This policy explains how we use the information we collect about you via our website.
- What Information Do We Collect About You?
- How will We Use the information About You?
- Who Might We Share Your Information With?
- Where Do We Store Your Information?
- Marketing and our Legitimate Interests
- How Long do we Keep your Personal Data for?
- Google Analytics and Other Third-Party tools
- Access to Your Information
- Accuracy of Your Information
- Applying for a Job at Graymatter
- How to Contact Us
What Information Do We Collect About You?
We collect and store information about you that you voluntarily provide when you complete a ‘Contact Us’ form or telephone us using the number displayed on the ‘Contact Us’ page of the website. We also collect information about you if you register for any event that we are co-hosting with a partner or affiliate. This personal information may include your name, the Company you work for, your telephone number, IP address, location and email address. If you choose to telephone us, your call may be recorded so that we can ensure that we have a record of your enquiry and answer your request appropriately. If you contact us, we may keep a record of that correspondence, including any CV you have voluntarily submitted to us for recruitment purposes, via the website. Website usage information is also collected using cookies and other automated means such as Google Analytics and LinkedIn analytics. This may include details of your visits to the website, including but not limited to, location and traffic data, weblogs and other communication data as well as the pages you visit and resources or information you access.
How Will We Use the Information About You?
We use the information collected about you or submitted by you, to process and answer your request whether for recruitment purposes, services, event registration or for more information. If you agree, we also use your information to email you about the other similar products and services we think may be of interest to you.
We use the information collected by automated means to personalise your visits to our website. This includes such things as your IP address, the type of internet browser you are using and information on actions taken on the site or the route chosen to navigate through it as well as the number of times you have visited.
Collecting this information enables us to continually improve our site for visitors. We may also use it to perform data analyses, including anonymisation of personal information.
Who Might We Share your Information With?
In order to provide you with information about some services, we may share your information with third parties which include;
- Business partners such as Salesforce, where Graymatter Reply is partnering with them as a specialist provider to offer a service or host an event. For clarity, where an event is hosted with an affiliate such as Salesforce, any of your Personal Data collected regarding your attendance or participation in an Event, will be shared with them and will also be subject to the relevant affiliate’s Privacy Notice.
- Sub processors such as Salesforce, where these platforms are employed by Graymatter Reply
- Reply to automate some of our marketing communications.
- Third party sub processors used by Salesforce for some of their processing. Some of these third parties may work outside the EEA. Where this is the case, they will be obliged to meet identical contractual terms and conditions and security obligations for processing.
- Other companies and organisations for the purposes of fraud protection and credit risk reduction, to protect our rights, property or safety of employees, clients or others or otherwise comply with any legal obligation.
We will never sell your information to another provider.
Please be aware that we do provide the ability to share information, articles and news on our site with your own personal Twitter or LinkedIn account. When you choose to use this ‘share’ function, you will be redirected away from Graymatter Reply’s website to Twitter or LinkedIn, where your personal data is controlled and processed in line with the respective Privacy Policies of those US websites.
Where Do We Store Your Information?
Because we use marketing automation platforms and CRM software such as Salesforce to streamline our marketing, some of the data we collect from you may be transferred or stored outside the European Economic Area (EEA). It may also be processed by staff operating outside the EEA who work for these platforms. By submitting your personal data to us, you agree to this transfer, storing and processing. Such platforms are committed to ensuring that any such sub-processors protect your personal data to the same standard and under the same terms as are provided by us.
Marketing and our Legitimate Interests
‘Legitimate interests’ means the interests of our Company in conducting and managing our business to enable us to give you the best service; in this case to ensure that our marketing is relevant to you and we send you marketing that is tailored to your interests.
When you choose to complete a ‘Contact Us’ form on this website or telephone us for more information, you are registering your interest in receiving selected information about our marketing services. With respect for your privacy, it is only when you explicitly select how you wish to be contacted, by telephone and/or email, that we will contact you with marketing information.
How Long do we Keep your Personal Data?
We may retain your personal data for a period of time consistent with the original purpose of collection (see “Marketing and our Legitimate Interests” above).
Where you cancel your registration for an event hosted by us or co-hosted with an affiliate (see “Who Might we Share your information With?” above), your personal data will be deleted from Graymatter Reply’s systems on receiving your cancellation within the timescales set out in the event specific information. Failure to ‘show’ will not constitute a cancellation. Please refer to any affiliated partner’s Privacy Notice for details of how they manage your personal information.
The length of time we keep your information for, is determined by an assessment of the amount, nature and sensitivity of the information being processed, the potential risk of harm from unauthorised use or disclosure of your personal data and whether we can achieve the purposes of the processing through other means, as well as on the basis of applicable legal requirements.
After expiry of the applicable retention periods, your personal data will be deleted or anonymised. If there is any data that for technical reasons, we are unable to delete entirely from our systems, we will put in place appropriate measures to prevent any further use of such data.
For further information on applicable data retention periods, please contact us at DPTeam.firstname.lastname@example.org
You have the right at any time to stop us from contacting you for marketing purposes. In order to ensure that we can comply with your request, we will need to retain a minimal record of your information on a suppression list, including your forename, surname and email address.
Cookies are text files placed on your computer or mobile device to collect standard internet log information and visitor behaviour information. This information is used to track visitor use of our website, such as what pages are visited and in what order and what is downloaded and to compile statistical information on website activity.
You can set your browser to not accept cookies and the above websites tell you how to do this as well as how to remove cookies from your browser. Some of our features may not function as a result of doing this however.
You can manage your cookie settings at any time using the button below.
Google Analytics and Other Third-Party Tools
Google Analytics: http://www.google.com/analytics/learn/privacy.html
LinkedIn Analytics: For more information, see LinkedIn’s Privacy Statement at https://www.linkedin.com/legal/privacy-policy
Twitter Pixel: A pixel is a small amount of code on a web page or in an email notification. We use pixels to learn whether you’ve interacted with certain web or email content. This helps us measure and improve our services and personalise your experience on Twitter. You can find out more about Twitter’s pixel here; https://help.twitter.com/en/rules-and-policies/twi…
Access to Your Information
You have the right to request a copy of the information we hold about you. If you would like a copy of some or all of your personal information, please email or write to us at the following address; DPTeam.email@example.com We may make a small charge for this service. We aim to answer all such subject access requests within one month. This may be extended by a further two months where requests are complex or numerous.
Accuracy of Your Information
We want to make sure that your personal information is up to date and accurate. You can access the personal information we hold about you here so that you can check, correct or delete it. Please note that is may take up to 28 days for any changes to come into effect.
Applying for a Job at Graymatter reply
By submitting your CV to us via our website, you are deemed to have agreed that we can process your personal information as necessary to progress your application, including the processing of any sensitive data about you.
Data protection principles
In relation to your personal data, we will:
- Process it fairly, lawfully and in a clear, transparent way
- Collect your data only for reasons that we find proper for the course of your employment in ways that have been explained to you
- Use it only in the way that we have told you about ensure it is correct and up to date
- Keep your data for only as long as we need it
- Process it in a way that ensures it will not be used for anything that you are not aware of or have not consented to (as appropriate), and is not lost or destroyed
Types of information we may collect or you may provide
Your information may include some or all of the following;
- Your personal details including your name, address, date of birth, email address, telephone numbers your photograph if you have provided one (but note that we do not request photo ID as part of the recruitment process)
- Gender marital status
- Whether or not you have a disability
- Information included on your Curriculum Vitae (CV) including references, education history and employment history
- Documentation relating to your right to work in the UK driving licence check data
How we collect your data
We collect data about you in a variety of ways including the information you would normally include in a CV or a job application cover letter, or notes made by our interviewers during a recruitment interview. Other details may be collected directly from you in the form of official documentation such as your driving licence details, passport or other right to work evidence. In some cases, we will collect data about you from third parties, such as employment agencies or former employers when gathering references or credit reference agencies.
Personal data is stored on Reply’s central recruitment database within the company’s HR and IT systems.
Why we process your information
We use the information we collect from you to ensure we are complying with legal requirements such as:
- Carrying out checks in relation to your right to work in the UK and
- Making reasonable adjustments for disabled candidates
and in the legitimate interests of the Company when;
- Making decisions about who to offer employment to
- Making decisions about salary and other benefits
- Assessing skills gaps and training needs
- Dealing with legal claims made against us
If you are unsuccessful in your application, we may ask you if we can retain your data in case other suitable job vacancies arise at Graymatter for which we think you may wish to apply. You can simply decline, if you don’t want us to keep your information. Where we do not ask your consent to retain your details, your data will not be used for any reason other than in the ways explained in relation to the specific application you have made.
Special categories of data
Special categories of data are information about your health, sex life, sexual orientation, race, ethnic origin, political opinion, religion, trade union membership and genetic and biometric data.
By law, if we process special categories of data, we must do so in accordance with more stringent guidelines, which means we will only process special categories of data when the following applies:
- You have given explicit consent to the processing
- We must process the data in order to carry out our legal obligations
- We must process data for reasons of substantial public interest; or
- You have already made the data public.
Graymatter Reply does not routinely collect special category data for recruitment purposes. If you are invited to interview, we will ask you if you have any special needs or access requirements; this is to ensure the interview can go ahead and may be used to inform the consideration of any reasonable adjustments. We do not need your consent if we only use special categories of personal data in order to carry out our legal obligations or exercise specific rights under employment law.
Criminal conviction data
We will only collect criminal conviction data where it is appropriate for the job advertised and where the law permits us. Currently Graymatter Reply has no requirement to collect criminal conviction data.
If you do not provide your data to us
One of the reasons for processing your data is to allow us to carry out an effective recruitment process. Whilst you are under no obligation to provide us with your data, we may not able to process or continue with your application without it.
Sharing your information
Your CV and cover letter, if provided, will only be accessed by those directly involved in the evaluation and recruitment process. This includes, for example, the HR manager and those people within the hiring team who are responsible for screening your application and interviewing you. In some cases, a pseudonymised profile may be shared with a potential Reply client as part of your evaluation.
In some cases, we will collect information about you from third parties, such as employment agencies. Any such company will be designated as a Data Processor according to art.28 of GDPR. Your information will be shared with third parties if you are successful in your job application. In these circumstances, we will share your data to obtain references as part of the recruitment process. We may need to share your information with people or bodies outside of the European Economic Area if you have worked previously in a country beyond the EEA.
Protecting your information
To ensure your information is protected against accidental loss or disclosure, destruction and abuse, it will be stored on secure servers with limited, permissions-based and password protected access.
Organisational measures include a Data Protection policy which all staff are made aware of and a Data Transfer Security Policy that sets out the limited circumstances in which personal information can be transferred, the permission to be sought and the secure means by which it can be transferred.
Any third parties we share your information with, must implement appropriate technical and organisational measures to ensure the security of your data.
Your rights over your information
Where you have consented to our use of your information, you also have the unrestricted right to withdraw that consent at any time. Withdrawing your consent means that we will stop processing the data that you had previously given us consent to use. There are no consequences for withdrawing your consent but in some circumstances, we may continue to store your information for one year after the recruitment process has finished, in the legitimate interests of the company, to protect against potential legal claims.
How long we keep your data for
We only keep your data for as long as we need it for and this will depend on whether or not you are successful in your application.
If you are not successful we will routinely keep your data for up to three years once the recruitment exercise ends unless you specifically request deletion.
At the end of this period, we will delete or destroy your data, unless you have already withdrawn your consent to our processing of your data in which case it will be deleted or destroyed upon your withdrawal of consent.
If your application is successful, your data will be kept and transferred to the systems we administer for employees. We have a separate privacy notice for employees, which will be provided to you.
Automated decision making
Automated decision-making is where a decision is taken about you using an electronic system without human involvement and which has a significant impact on you. No automated decision technology will be used at Graymatter Reply.
Data Controller and Privacy Lead
Reply S.p.A. (with registered office at Corso Francia 110, Turin), Reply Deutschland SE (with registered office at Bartholomäusweg 26 D-33334 Gütersloh), Reply LTD (with registered office at 38 Grosvenor Gardens, London SW1W 0EB) together with one or more Reply Group Companies are the Joint Controllers of this recruitment processing activity, according to Art.26 of GDPR.
The contact details of the UK Reply Data Protection Officers are:
UK DPO: firstname.lastname@example.org
How to Contact Us
By email: DPTeam.email@example.com
Or write to us at; Graymatter Reply Limited, DP Team, 18 Davy Avenue, Knowlhill, Milton Keynes MK5 8PL.