ML Digitech Ltd IT Privacy Policy and Incident Response Plan
Identity and contact details of the controller and where applicable, the controller’s representative) and the data protection officer
Joseph Ferguson – Joe@mldigitech.com 07583260614
Purpose of the processing and the legal basis for the processing
ML Digitech processes personal data for the purpose of recruitment activity. This includes assessing the suitability of individuals for job roles, contacting individuals to gain updates on their job status and skills and to engage with prospective employers or hiring managers about their recruitment plans. The legal basis for such processing will be based on the specific consent of the individual, or in certain cases where legitimate interests may apply. ML Digitech Ltd will also process data on the basis of an individual entering into a contract with ML Digitech Ltd, and such data is required to be processed under the terms of the contract.
Categories of personal data
Personal data means data which relate to a living individual who can be identified –
(a) from those data, or
(b) from those data and other information which is in the possession of, or is likely to come into the possession of, the data controller,
and includes any expression of opinion about the individual and any indication of the intentions of the data controller or any other person in respect of the individual.
ML Digitech Ltd may process data including: email addresses, names, postal addresses, employment history or other personally identifiable information that an individual includes within a CV.
Any recipient or categories of recipients of the personal data
ML Digitech Ltd may disclose personal data to prospective employers on behalf of the data subject (with prior consent). ML Digitech may also disclose personal data to third parties, only if applicable and with consent of the data subject (for example - reference or background checking agencies).
Transfers to third country and safeguards
ML Digitech Ltd does not transfer data to third countries (outside the EEA). In the unlikely event we are required to do so adequate safeguards would be put in place in line Data Protection Law and principles.
Retention period or criteria used to determine the retention period
ML Digitech Ltd will usually retain personal data for a period of two years. However this period would continue if we remained in contact and the data subject consented to it. In some instances Personal data will be retained in accordance with the contractual obligations between ML Digitech Ltd and the individual.
The Rights of Data Subjects
- Data Subjects will have the right to withdraw their consent at any time. The easiest way to do this is to email Rob@mldigitech.com
- Data Subjects have the right to launch a complaint to the appropriate supervisory authority
- Data Subjects have the right to submit a Subject Access Request (SAR) at any time to Rob@mldigitech.com. There will be no fee applicable and the data will be supplied within one month of the request.
The source the personal data originates from and whether it came from publicly accessible sources
Data processed by ML Digitech Ltd is predominately sourced from the Data Subject directly via their CV or contact details sent through email or other communication channels such as LinkedIn. ML Digitech Ltd also processes data from publicly accessible sources.
The existence of automated decision making, including profiling and information about how decisions are made, the significance and the consequences.
ML Digitech Ltd use software to help filter data in order to identify suitable individuals for specific vacancies or client requirements.
Data Breach Incident Response
In the event of a Data breach ML Digitech Ltd will:
- Our designated DPO will take the lead on investigating the breach along with our hosting provider.
- Engage with our hosting provider to isolate and/or shut down the area compromised.
- If the breach could result in a risk for the rights and freedoms of the data subject(s) ML Digitech Ltd will notify the ICO no later than 72 hours after becoming aware of the breach.
- Provide the ICO details regarding the nature of the breach and the categories and approximate number of data subjects and personal data records affected.
- Where there is high risk to the rights and freedoms of the Data Subject, ML Digitech Ltd will notify the breach to the Data Subjects without undue delay. In the event of Data loss or if otherwise unfeasible to contact the Data Subjects, ML Digitech Ltd will make a public communication whereby Data Subjects are informed in an effective manner. This will be done through the most appropriate media platform(s) available. Such notifications will include the name and contact details of our designated DPO.
- Document the mitigating measures taken or proposed to be taken and share these with the ICO and the Data Subjects that have been affected.