Privacy Policy
This Privacy Policy explains how Trusty Scouts, a trading name of Goea Ltd ("we", "us", "our"), collects, uses, stores, and protects your personal information. We are committed to protecting your privacy and complying with data protection laws including the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.
1. Who We Are
Data Controller: Goea Ltd, trading as Trusty Scouts
Registered Address: 273 Park Street, Luton, LU1 3HH, United Kingdom
Contact Email: support@trustyscouts.com
As a data controller, we are responsible for deciding how we hold and use personal information about you.
2. Information We Collect
2.1 From Job Seekers and Candidates
We may collect and process the following personal information:
Identity and Contact Information:
- Full name
- Email address
- Phone number
- Home address
- Date of birth
- Nationality
Professional Information:
- CV/resume
- Employment history
- Educational qualifications
- Professional certifications and licenses
- Skills and competencies
- Salary expectations and history
- References
- LinkedIn profile and other professional social media
Right to Work Information:
- Passport or ID documentation
- Visa status and work permits
- National Insurance number (where necessary)
Other Information:
- Interview notes and assessments
- Correspondence with you
- Preferences regarding job types, locations, and working arrangements
2.2 From Client Companies
We collect:
- Company name and registration details
- Contact names, email addresses, and phone numbers
- Job descriptions and requirements
- Hiring decisions and feedback
- Payment and billing information
- Correspondence and communications
2.3 From Website Visitors
When you visit our website, we may automatically collect:
- IP address
- Browser type and version
- Operating system
- Pages visited and time spent on pages
- Referring website
- Location data (country/city level)
2.4 Special Category Data
We do not routinely collect special category (sensitive) personal data such as information about race, ethnicity, religion, health, or sexual orientation. If we do collect such data (for example, to support diversity initiatives or reasonable adjustments), we will:
- Only collect it with your explicit consent
- Explain why we need it
- Handle it with extra care and security
3. How We Collect Your Information
We collect information through:
- Direct provision: When you submit your CV, create an account, fill in forms, or communicate with us
- Third-party platforms: Job boards, LinkedIn, professional networking sites
- Referrals: From other candidates, clients, or professional contacts (with appropriate permissions)
- Public sources: Publicly available information from LinkedIn, company websites, or professional directories
- Client submissions: When employers share your information as part of an application process
- Cookies and tracking: Automatically through our website (see Section 10)
4. How We Use Your Information
4.1 Legal Bases for Processing
We process your personal data on the following legal bases:
Legitimate Interests: To operate our recruitment business, match candidates with opportunities, and provide services to clients
Contractual Necessity: To fulfill our obligations under contracts with candidates and clients
Legal Obligation: To comply with employment law, tax requirements, and right-to-work checks
Consent: Where you have given specific permission (you can withdraw consent at any time)
4.2 Purposes of Processing
We use your information to:
For Candidates:
- Match you with suitable job opportunities
- Submit your details to potential employers
- Arrange and coordinate interviews
- Provide career advice and guidance
- Verify your identity and qualifications
- Maintain our candidate database
- Send relevant job alerts and opportunities
- Process references and background checks
- Manage the recruitment process end-to-end
For Clients:
- Provide recruitment services
- Match candidates to job specifications
- Manage the hiring process
- Provide access to our Platform
- Process payments and invoices
- Communicate about services and placements
General Business Purposes:
- Improve our services and Platform
- Conduct market research and analysis
- Comply with legal and regulatory requirements
- Prevent fraud and ensure security
- Resolve disputes and enforce our Terms
- Send service updates and important notices
4.3 Marketing Communications
With your consent, we may send you:
- Job alerts and opportunities
- Industry news and insights
- Career advice and tips
- Company updates and blog articles
You can opt out of marketing communications at any time by:
- Clicking "unsubscribe" in any email
- Contacting us at support@trustyscouts.com
- Updating your preferences in your Platform account
Note: Opting out of marketing does not stop essential service communications (e.g., job application updates, interview confirmations).
5. Who We Share Your Information With
5.1 Candidate Information Sharing
We share candidate information with:
Client Companies: When submitting you for roles, we share your CV and relevant details with potential employers. We will always seek your permission before submitting you to a specific role.
Third-Party Service Providers:
- Background check and reference verification services
- CV parsing and candidate management systems
- Email and communication platforms
- Cloud storage providers
- Payment processors
Professional Advisors: Lawyers, accountants, auditors (where necessary)
Legal Requirements: Law enforcement, regulators, or government bodies when legally required
5.2 Data Sharing Safeguards
When we share your data:
- We only share what is necessary for the specific purpose
- We require recipients to protect your data and use it only for agreed purposes
- We use contracts and agreements to enforce data protection standards
- We do not sell your personal data to third parties
5.3 International Transfers
Your data is primarily stored and processed within the United Kingdom. If we transfer data outside the UK or EEA, we ensure:
- The country has adequate data protection laws, OR
- We use Standard Contractual Clauses approved by the UK government, OR
- We obtain your explicit consent
6. How Long We Keep Your Information
6.1 Retention Periods
Active Candidates: We retain your data while you are actively seeking opportunities through us, plus up to 3 years after your last interaction with us.
Placed Candidates: We retain data related to successful placements for up to 7 years to comply with tax and employment law requirements.
Client Data: We retain client information for the duration of the business relationship plus up to 7 years for legal and accounting purposes.
Website Visitors: Analytics data is retained for up to 26 months.
6.2 Why We Keep Data
We retain data to:
- Maintain our recruitment database
- Contact you about future opportunities
- Comply with legal obligations (tax, employment law)
- Defend legal claims within limitation periods
- Honor our guarantee obligations to clients
6.3 Deletion and Anonymization
After retention periods expire, we will:
- Securely delete your personal data, OR
- Anonymize it so you can no longer be identified
You can request early deletion by contacting us (see Your Rights below).
7. Your Rights
Under UK GDPR, you have the following rights:
7.1 Right of Access
You can request a copy of the personal data we hold about you (known as a Subject Access Request).
7.2 Right to Rectification
You can ask us to correct inaccurate or incomplete information.
7.3 Right to Erasure ("Right to be Forgotten")
You can ask us to delete your personal data in certain circumstances, such as:
- You withdraw consent and we have no other legal basis to process
- The data is no longer necessary for the purpose collected
- You object to processing and we have no overriding legitimate interest
Note: We may not be able to delete data if we have legal obligations to retain it (e.g., accounting records, placed candidate information).
7.4 Right to Restriction
You can ask us to restrict processing of your data in certain situations (e.g., while we verify accuracy or assess legal claims).
7.5 Right to Data Portability
You can request your data in a structured, commonly used format to transfer to another service.
7.6 Right to Object
You can object to processing based on legitimate interests or for direct marketing purposes.
7.7 Rights Related to Automated Decision-Making
We use AI-assisted CV screening, but no automated decisions are made about you without human oversight. You have the right to request human review of any automated assessment.
7.8 How to Exercise Your Rights
To exercise any of these rights, contact us at: support@trustyscouts.com
We will respond within one month (this may be extended by two months for complex requests).
You also have the right to complain to the UK Information Commissioner's Office (ICO) if you believe we have not handled your data properly. Visit ico.org.uk for more information.
8. How We Protect Your Information
8.1 Security Measures
We implement appropriate technical and organizational measures including:
- Encryption of data in transit and at rest
- Secure access controls and authentication
- Regular security assessments and updates
- Staff training on data protection
- Secure backup and disaster recovery procedures
- Confidentiality agreements with staff and partners
8.2 Data Breach Response
In the unlikely event of a data breach that poses a risk to your rights and freedoms, we will:
- Notify the ICO within 72 hours
- Notify affected individuals without undue delay
- Take steps to mitigate the breach
- Investigate and prevent future incidents
9. Third-Party Links
Our website may contain links to third-party websites (e.g., job boards, client websites, LinkedIn). We are not responsible for the privacy practices of these sites. Please review their privacy policies before providing personal information.
10. Cookies and Tracking Technologies
10.1 What Are Cookies
Cookies are small text files stored on your device when you visit our website. They help us improve your experience and understand how you use our site.
10.2 Types of Cookies We Use
Essential Cookies: Necessary for the website to function (e.g., login sessions, security)
Performance Cookies: Help us understand how visitors use our site (e.g., Google Analytics)
Functionality Cookies: Remember your preferences and settings
Marketing Cookies: Track visits across websites to deliver relevant advertising (used only with your consent)
10.3 Managing Cookies
You can control cookies through:
- Your browser settings (most browsers allow you to block or delete cookies)
- Opting out of Google Analytics: tools.google.com/dlpage/gaoptout
Note: Blocking cookies may affect website functionality.
11. Children's Privacy
Our services are not directed at children under 16. We do not knowingly collect personal data from children. If we become aware that we have collected data from a child without parental consent, we will delete it promptly.
12. Changes to This Privacy Policy
We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors.
When we make material changes, we will:
- Update the "Last Updated" date at the top of this policy
- Notify active users via email or Platform notification
Continued use of our services after changes indicates your acceptance of the updated policy.
13. Contact Us
For questions, concerns, or requests regarding this Privacy Policy or your personal data, please contact us:
Email: support@trustyscouts.com
Address: Goea Ltd, 273 Park Street, Luton, LU1 3HH, United Kingdom
We aim to respond to all inquiries within 2 business days.
14. Supervisory Authority
If you have concerns about how we handle your personal data, you have the right to lodge a complaint with the UK's supervisory authority:
Information Commissioner's Office (ICO)
Wycliffe House
Water Lane
Wilmslow
Cheshire SK9 5AF
Website: ico.org.uk
Helpline: 0303 123 1113
By using Trusty Scouts' services, you acknowledge that you have read and understood this Privacy Policy and consent to the collection, use, and disclosure of your personal information as described herein.