Introduction

Harrington Starr Group, including Harrington Starr Limited, The North Starr Limited, and Search 5.0 Limited (collectively referred to as "the Group"), respects your privacy and is committed to protecting your personal data. This privacy notice explains how we collect, use, and protect your data in accordance with data protection laws, including the General Data Protection Regulation (GDPR).

This privacy notice supplements other notices we may provide during specific data collection activities and is not intended to override them.

Data Controller Contact Details

Harrington Starr Limited is the primary data controller for your personal data. However, depending on the service provided, the relevant company within the Group may act as the data controller.

For questions regarding this privacy policy, please contact: GDPR Team
Email: gdpr@harringtonstarr.com

What Data We Collect

We may collect, use, store, and transfer various types of personal data, including but not limited to:

• Identity Data: Such as name, title, and date of birth.
• Contact Data: Such as address, email address, phone number.
• Work Data: Such as CVs, employment history, qualifications, and references.
• Technical Data: Such as IP address, browser type, location data, and other technology data collected through cookies.
• Marketing and Communications Data: Such as preferences for receiving marketing and communications from us.

The specific types of data collected may vary depending on the information provided to us by candidates and clients. We do not collect special categories of personal data (e.g., health, ethnicity) unless required by law.

How We Collect Your Data

We collect personal data through the following methods:

• Direct Interactions: Via job applications, online forms, or email correspondence.
• Automated Technologies: Through cookies and analytics tools when you visit our website.
• Third Parties: Social media profiles, recruitment platforms, or publicly available sources.

How We Use Your Data

We use your data for the following purposes and rely on specific legal bases for processing:

• Candidate Management: Reviewing CVs, arranging interviews, background screening, and/or compliance checks as required (legal basis: legitimate interest; contractual necessity)
• Marketing Communications: Sending newsletters, event invitations (legal basis: consent, when required).
• Technical Improvements: Analysing website performance (legal basis: legitimate interest).
• Legal and Regulatory Compliance: Record-keeping, reporting obligations (legal basis: legal obligation).

Call Recording

We use a phone and text messaging service provider to manage communications. Calls and text messages conducted through this service may be recorded and stored for training, quality assurance, and regulatory compliance purposes. You will be notified at the start of any recorded call.

Text Messaging Policy

No mobile information will be shared with third parties/affiliates for marketing/promotional purposes. All the stated categories in this privacy policy exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties. End users can opt out of receiving further messages by replying STOP or ask for more information by replying HELP. Message frequency varies. Message and data rates may apply.

Data Sharing

We may share your personal data:

• Within the Group, to facilitate business operations and recruitment processes.
• With third-party service providers, such as IT support and marketing platforms. We ensure these third parties are bound by data protection, intellectual property, and confidentiality agreements to protect your data. Additional details can be provided upon request.
• If legally required, with regulatory authorities or law enforcement.

International Data Transfers

If we transfer your data outside the European Economic Area (EEA), we ensure appropriate safeguards, such as Standard Contractual Clauses, are in place to protect your data.

Data Retention

We retain personal data only as long as necessary for the purposes outlined in this policy or to comply with legal, tax, or regulatory requirements. 

Your Legal Rights

Under GDPR, you have the following rights:

• Access: Request access to your personal data.
• Correction: Have incorrect or incomplete data rectified.
• Erasure: Request deletion of your data (subject to legal limitations).
• Objection: Object to processing based on legitimate interests.
• Data Portability: Request a copy of your data in a commonly used format.
• Withdraw Consent: Withdraw consent for marketing or other purposes where consent is the basis for processing.

To exercise these rights, contact our GDPR Team at gdpr@harringtonstarr.com.

Security Measures

We have implemented appropriate technical and organisational measures to secure your data, including encryption, firewalls, and restricted access protocols. Despite these measures, no data transmission or storage system is guaranteed to be 100% secure.

Third-Party Links

Our website may include links to third-party websites. We are not responsible for their privacy practices, and we encourage you to review their privacy policies.

Updates to This Policy

We regularly review and update this privacy policy to reflect changes in our practices or legal requirements. We encourage you to review this policy periodically.

Contact Us

For any questions or concerns about this privacy policy or your personal data, please contact our GDPR Team at gdpr@harringtonstarr.com.