Candidate Privacy Policy
Last updated: October 31, 2025
This Privacy Policy describes Our policies and procedures on the collection, use and disclosure of Your information when You use the Service and tells You about Your privacy rights and how the law protects You.
We are a recruiting/staffing agency company. This Privacy Policy applies to our candidates, other people we may have contact with to find out more about our candidates or whose details have been provided in the event of an emergency, our clients and our suppliers.
We use Your Personal data to provide and improve the Service. By using the Service, You agree to the collection and use of information in accordance with this Privacy Policy.
Interpretation and Definitions
The words of which the initial letter is capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.
Definitions
For the purposes of this Privacy Policy:
- Account means a unique account created for You to access our Service or parts of our Service.
- Company (referred to as either “the Company”, “We”, “Us” or “Our” in this Agreement) refers to The Computer Merchant, Ltd. 95 Longwater Circle. Norwell, MA. 02061.
- Cookies are small files that are placed on Your computer, mobile device or any other device by a website, containing the details of Your browsing history on that website among its many uses
- Country refers to: Massachusetts, United States
- Device means any device that can access the Service such as a computer, a cellphone or a digital tablet
- Personal Data is any information that relates to an identified or identifiable individual
- Service refers to the placement of a candidate on a client assignment by the Company
- Service Provider means any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Service, to provide the Service on behalf of the Company, to perform services related to the Service or to assist the Company in analyzing how the Service is implemented and managed
- Usage Data refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the type, location and duration of an assignment)
- Website refers to any of the The Computer Merchant, LTD. online tools such as websites related to the Service
- You means the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable.
Data Protection Principles
We will comply with data protection legislation. This says that the personal information we hold about you must be:
- Used lawfully, fairly and in a transparent way.
- Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
- Relevant to the purposes we have told you about and limited only to those purposes.
- Accurate and kept up to date.
- Kept only as long as necessary for the purposes we have told you about.
- Kept securely.
The Information We Hold and How We Collect It
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
There are “special categories” of more sensitive personal data which require a higher level of protection. We only hold this type of data in relation to candidates.
We will collect, store, and use the categories of personal information set out below. The lists are not intended to be exhaustive and not every category of information will apply to you:
Candidate Data
- Name
- Title
- Address
- Email address
- Telephone number
- Age/date of birth
- Birth certificate
- Proof of name change
- Sex/gender
- Marital status
- Education details
- Resume/work history
- Job preferences including role, geographical areas, and salary
- Any other work-related information you provide, for example, education or training
- Proof of qualifications or training
- Industry registration
- Emergency contacts and details of any dependents
- Referrer details
- A copy of your passport/identity card
- Permits and visas
- Immigration status
- Nationality/citizenship/place of birth
- A copy of your driving license
- National insurance number/Social Security Number
- Full details of job offers and placements
- Background checks
- Drug screening results
- Education verifications
- Employment history verifications
- Diversity information including racial or ethnic origin, religion or similar beliefs, physical or mental health including disability related information
- Medical information
- References
- Details of current remuneration package and benefits
- Self-employed/business credit details
- Information in relation to your limited company including certificate of incorporation, insurance policy, VAT certificate, and tax registration documents
- Any extra information you tell us, your references tell us, our clients tell us, or from third-party sources such as job board
- A log of our communications with you by email and telephone
This information will have been collected by us in the following ways:
- Provided by you directly through our website, application forms or registration process
- Provided by a third party who we work with such as a job board company or another recruiting company or our clients or referral
- Other third-party searches such as LinkedIn and other job sites
- If you like or follow our social media pages, we will receive information from these sites
- Your references will be provided by your previous employers or other named referrers
- Medical information may be supplied by your doctor, consultant or occupational health
- Background checks, where relevant, will be supplied by the external investigator companies
Other Personal Data Received from Candidates
In order to provide services as a recruiting company and progress opportunities for individuals, we will also be provided with personal data about individuals by candidates. This includes but is not limited to referrer details and emergency contact details. The information held will be limited to contact details such as name, address, email address and telephone number.
Client Data
The information we hold in relation to clients is to enable us to provide our services to them as a recruiting company. This data will be limited and will include:
- Name
- Telephone number
- Email address
- Information about the business
This information is usually provided by:
- The individuals themselves
- By third parties e.g. candidates
- From market research
Supplier Data
The information we hold in return to suppliers is to enable them to provide services to us. This data will be limited and will include:
- Name
- Telephone number
- Email address
This information is usually provided by:
- The individuals themselves
- By third parties
How and Why We Use Your Personal Data
We will only use your personal information where the law allows us to. The tables below explain what we process your data for and the legal basis for this.
Candidates
Most commonly we will use your personal information in the following circumstances:
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override these interests, i.e. providing you with our service.
- Where we need to comply with a legal obligation.
- Where you have given consent.
“Special Categories” of particularly sensitive data require higher levels of protection. For the purpose of this Notice, this includes criminal convictions. We need to have further justifications for processing this type of data. We may process this type of data in the following circumstances:
- With your explicit written consent.
- Where we need to carry out our obligation or exercise rights in connection with employment law.
- Where it is needed in the public interests such as equal opportunity monitoring.
Less commonly we may process this information where it is needed in relation to legal claims.
| What We Use Your Personal Data For | Legal Basis |
| Collecting your data from you and other sources | For our legitimate interests, i.e. providing you with our services |
| Storing your details on our database | For our legitimate interests, i.e. providing you with our services |
| Providing you with our recruiting services and to facilitate the placement process | For our legitimate interests, i.e. providing you with our services |
| To match your skill sets with job openings | For our legitimate interests, i.e. providing you with our services |
| To put forward your qualifications to our clients and prospective employers for you to be considered for job openings | For our legitimate interests, i.e. providing you with our services |
| To place you with our clients and prospective employers | For our legitimate interests, i.e. providing you with our services |
| To keep you informed of available opportunities as they arise | For our legitimate interests, i.e. providing you with our services |
| Checking you are legally entitled to work in the US | To comply with our legal obligations |
| To put in place contractual arrangements and documentation once a role has been secured | To comply with our legal obligations |
| For the performance of our contract with your company | To comply with our legal obligations |
| To undertake background checks | To comply with our legal obligations in connection with employment law and/or with your explicit consent |
| To deal with any medical and health and safety issues arising in relation to certain positions | To comply with our legal obligations in connection with employment law and/or with your explicit consent |
| Equal opportunities monitoring and compliance with discrimination law | To comply with our legal obligations (or in public interest) |
| To help us establish to exercise, establish or defend legal claims (this could involve personal data and special data) | Our legitimate interests i.e. defending a claim and as it is necessary for dealing with claims |
| Sending AI-generated emails, calls, and text messages | For our legitimate interests, i.e. providing you with information about our services and providing information about job opportunities |
| For business transfers: We may use Your information to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by Us about our Service users is among the assets transferred | For our legitimate interest |
Other Personal Data Received from Candidates
| What We Use Your Personal Data For | Legal Basis |
| To contact individuals in an emergency | For our legitimate interests i.e. to ensure an emergency situation is properly managed |
| To obtain references | For our legitimate interest – to ensure we offer a good service to our clients to check credentials |
| For business transfers: We may use Your information to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by Us about our Service users is among the assets transferred | For our legitimate interest |
Clients
| What We Use Your Personal Data For | Legal Basis |
| To enable us to contact our clients | For our legitimate interest – to enable us to offer our services to clients |
| To obtain references | For our legitimate interest – to ensure we offer a good service to our clients to check credentials |
| For business transfers: We may use Your information to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by Us about our Service users is among the assets transferred | For our legitimate interest |
Suppliers
| What We Use Your Personal Data For | Legal Basis |
| To enable us to contact our suppliers | For our legitimate interest – to allow our suppliers to provide a service to us |
| For business transfers: We may use Your information to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by Us about our Service users is among the assets transferred | For our legitimate interest |
How We Hold this Information
All the personal data we have is stored on our database and in our encrypted cloud-based server. This will also include emails if personal data was received via this method.
Data Sharing
We will only share your personal information where it is required by law, where it is necessary to administer the working relationship with you, where we have another legitimate business interest or we have your consent. Any third parties who may ever receive data are bound by all data protection laws and obligations.
Candidates
We may share your information with the following third parties:
- Prospective employers and our clients with your consent to secure a placement and if you are successful to enable the placement to proceed.
- Tax authorities for tax reasons.
- Pension providers to facilitate access to the program.
- External companies for the purpose of undertaking background checks, where required by law or where your consent has been obtained.
- External companies for the purpose of paying you.
- To previous employers or other nominated referrers for the purpose of obtaining a reference.
- To legal advisors to establish, exercise or defend legal claims.
- To a new owner of the business should we merge or be acquired by another business.
- Service Providers, if any, who perform functions on our behalf, including lawyers and IT support
Personal Data Provided by Candidates
Referenced personal data will be shared with Service Providers and clients we provide services to.
Client Data
Client data will be shared with any company within the Group, service providers, clients we provide services to and candidates.
Suppliers’ Data
Suppliers’ data will be shared with service providers, candidates, and clients.
Data Security
We have put in place measures to protect the security of your information. Details of these measures are available on our company websites.
Third parties will only process your personal information or contact you based on our instructions and where they have agreed to treat the information confidentially and to keep it secure. Information obtained will not be shared with third parties/affiliates for marketing or promotional purposes.
We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality. Details of these measures can be found in the security policies.
We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.
Data Retention
We will only retain your personal information for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. Details of retention periods are available in our retention policy which is available from the company website. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
For candidates where you are not in an active engagement, we will seek your consent to continue to hold your data every six (6) years. After this period, it is likely that your data will no longer be relevant and it will be deleted subject to any legal requirements we have to hold your data.
In some circumstances, we may anonymize your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you. Once you are no longer a contractor of the company we will retain and securely destroy your personal information in accordance with our data retention policy.
Rights of Access, Correction, Erasure, and Restriction
Your Duty to Inform Us of Changes
It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your working relationship with us.
Your Rights in Connection with Personal Information
Under certain circumstances, by law, you have the right to:
- Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
- Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
- Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us to continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
- Object to processing your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.
- Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example, if you want us to establish its accuracy or the reason for processing it.
- Request the transfer of your personal information to another party.
If you want to review, verify, correct or request the erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact contact@ITStaffing.com in writing. We are in compliance with CCPA and Virginia Consumer Data Protection Act obligations. If you are a resident of either Virginia or California, please inform us of your wanting to exercise your rights to access, correct, delete or obtain a copy of your personal data.
No Fee Usually Required
You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.
What We May Need from You
We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.
How to Exercise Your Rights
In the limited circumstances where you may have provided your consent to the collection, processing, and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact contact@ITStaffing.com or click Privacy Request. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.
California “Shine the Light” Law
California Civil Code Section §1798.83 permits California users to request information regarding the disclosure of their personal information to third parties for direct marketing purposes. We do not share personal information with third parties for their own direct marketing use without your consent.
Changes to this Privacy Notice
We reserve the right to update this privacy notice at any time, and we will provide you with a new privacy notice when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal information.
Contact Us
If you have any questions about this Privacy Policy, You can contact us by email at contact@ITStaffing.com
