JBCSTYLE LIMITED
JBCStyle Limited (“JBC“, “we”, “our”, and “us”) and its affiliated entities including JBCConnect Limited, is committed to protecting any personal information received, as a data controller, from our candidates, clients and users of the Sites. Personal information is any information that is capable of identifying you as an individual person. This policy explains how we collect and process personal information that you provide or which is obtained by us when you use our recruitment services and/or visit our website.
This website (and any mobile site or applications that link to this privacy policy) (collectively, the “Sites”) is owned and operated by JBCConnect Limited (a limited liability company registered in England and Wales under number 10352243 with its registered office at 2 Eastbourne Terrace, London, United Kingdom, W2 6LG).
The Sites are not intended for or directed at children under the age of 16 years and we do not knowingly collect data relating to children under this age.
We are registered with the Information Commissioner’s Office under registration number ZA370528.
JBC are not required to appoint a formal data protection office under data protection laws. However, we have appointed Dhana Toulson as our privacy manager who is responsible for overseeing questions in relation to this privacy policy.
CONTACTING USIf you have any questions about our privacy policy or your information, or to exercise any of your rights as described in this privacy policy or under data protection laws, you can contact us: By post: By email: By telephone: +44 (0)203 002 0626 |
DATA PROTECTION PRINCIPLES
JBC adheres to the following principles when processing your personal information:
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Lawfulness, fairness and transparency – data must be processed lawfully, fairly and in a transparent manner.
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Purpose limitation – data must be collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes.
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Data minimisation – data must be adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed.
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Accuracy – data must be accurate and, where necessary, kept up to date.
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Storage limitation – data must be kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal information are processed.
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Integrity and confidentiality – data must be processed in a manner that ensures appropriate security of the personal information, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage by using appropriate technical or organisational measures.
PERSONAL INFORMATION WE COLLECT
We collect personal information as necessary to enable us to carry out the recruitment services you have requested. The categories of personal information that we may collect in the course of providing our services to you includes, but is not limited to, the following:
For candidates
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first and last name;
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personal contact details such as title, home address, home telephone number, mobile number and email address;
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company name where the candidate is a limited company contractor;
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date of birth;
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gender;
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marital status and dependents;
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next of kin and emergency contact information;
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passport, driving licence and similar documents;
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education history, training and professional experience;
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current and past employment details;
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immigration status and work permits;
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nationality/place of birth;
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languages spoken and level of proficiency;
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photograph(s) of you;
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other information given in your CV and cover letter;
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references;
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national insurance number;
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information about your current salary, pensions and benefits;
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bank details.
We also collect, store and use the following “special categories” of more sensitive personal information and criminal convictions data about candidates, as follows:
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information about your race or national or ethnic origin, religious, philosophical or moral beliefs, or your sexual life or sexual orientation;
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information about your health, including any medical condition, health, sickness records and disability-related information; and
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information about criminal convictions and offences.
For clients
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full name;
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contact details such as telephone number and email address;
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information about your organisation; and
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extra information you choose to tell us.
Information collected from third parties
We may collect personal information about candidates from the following third party sources:
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recruitment websites and job boards, from which we collect the following categories of data: name and contact details, information contained in your CV and information about your experience in your portfolio;
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publicly accessible sources such as LinkedIn, Facebook and Business of Fashion (BoF), from which we collect the following categories of data: name and contact details, your skills and experience, qualifications and previous employment history.
Information you give us on the Sites
When using our Sites, whether as a client or candidate looking for a job through JBC, you may provide personal information such as your name, email address and extra information that you choose to tell us (i.e. about your employment preferences). This includes information you provide when you:
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request additional information or materials regarding our services on the Sites or ask us to contact you;
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are a candidate visiting our Sites and seeking information about employment opportunities and create an account with us;
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are a client of JBC visiting our Sites and looking for candidates for your organisation;
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report a problem with our Sites.
Information we automatically collect from you on the Sites
JBC may collect, store and use information about your visits to the Sites and about your computer, tablet, mobile or other device through which you access the Sites. This includes your Internet protocol (IP) address.
WHAT WE DO WITH YOUR PERSONAL INFORMATION
We will only use your personal information if we have a legal basis for doing so.The table below sets out the purposes for which JBC will use your personal information (excluding sensitive personal information – see below) and our legal basis for doing so:
Purposes for which we will process the information |
Legal Basis for the processing |
To provide recruitment services to candidates and clients, and to facilitate the recruitment process. |
For the performance of our contract with you or to take steps at your request before entering into a contract. |
To enable candidates to register on our Sites and create an account with us. |
It is in our legitimate interests to provide our services to you and to register you at your request. We consider this use to be necessary for our legitimate interests and proportionate. |
To assess and verify candidates skills, qualifications and suitability for roles and send your information to clients. |
For the performance of our contract with you or to take steps at your request before entering into a contract. |
To carry out background checks on candidates. |
It is in our legitimate interests to ensure that candidates are suitable for the roles we put them forward for with our clients.We consider this use to be necessary for our legitimate interests and proportionate. |
To communicate with candidates and clients about the recruitment process. |
For the performance of our contract with you or to take steps at your request before entering into a contract. |
To respond to general enquiries on the Sites and offline. |
It is in our legitimate interests to respond to your queries and provide any information and materials requested in order to develop our business. We consider this use to be proportionate and will not be prejudicial or detrimental to you. |
To store (and update) candidates’ details on our database so that we can contact candidates about employment opportunities. |
It is in our legitimate interests to maintain our business relationship with candidates. We consider this use to be necessary for our legitimate interests and proportionate. |
To send candidates notifications about job opportunities where they sign up to receive alerts. |
It is in our legitimate interests to provide this service as part of our overall recruitment service. We consider this use to be necessary for our legitimate interests and will not be prejudicial or detrimental to you. |
To post client testimonials on the Sites. |
It is in our legitimate interests to promote our services. We consider this use to be necessary for our legitimate interests and proportionate. |
To comply with our internal business policies. |
It is in our legitimate interests or those of a third party to adhere to our own internal procedures so that we can deliver an efficient service to you. We consider this use to be necessary for our legitimate interests and proportionate. |
To send you marketing materials and other communications we believe may be of interest to you. |
It is in our legitimate interests to market our services. We consider this use to be proportionate and will not be prejudicial or detrimental to you. |
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To enforce the terms and conditions and any contracts entered into with you. |
It is in our legitimate interests to enforce our terms and conditions of service. We consider this use to be necessary for our legitimate interests and proportionate. |
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To send you information regarding changes to our policies, other terms and conditions and other administrative information. |
It is in our legitimate interests to ensure that any changes to our policies and other terms are communicated to you. We consider this use to be necessary for our legitimate interests and will not be prejudicial or detrimental to you. |
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For all these categories, it is in our legitimate interests to continually monitor and improve our services and your experience of the Sites and to ensure network security. We consider this use to be necessary for our legitimate interests and will not be prejudicial or detrimental to you. |
Where we rely on legitimate interests as a lawful basis, we will carry out a balancing test to ensure that your interests, rights and freedoms do not override our legitimate interests. If you want further information on the balancing test we have carried out, you can request this from us by contacting us as provided above.
Where you provide consent, you can withdraw your consent at any time and free of charge, but without affecting the lawfulness of processing based on consent before its withdrawal. You can update your details or change your privacy preferences by contacting us as provided above.
If you choose not to provide information requested, which is necessary for us to assess your suitability for roles (such as evidence of qualifications or work history), we will not be able to provide the services to you. For example, if we require a credit check or references for the role and you fail to provide us with relevant details, we will not be able to take your application further.
JBC will only use your personal information 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 we need to use your personal information for an unrelated purpose, we will notify you in a timely manner and we will explain the legal basis which allows us to do so.
SPECIAL CATEGORIES OF (“SENSITIVE”) PERSONAL INFORMATION
We will use your sensitive personal information in the following ways:
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information about your disability status to consider whether we need to provide appropriate adjustments during the recruitment process, for example whether adjustments need to be made during an interview;
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diversity information about your race or national or ethnic origin, religious, philosophical or moral beliefs, or your sexual life or sexual orientation, to ensure equal opportunity monitoring and reporting.
We process these special categories of personal information on the basis of one or more of the following:
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where the processing is necessary for carrying out obligations in the employment field;
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where you have given explicit consent to the processing of the personal information for one or more specified purposes;
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where the processing relates to personal information which is manifestly made public by you;
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where the processing is necessary for reasons of substantial public interest in accordance with applicable law. This includes where the processing is necessary for equality of opportunity of treatment; and
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where the processing is necessary for the establishment, exercise or defence of legal claims.
INFORMATION RELATING TO CRIMINAL CONVICTIONS & OFFENCES
We will collect information about your criminal convictions history where necessary for certain roles which are listed on the Rehabilitation of Offenders Act 1974 (Exceptions) Order 1975 (SI 1975/1023) and so are eligible for a standard or enhanced check from the Disclosure and Barring Service.
This information will be processed on the basis of one or more of the following:
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the processing is necessary for exercising obligations or rights in connection with employment;
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the processing is necessary for reasons of substantial public interest in accordance with applicable law. This includes where the processing is necessary:
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for equality of opportunity of treatment;
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for the purposes of the prevention or detection of an unlawful act or for preventing fraud.
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the processing is necessary for the purposes of, or in connection with any legal proceedings (including prospective legal proceedings), or necessary for obtaining legal advice; or otherwise necessary for establishing, exercising or defending legal rights.
MARKETING AND JOB ALERTS
We also use your personal information to notify candidates and clients by email, telephone, SMS or post about services which we think might be of interest to you and to send you information we think you may find interesting. You may choose to sign up to our job alerts service so that we can notify you by email of new jobs that match your search.
For marketing purposes, we may disclose personal information to our affiliated offices in the USA and Amsterdam or to third parties providing marketing services to us, or with whom we are conducting joint marketing exercises.
You have the right to opt out of receiving direct marketing communications from us at any time by:
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contacting the privacy manger using the contact details set out above; and
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using the “unsubscribe” link in emails.
You may ask to unsubscribe from job alerts at any time by using the “unsubscribe” link in notification emails.
DISCLOSURE OF YOUR PERSONAL INFORMATION TO THIRD PARTIES
JBC will not share or otherwise disclose your personal information, except as set out in this privacy policy. We share your personal information with the following parties:
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with JBC staff as necessary to carry out the purposes for which the information was supplied or collected (i.e. to provide the services you have requested);
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with potential employers (our clients) to increase your changes of finding employment;
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with our group companies and offices based in the USA, France and the Netherlands as necessary to carry out the purposes for which the information was supplied or collected;
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with our third party service providers who assist with the running of the Sites and our services including marketing, database service providers, IT services such as backup and disaster recovery service providers in the USA and Europe;
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individuals or organisations who hold information relating to your reference or application (i.e. past employers, examining bodies);
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third parties engaged by JBC to provide services such as reference, qualification and background checks;
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our accountants and tax partners and lawyers as necessary for the provision of our services.
Our third party service providers are subject to security and confidentiality obligations and are only permitted to process your personal information for specified purposes and in accordance with our instructions.
In addition, JBC may disclose information about you:
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in the event that we sell or buy any business or assets, in which case we may disclose your personal information to the prospective seller or buyer of such business or assets;
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if all or substantially all of JBC’s assets are acquired by a third party, in which case personal information held by it about its customers will be one of the transferred assets;
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if we are under a duty to disclose or share your personal information in order to comply with any legal obligation;
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if necessary to protect the vital interests of a person;
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to enforce or apply our terms and conditions or to establish, exercise or defend the rights of JBC, our staff, clients or others.
INTERNATIONAL TRANSFERS
To deliver our services to you, it is sometimes necessary for us to transfer and store your personal information to a location outside the European Economic Area (“EEA”) as follows:
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with our group companies in the USA;
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with our third party service providers located outside the EEA;
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where you are based outside the EEA;
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where clients within the EEA, transfer your personal information outside the EEA;
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to a cloud-based storage provider.
This includes the USA.
These non-EEA countries do not have the same data protection laws as the United Kingdom and EEA. Where personal information is transferred to and stored outside the EEA, we take steps to provide appropriate safeguards to protect your personal information, including:
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transferring your personal information to a country, territory, sector or international organisation which the European Commission has determined ensures an adequate level of protection, as permitted under Article 45(1) of the GDPR;
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entering into standard contractual clauses approved by the European Commission, obliging recipients to protect your personal information as permitted under Article 46(2)(c) of the GDPR;
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under the EU-U.S. Privacy Shield Framework which enables U.S. business to self-certify as a means of complying with EU data protection laws.;
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where the transfer is necessary for the performance of a contract between you and JBC as permitted under Article 49(1)(b) of the GDPR; and
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where you have provided explicit consent to the transfer and have been informed of the risks, as permitted under Article 49(1)(a) of the GDPR.
To obtain a copy of the standard contractual clauses, please contact our privacy manager. If you want further information on the specific mechanism used by us when transferring your personal information out of the EEA, please contact the privacy manger using the details set out above.
SECURITY OF YOUR PERSONAL INFORMATION
JBC use appropriate technical and organisational safeguards to protect personal information both online and offline from unauthorised use, loss or destruction. We use industry standard physical and procedural security measures to protect information from the point of collection to the point of destruction. This includes encryption, firewalls, access controls, policies and other procedures to protect information from unauthorised access.
Only authorised personnel and third party service providers if and when necessary are permitted access to personal information, and that access is limited by need. Where data processing is carried out on our behalf by a third party, we take steps to ensure that appropriate security measures are in place to prevent unauthorised disclosure of personal information.
Despite these precautions, however, JBC cannot guarantee the security of information transmitted over the Internet or that unauthorised persons will not obtain access to personal information. In the event of a data breach, JBC have put in place procedures to deal with any suspected breach and will notify you and any applicable regulator of a breach where required to do so.
HOW LONG WE KEEP YOUR PERSONAL INFORMATION
Your personal information will not be kept for longer than is necessary for the purposes for which it was collected and processed. We will retain candidates’ personal information for as long as your account is active or as needed to provide you with services you have requested.
The criteria we use for retaining different types of personal information, includes the following:
General queries – when you make an enquiry or contact us by email or telephone, we will retain your information for as long as necessary to respond to your queries. After this period, we will not hold your personal information for longer than one year if we have not had any active subsequent contact with you;
Direct marketing – where we hold your personal information on our database and systems for direct marketing purposes, we will retain your information for no longer than four years if we have not had any active subsequent contact with you.
Legal and regulatory requirements – we may need to retain personal information for up 7 years after we cease providing services to you where necessary to comply with our legal obligations, resolve disputes or enforce our terms and conditions.
YOUR RIGHTS
Subject to certain limitations, you have rights under data protection laws in relation to your personal information. These rights include the rights to:
Access to and updating your personal information
You have the right to access information which we hold about you (“data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we processing it lawfully. Note, that we may refuse to comply with a data subject access request if the request is manifestly unfounded or excessive or repetitive in nature.
You also have the right to receive your personal information in a structured and commonly used format so that it can be transferred to another data controller (“data portability”). Note, that this right only applies where your personal information is processed by us with your consent or for the performance of a contract and when processing is carried out by automated means.
We want to make sure that your personal information is accurate and up to date and you have the right to have inaccurate personal information rectified or completed if it is incomplete. We may refuse to comply with a request for rectification if the request is manifestly unfounded or excessive or repetitive.
Right to object
Direct marketing
You have the right to object at any time to our processing of your personal information for direct marketing purposes.
Where we process your information based on our legitimate interests
You also have the right to object, on grounds relating to your particular situation, at any time to processing of your personal information which is based on our legitimate interests. Where you object on this ground, we shall no longer process your personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms or for the establishment, exercise or defence of legal claims.
Your other rights
You also have the following rights under data protection laws to request that we rectify your personal information which is inaccurate or incomplete.
In certain circumstances, you have the right to:
- request the erasure of your personal information erasure (“right to be forgotten”);
- restrict the processing of your personal information to processing in certain circumstances.
Please note that the above rights are not absolute and we may be entitled to refuse requests, wholly or partly, where exceptions under the applicable law apply. We may refuse a request for erasure, for example, where the processing is necessary to comply with a legal obligation or necessary for the establishment, exercise or defence of legal claims. We may refuse to comply with a request for restriction if the request is manifestly unfounded or excessive or repetitive in nature.
EXERCISING YOUR RIGHTS
You can exercise any of your rights as described in this privacy policy and under data protection laws by contacting us as provided above.
Save as described in this privacy policy or provided under data protection laws, there is no charge for the exercise of your legal rights. However, if your requests are manifestly unfounded or excessive, in particular because of their repetitive character, we may either: (a) charge a reasonable fee taking into account the administrative costs of providing the information or taking the action requested; or (b) refuse to act on the request.
Where we have reasonable doubts concerning the identity of the person making the request, we may request additional information necessary to confirm your identity.
COOKIES
For our internal payroll system, we use small files commonly known as “cookies”. A cookie is a small amount of data which often includes a unique identifier that is sent to your computer or mobile phone (your “device”) and is stored on your device’s browser or hard drive. The cookies we use for our internal payroll system won’t collect personally identifiable information about you and we won’t disclose information stored in cookies that we place on your device to third parties.
By continuing to use our services, you are agreeing to our use of cookies.
If you don’t want us to use cookies, you can set your internet browser not to accept cookies. However, if you block cookies some of the features on our internal time, attendance and payroll system may not function as a result.
You can find more information about how to manage cookies for all the commonly used internet browsers by visiting www.allaboutcookies.org. This website will also explain how you can delete cookies which are already stored on your device.
We currently set the following cookies:
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Cookie |
Purpose |
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Session Cookie |
To track that you have logged in to use the site(s). No personal information is stored. |
We use “Google Analytics” on the Sites. This cookie provides us with a visitor count and an understanding of how visitors move around and use the website. We can then use this information to improve navigability and the Sites generally. The cookies we use on the Sites won’t collect personally identifiable information about you and we won’t disclose information stored in cookies that we place on your device to third parties.
Visitors to our Sites can adjust their browsers to refuse cookies but if not adjusted, the Sites will deliver the cookie as soon as the Sites is visited. You can find more information about how to manage cookies for all the commonly used internet browsers by visiting www.allaboutcookies.org. This website will also explain how you can delete cookies which are already stored on your device.
We are obliged by Google Analytics to state the following:
This website uses Google Analytics, a web analytics service provided by Google Inc. (“Google”). Google Analytics uses “cookies”, which are text files placed on your computer, to help the website analyse how users use the site. The information generated by the cookie about your use of the website (including your IP address) will be transmitted to and stored by Google on servers in the United States. Google will use this information for the purpose of evaluating your use of the website, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf. Google will not associate your IP address with any other data held by Google. You may refuse the use of cookies by selecting the appropriate settings on your browser, however please note that if you do this you may not be able to use the full functionality of this website. By using this website, you consent to the processing of data about you by Google in the manner and for the purposes set out above.
LINKS
The Sites may, from time to time, contain links to and from the websites of our affiliates, advertisers and social media platforms including Facebook, Twitter and Instagram.
If you follow a link to any of these websites, please note that these websites have their own privacy policies and JBC does not accept any responsibility or liability for these policies. Please check these policies before you submit any personal information to these websites.
COMPLAINTS
If you have concerns about our use of your personal information, please send an email with the details of your complaint to our privacy manager using the contact details provided above.
You have the right to make a complaint at any time with a supervisory authority, in particular in the EU (or EEA) state where you work, normally live or where any alleged infringement of data protection laws occurred.The supervisory authority in the UK is the Information Commissioner’s Office (“ICO”) who can be contacted at https://ico.org.uk/ or telephone on 0303 123 1113.
CHANGES TO OUR PRIVACY POLICY
JBC may change this privacy policy from time to time. The current version will always be available from us in hard copy or on our Sites. We will post a prominent notice on the Sites to notify you of any significant changes to our privacy policy, or update you by other appropriate means.
This privacy policy was last updated on 23 May 2018.