Up Front Soft is committed to protecting and respecting your privacy.
This policy sets out the basis of personal data we collect from you, that you provide to us, and how that data will be processed by us in line with our legal obligations to you.
For the purpose of the General Data Protection Regulation (Regulation (EU) 2016/679) (the GDPR), the data controller is
Up Front Soft (UK) Ltd
47-49 Park Royal Rd,
What does Up Front Soft (UK) Ltd do?
Up Front Soft provides software solutions related services to clients and we will, therefore, use your personal data in order for us to be able to deliver these services to you whether you be a; client or website user.
What kind of personal information do we collect?
The client data we collect is fairly minimal. In line with the information we require to operate our business as a provider of recruitment services, but will incorporate the following:
Company phone number
Any information you have chosen to disclose as part of our business dealings
Supplier data we collect simply relates to the information we need to enable our relationship to run smoothly. It will incorporate the following:
Any information you have chosen to disclose as part of our business dealings
We collect limited information that is purely focussed on helping us to improve your experience whilst using our website. This includes how you use our website, how often you access our website, your location and any contact details you provide by filling in a contact form.
Collection of your personal data
Client personal data is collected in three ways:
Data we receive directly from you
Data we receive from other sources
Personal data we collect automatically
Data we collect from you
We want to find the best staff for you and your organisation. We will collect data in two main ways:
Where you contact us directly by phone or email
Where we contact you by either phone or email, or through our consultants wider business development activities
Data from other sources
We may collect your data from other sources where your details are available in the wider public domain by way of due diligence or market intelligence including:
From reviewing market & business trends through the analysis of online and offline media
From delegate lists at events
Data we collect automatically
By using our website or clicking or reading an email from us in line with any local laws and requirements we may also collect data automatically.
Use of your personal data
We use client information in the following ways:
Software Solutions Activities
For legal purposes
Further detail on this is here:
Software Solutions Activities
Software Solutions as a service is what our business is focussed on. The main purpose of processing client data is therefore centred on the providing solutions. We will use your data in the following ways to assist this:
Storing your details on our database so that we can contact you about software solutions services
Keeping records of conversations and meetings so that we can tailor our services to you
Undertaking client satisfaction questionnaires
Processing your data for the purpose of targeting appropriate marketing campaigns
We will use these details where we deem it necessary in line with our legitimate interest which is our legal basis for processing your data. For more information, please refer to Our legal bases for processing your data below.
We will not seek consent when sending business to business emails as the rules on consent do not apply to business to business emails. However, where your personal data is processed to send business to business emails you have the right to object to direct marketing.
You have the right to object to us processing your data for the purposes of direct marketing and you can do so by clicking this Unsubscribe link. We will then ensure we no longer contact you by email for direct marketing, however, we will keep your data in line with our data retention policy unless you specifically request that we delete you from our CRM.
If you would prefer Up Front Soft to no longer retain your details please click Remove Details and Up Front Soft will completely remove you from our system.
We will only use the data provided for intended purposes:
To store your details on our database in order to be able to contact you in line with the services you are providing to us
To obtain support and services from you
Where necessary to deal with any legal claims or legal obligations
Data we receive from clients & staff
From a reference taking perspective, this could be integral to a candidate securing or not securing an opportunity
If your data was processed for reference purposes we may on occasion use your details to discuss recruitment services with you where we think it may be of interest to you at which point we will use your data for the same purpose we do as a client.
Who we share your personal data with
In line with all local laws and requirements your data may be shared for any of the reasons outlined below:
Tax, audit or government bodies relating where we are requested to do so by law
Third-party service providers carrying out work on our behalf under our instruction whether that be professional advisers such as lawyers, auditors or accountants, IT service providers carrying out work relating to our technology or services
Third-party outsourced IT & document storage providers where we have a processing agreement (or similar protection) in place
Marketing technology platforms
How we safeguard your personal data
We will do what we reasonably can to protect the personal data we hold from misuse, loss or unauthorised access.
If you suspect any misuse, loss or unauthorised access of your personal data please let us know immediately HERE
Data Retention Period
We will retain client data for a period of 4 years.
If we have not had meaningful contact by the end of those 4 years we will delete you from our CRM.
If we have not had a meaningful contact that has involved you updating us about your circumstances in relation to looking for work within that period of time we will delete your data from our systems.
For a client, meaningful contact refers to an interaction between both parties, be it written or verbal, where you actively engage with our online services or where you request services from us relating to recruitment. We will not consider contact to be where you have received, opened and read any communication we have sent to you without actually responding to it.
From a supplier perspective, we will maintain your data in line with the duration of any contractual agreements that we have in place.
This data retention policy will only be superseded in situations where we are legally obliged to maintain your data for a longer period than the period stated.
How to access and control the data we hold
Once we have processed your data you have rights over it.
It is likely that we will keep a record of communication with you to help resolve any issues raised.
Right to Object
You have the right to object to certain types of processing such as; direct marketing or where we have processed your details under legitimate interests.
We can refuse your right to object where we have processed your data to aid in dealing with any legal claim or legal matter.
If your process relates to direct marketing we must act on your objection by ceasing this activity.
Right to withdraw consent
Where we have obtained consent as the legal basis for processing your data you can withdraw consent at anytime. Where there is a requirement by law for us to retain data for a certain period of time we will be legally unable to delete or remove this data.
Data Subject Access Requests (DSAR)
You can ask us to confirm what information we hold about you at any time as well as requesting us to modify, update or delete such information. We will ask you to verify your identity and for more information about your request. You will not be charged for this request unless the request is “unfounded” or excessive. If you make multiple requests for the same data whilst we can’t charge you every time we may charge an administration fee if we constantly get the same request from you. If we refuse the request for any reason we will confirm in writing with the reason as to why.
Right to erasure
You have the right to request that we erase your personal details. The only reason we wouldn’t do this is where we are required to keep the information we hold by law for a certain period of time. Where this is the case we will inform you in writing.
If you are a candidate it is likely that we have processed you from a job board or wider public entity. If you do not remove your details from where we originally processed your data it is possible we may end up processing it again with no knowledge of it had previously existed. Where this is the case we do offer an alternative that allows us to know that you have previously requested this but would mean Up Front Soft retaining minimal information for us to identify who you are and that you have previously requested removal.
Our legal bases for processing your data
Article 6-1-f of the GDPR states that we can process your data where “processing is necessary for the purposes of the legitimate interests pursued by the controller [Up Front Soft] or by a third party except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data.”
As already established, Up Front Soft is a company that provides software solutions services to clients.
Where you have made your personal data available within these circumstances we will also provide you with updates on similar positions on email based around a soft opt-in that is you have made your data available to us for the purposes of recruitment services including receiving updates about job opportunities that could be suitable to you.
You have the right to object to us processing your data on this basis and you can do so by clicking HERE
Where requested by the client once we have introduced you for a role we will also likely need to process further information as requested on their behalf to fulfil a contract with them. That is to provide them with reference details, criminal record and financial background checks. The collection of such personal information will be requested from you and each consultant will explain why.
From a client perspective, we will think it is reasonable to collect data relating to individual contacts of an organisation as well as keeping records of conversations (email & phone calls) meetings, jobs registered and placed with you. As a business that provides software solutions services to clients, we deem it legitimate to collect this information in order to fulfil our requirements as a profit-making business.
Contract as a legal basis for processing data
For Up Front Soft members of staff or contractors working on client site for Up Front Soft, we will work on the basis Contract.
The ICO states that Article 6(1)(b) gives you a lawful basis for processing where:
“processing is necessary for the performance of a contract to which the data subject is a party or in order to take steps at the request of the data subject prior to entering into a contract."
Legal Obligation as the legal basis for processing data
There may be times where Up Front Soft has to exercise or defend a legal claim and in doing so may need to process your details for this purpose.
Article 6(1)(c) provides a lawful basis for processing where:
“processing is necessary for compliance with a legal obligation to which the controller is subject.”
How to contact us
You can get in contact with us anytime in order to discuss any of the following:
To access, amend or request a delete of your personal data
If you suspect any misuse or loss of or unauthorised access to your personal information
To exercise the right for you to object to the processing of your data
You can write to us at the following email address: email@example.com