with statutory and regulatory obligations relating to business generally, for example
tax, bribery and fraud/crime prevention legislation, and co-operating with regulatory authorities such as HMRC.
2. Our legitimate interests (carrying on the commercial activity of Employment Services):
In providing our Employment Services, we will carry out some processing of personal data which is necessary for
our legitimate interests, which include:
• Using your personal data:
o to contact you regarding our Employment Services
o to assess suitability of Candidates and roles, for example, referencing or other feedback
o to collate market information or trends including providing analysis to potential or actual Clients
o as otherwise necessary to provide our Employment Services and/or to meet our obligations towards
either the party whom you represent, or other Clients or suppliers
o to personalise your experience and our offering, whether via our website or otherwise
• Retaining records of our dealings and transactions and where applicable, use such records for the purposes
of:
o establishing compliance with contractual obligations with Clients or suppliers
o addressing any query or dispute that may arise including establishing, exercising or defending any legal
claims
o protecting our reputation
o maintaining a backup of our system, solely for the purpose of being able to restore the system to a
particular point in the event of a system failure or security breach
o evaluating quality and compliance including compliance with this Privacy Notice
o determining staff training and system requirements
For our commercial viability and to pursue these legitimate interests, we may continue to process your personal
information for as long as we consider reasonably appropriate for these purposes.
3. Consent
We may process your personal data on the basis that you have consented to us doing so for a specific purpose, for
example, if you have provided your contact details in order that we may use these to provide you with details of
our services you may have consented to our processing of the data for that purpose. In other cases you may have
provided your written or verbal consent to the use of your data for a specific reason, for example references.
You may withdraw your consent to our processing of your personal data for a particular purpose at any stage.
However, please note that we may continue to retain, or otherwise use your personal information thereafter where
we have a legitimate interest or a legal or contractual obligation to do so. Our processing in that respect will be
limited to what is necessary in furtherance of those interests or obligations. Withdrawal of consent will not have
any effect on the lawfulness of any processing based on consent before its withdrawal.
What if we obtain your personal data from a third party?
Part of our business activity involves researching information for the purposes of finding and filling job roles. This
may include obtaining personal data from sources including job boards, advertisements, LinkedIn or other social
media, some information being publicly available but others being from sites or providers to which we subscribe.
From time to time we may also receive personal data about you from hiring organisations, colleagues and former
employers, or from persons for whom you have provided services or been otherwise engaged.
Where information from third party sources is of no use to us we shall discard it, however we may maintain a
limited record in order to avoid the duplication of process. Where we consider that information may be of use to
us in pursuance of the provision of our Employment Services, any processing will be in accordance with this Privacy
Notice. You do have the right to object to processing, please see Section 4 ‘Your rights’.
Sensitive Personal Data (SPD)
Sensitive personal data is information which is intensely personal to you and is usually irrelevant to our dealings
with you in respect of our Employment Services. Examples of SPD include information which reveals your political,
religious or philosophical beliefs, sexual orientation, race or ethnic origin, or information relating to your health.
Regardless of the basis for your dealings with us, we request that you do not provide us with any sensitive personal
data unless absolutely necessary. However, to the extent that you do provide us with any sensitive personal data,
such as data which you choose to share with us in conversation, we shall only use that personal data for the
purposes of our relationship with you or for the provision of our Employment Services. This will be for one or more
of the following reasons:
• You have explicitly consented to the processing
• Where processing is necessary for the purpose of obligations or rights under employment, social security or
social protection law
• To maintain records of our dealings to address any later dispute, including but not limited to the
establishment, exercise or defence of any legal claims
Who we share personal data with:
We shall not share your personal data unless we are entitled to do so. The categories of persons with whom we
may share your personal information include:
• Candidates and other third parties necessary for the provision of our Employment Services
• Any regulatory authority or statutory body pursuant to a request for information or any legal obligation
which applies to us
• Parties who process data on our behalf, which may include
o outsourced payroll providers
o IT support
o storage service providers including cloud providers
o background screening providers
• Legal and professional advisers and Insurers
Section 3: This section applies to all personal data
Transfer of data to other jurisdictions
During the provision of our Employment Services we may transfer data to countries or international organisations
outside of the EEA. This may, for example, be to Clients or Candidates, or third parties who provide support services
to us. Where information is to be so transferred, it may be to a country in respect of which there is an adequacy
decision from the EU Commission. However, if this is not the case, it is our policy to take steps to identify risks and
in so far as is reasonably practicable, ensure that appropriate safeguards are in place. Details relating to specific
countries or organisations are available on request from dpo@lucid-support.com
If you do not wish to provide us with necessary data
There may be circumstances where we require you to provide data which is necessary for us to meet statutory or
contractual obligations or perform our Employment Services. If you do not wish to provide us with information we
request then please notify us. However, please be aware that as a result we may be unable to provide you or the
party who you represent with an Employment Service, and in some cases may result in a breach of the contract we
have with you or a third party you represent.
Group companies & transfer
In the event of a sale, merger, liquidation, receivership or the transfer of all or part of our assets to a third party,
we may need to transfer your information to a third party. Any transfer will be subject to the agreement of the
third party to this Privacy Notice and any processing being only in accordance with this Privacy Notice.
Data Security and Confidentiality
It is our policy to ensure, in so far as is reasonably practicable, that our systems and records are secure and not
accessible to unauthorised third parties in line with contemporary practice.
Cookies
A cookie is a small file of letters and numbers that is downloaded on to your computer when you visit a website,
which enables the website to tailor its offerings to your preferences when you visit it.
We use cookies to help manage our website, make our website easier to use and support the provision of
relevant information and functionality. This is done to improve your visitor experience, as well as provide us with
information about how our website is used so that we can make sure it is as relevant and as error free as we can
make the site. By using our website, you agree to the use of cookies as described in this Cookie Policy.
Cookies set across our website, can be in the form of session cookies (lasting only as long as your visit to our
website) or persistent cookies, and may use different technologies, such as JavaScript or Flash. You can choose to
manage the cookies we use on our website through your internet browser settings at any time. Certain cookies
may be set as soon as you visit our website, but you can remove them using your internet browser settings.
If you have any further questions, require further clarification around our use of cookies or wish to discuss how
we are embracing online privacy, please email us at info@lucid-support.com
What happens if you disable cookies from our site?
Preventing cookies is likely to impact the functionality or performance of our website and could stop you from
using certain services provided through it. If you choose to disable cookies, we cannot guarantee how the
operation of our website will perform during your visit. It will also affect our ability to improve our website,
making changes to user preferences.
What are Cookies?
Cookies are small text files that are sent to and stored on your computer, smartphone or other device used to
access the internet, whenever you visit a website. Cookies are useful because they allow a website to recognise
the device you are using. We use cookies for a variety of reasons, such as to determine preferences, let users
navigate between pages efficiently, verify the user and other functions More information about cookies can be
found on allaboutcookies.org
Retaining your data
In most circumstances your data will not be retained for more than 6 years from the last point at which we provided
any services or otherwise engaged with you and it is our policy to only store your personal data for as long as is
reasonably necessary for us to comply with our legal obligations and for our legitimate business interests. However,
we may retain data for longer than a 6 year period where we have a legal or contractual obligation to do so, or we
form the view that there is otherwise a continued basis to do so, for example where your personal information
identifies specialist skill sets which may remain in demand, or we are subject to a legal obligation which applies for
a longer period.
If however you believe that we should delete your personal data at an earlier date, please inform us in writing of
your reasons. Please see Section 4 ‘Your Rights’ below.
Changes to this Privacy Notice
This Privacy Notice is regularly reviewed and may be updated from time to time to reflect changes in our business,
or legal or commercial practice. Where an update is relevant to our processing of your data, we shall notify you of
the same.
Section 4: Your rights
We take the protection of your personal data very seriously and it is important that you know your rights within
that context, which include rights to:
• Request a copy of the personal data that we hold
• Object to our processing of your data where that processing is based upon legitimate interest and there are
no compelling grounds for the continued processing of that data
• Request that we restrict processing of your data in certain circumstances
• Request that data is erased where the continued use of that data cannot be justified
• Object to any decision, which significantly affects you, being taken solely by a computer or via another
automated process
• Withdraw your consent to our processing of your personal data for a particular purpose at any stage.
However, please note that we may continue to retain, or otherwise use your personal information thereafter
where we have a legitimate interest or a legal or contractual obligation to do so. Our processing in that
respect will be limited to what is necessary in furtherance of those interests or obligations
• Request that inaccurate or incomplete data is rectified
• Request that data provided directly by you and processed by automated means is transferred to you or
another controller; this right only being applicable where our processing of your data is based either on your
consent or in performance of a contract
• Make a complaint to the Information Commissioner’s Office Request that direct marketing by us to you is
stopped
Please note that should you exercise your right to request that we erase data or cease any processing activity, we
may retain a record of this request and the action taken to both evidence our compliance, and to take steps to
minimise the prospect of any data being processed in the future should it be received again from a third-party
source.
If you have any questions concerning your rights or should you wish to exercise any of these rights, please contact
dpo@lucid-support.com
Complaints
If you are dissatisfied about any aspect of the way in which your data is processed you may, in the first instance
refer the matter to dpo@lucid-support.com
This does not affect your right to make a complaint to the Information Commissioner’s Office.