Client Privacy Notice
Last Updated: February 2022
RECREF takes its obligations, as set out in the UK General Data Protection Regulations (GDPR) very seriously. It sets out the principles and requirements that should be followed when processing personal data.
For the purposes of the contract between you, the client, and us, Paragon Scheme Management Services Ltd, T/A RECREF, RECREF is the data controller.
You the client are the data controller in respect of your contract with the candidates for whom you use our services.
When processing candidate´s personal data, RECREF is the data processor.
Contacting RECREF about your data privacy, whether you are a client or a supplier of RECREF, should be via your usual contact with us in the first instance.
If you are not satisfied with the response you receive, you can write to us at Our registered offices:
RECREF, 4-5 Quay Point, Northarbour Road, Cosham, Portsmouth, PO6 3TD.
If you wish to escalate something which you do not believe has been handled appropriately, you can contact the data protection officer at the above address.
You do have the right to lodge a complaint if in the unlikelihood you are still not satisfied, to the Information Commissioners Office (ICO) the UK data regulator. Please visit the ICO's website for more details.
Supply of Data
As a client, supplier or business contact, we use a secure online portal (CRM System) to collect data relevant to us providing services to you which will include:
Name of contact and their job title.
Contact details including email, landline and mobile numbers.
In addition, our online portal may collect data from emails sent by you such as the senders and/or organisers name if it is a meeting and could include names and contact details of 3rd parties included in the correspondence.
Data relating to our clients, suppliers and business contacts may be visible to our own employees to learn more about you our client or supplier and could be used for the following purposes, for example:
Administration and management of your account.
Performing analysis and intelligence gathering about what services are being used more commonly, for example buying patterns and response times.
Providing information about our products and services.
We do not sell or release your data contained on our portal to 3rd parties for the purposes of allowing them to market to you without your consent.
Purposes and Legitimate, Lawful Basis of Processing Data
Under the current legislation, the purposes of processing personal data must only be carried out if we have a proper reason to do so. This includes sharing the information outside of RECREF such as with a referee, the candidates or 3rd party suppliers such as a credit referencing agency.
The legislation says we need one or more of these reasons:
To fulfil our contract with you
When it is in our legitimate business interest
If it is our legal duty to do
Or when you consent to it
The data we collect, and hold is very seriously considered. We have robust policies and procedures in place covering UK GDPR, confidentiality and security, which is reviewed on a regular basis to ensure processes and systems are appropriate and continue to comply.
All data collected and stored is held in secure UK data centres via Hostek Ltd.
Physical security: there is limited access and RECREF are committed to ensuring the safety of the data and its security. All measures are compliant with current legislation.
Our website may contain links to other websites of interest. It is important to note however, if you navigate to one of these sites that we have no control over that site, and therefore are not responsible for the protection and privacy of any information you share with them. Please exercise caution.
We have strict security measures in place within our offices and with access and control which is limited to authorised personnel only.
- Cookies are small files that a site or its service provider transfers to your computer's hard drive through your web browser (if you allow) that enables the sites or service provider's systems to recognise your browser and capture and remember certain information.
- If you prefer, you can choose to have your computer warn you each time a cookie is being sent, or you can choose to turn off all cookies via your browser settings. Like most websites, if you turn your cookies off, some of our services may not function properly.
We will retain accounts details of our clients for a period of 6 years in line with current legislation.
We will retain candidate's details for 14 months following the services requested by you, being completed where upon they will be deleted securely.
Access to Data
You have the right to access your data that we hold as the data controller. You may request the data at any time, and we will respond in a timely manner, but always within the legislated time frame.
Any data you supply to us with regards to your account, you will be able to amend by accessing the online portal via your secure log in, such as staff changes, email addresses, contact numbers etc.
Candidate Privacy Statement v1
Last Updated: August 2019
1. Who we are
RECREF is a trading name of Paragon Scheme Management Service Ltd.
RECREF is contracted to provide reference assessments for prospective candidates and existing employees on behalf of its clients.
Please note that in line with UK GDPR Legislation RECREF is the data processor and the client is the data controllers
2. How do the Services work?
RECREF only acts upon the requests from the client. The client will select the levels of checks they require to be carried out on a candidate.
If you require more information on what data is to be collected and why please contact your employer/prospective employer.
Our service is delivered by a secure online portal whereby the candidate will complete a form (after being sent a link with a unique password by the client) with all the appropriate consents.
3. On what basis do you process my personal data?
At the start of the referencing process you will be provided with a secure remote access link to the form which requires completion.
This will provide you with all the information to equip you to consent and ensure you are fully informed.
If you have any questions about this service, please revert to your employer/ prospective employer.
You have the right to withdraw consent at any time. This must be done directly with the client (i.e. your employer/ prospective employer).
4. What personal data do we collect and process?
So that RECREF can supply the services to the client, we must collect your personal data.
Please see Example 1 below of the type of data we will collect which could include:
|Type of personal data:
||Reason for collecting:
|Name (and former names including any changed by deed poll)
||We ask for your name as it appears on your official documents. We also require any other names you are known by, for example family surname before marriage, change by deed poll etc.
|Date of Birth
||As recorded on official documents.
||Telephone numbers and email address should RECREF need to contact you through this process. Your details are deleted subject to our retention policy.
||Depending upon the service selected by the client the online form will ask for as many addresses as that service requires.
||Depending upon the service and industry for which you are being considered it may be that you will be required to provide a longer employment history. The form will ask for the appropriate level of information intuitively.
||If selected, this service checks your academic achievements and, in most cases, up to the highest level of education.
||Referees enable us to validate your employment history.
||Some services that RECREF provide to their clients may require supporting documents such as passport/visa/qualification certificate etc.
The form will guide you if such a service has been selected and you will be asked to upload the appropriate ones.
Yes, cookies are small files that a site or its service provider transfers to your computer's hard drive through your web browser (if you allow) that enables the sites or service providers systems to recognise your browser and capture and remember certain information.
If you prefer, you can choose to have your computer warn you each time a cookie is being sent, or you can choose to turn off all cookies via your browser settings. Like most websites, if you turn your cookies off, some of our services may not function properly. However, you can still enquire over the telephone or by contacting our client liaison department.
6. When does RECREF transfer data?
RECREF will transfer data to their clients once the assessment has been completed.
It may be necessary to transfer your data outside of the EEA for the purposes of validating your employment and education history for example, if you have previously resided abroad.
Each of the RECREF's clients have secure access via a unique account and login.
They can access the reports online but may choose to download these for their records.
For information about how your records are held with the employer / prospective employer, please refer to them directly.
RECREF do use third party services who provide credit and anti-money laundering searches. Other sources could include DVLA, FCA and DBS checks, if these services are requested by our clients.
7. How do we ensure your personal data is safe?
RECREF's robust processes and procedures mitigate the risk of loss of data or unauthorised access for example, all access is authorised only with unique passwords and is limited.
Physical security: there is limited access and RECREF are committed to ensuring the safety of data and its security. All measures deployed are compliant with current legislation.
8. Does RECREF operate any automated decision making?
RECREF does not make any decisions as to the suitability of a candidate. That decision is the responsibility of our client once furnished with all the data collected.
9. Does RECREF use personal data for any reason other than the provision of the Services?
RECREF will only use your data for the purposes for which it was processed. We retain the data for a period of 14 months following completion of the assessment after which it is deleted.
10. How long is personal data retained for?
RECREF retains the records for 14 months upon completion of the assessment after which it is irretrievably deleted securely.
11. Exercising your privacy rights under current legislation.
Regarding the service RECREF provides to our client, you do have a number of rights with regards to the data collected and processed, such as access erasure etc.
Your rights are executable against the data controller i.e. Our client (the employer/prospective employer).
12. How can I withdraw my consent for RECREF to process my personal data?
Withdrawal of consent must be made to our client directly. Once instructed by them we shall cease processing your personal data or a component part of that data if applicable.
13. How do I make a complaint?
RECREF takes complaints very seriously. If you have a reason to raise a complaint this should be raised with our client liaison department to email@example.com.
If you are not satisfied with the response you have received, you can escalate this to the data controller at RECREF. The address is 4-5 Quay Point, Northarbour Road, Cosham, PO6 3TD.
If your complaint concerns one of our 3rd party suppliers, please contact us and we will direct you to the appropriate organisation.