Privacy Policies

Change Mechanics

Great People for Less Money

Change Mechanics Limited

PRIVACY NOTICE

This privacy notice was last updated on 23 December 2021 and is provided by Change Mechanics Limited (“Change Mechanics”) to keep you informed regarding your privacy rights, how we look after your personal data and other legal protections.

Change Mechanics respects your privacy and is committed to protecting your personal data.

It is important that you read this together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This notice also does not form part of any contract of services.

We reserve the right to update this privacy notice when required and it is effective on the date on which it is uploaded to this website. We may also notify you in other ways from time to time about the processing of your personal data.

1. INTRODUCTION

For the purposes of data protection law, Change Mechanics is the controller of your personal data. This means that we are responsible for deciding how we hold and use personal data about you.

“Clients” means an actual or potential individual or entity in respect of which Change Mechanics sources (or seeks to source) one or more Consultant(s).

“Consultant” means an actual or potential individual or entity in respect of which Change Mechanics finds (or seeks to find) engagement (whether as a contractor, employee or otherwise) with a Client.

This privacy notice describes how we collect and use personal data about you during and after your relationship with us, in accordance with applicable data protection law. This will range from casual visitors to this website, to our business contacts, Clients, Consultants, professional advisors, suppliers, and other parties with whom we conduct business and any associated individuals.

We will not knowingly collect any data relating to children and this website and our services generally are not intended for use by children.

Any links included on the website or provided by us elsewhere may link third-party websites, plugins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third parties and are not responsible for their privacy statements. We encourage you to read the privacy notice provided by a third party or included on a third party website you visit.

Change Mechanics is not obliged to have a Data Protection Officer. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact us by email at enquiries@change-mechanics.com

2. COLLECTION OF PERSONAL DATA

“Personal data” means any information about a person from which that individual can be identified. Anonymous data, where the person cannot be identified, does not count as personal data.

Sensitive Personal Data – There are more sensitive types of personal data which require a higher level of protection known as ‘special category data’. These include details about your race or ethnicity, trade union membership, religious or philosophical beliefs, sex life, sexual orientation, political opinions, information about your health and genetic and biometric data. We do not collect any special category data about you, except for limited health data to assist in the control of infectious diseases (such as the virus Covid-19) that you voluntarily provide to us.

In the case of Consultants, where appropriate we may also collect information about criminal convictions and other information required for the purposes of Consultant screening and to comply with our legal or regulatory obligations.

Person data may be collected from a number of sources – e.g. email, phone, face-to-face meetings, post, LinkedIn.

3. USE OF PERSONAL DATA

We will only use your personal data when the law allows us to.

Usually, we will use your personal data in the following circumstances (each a lawful basis):

where we need to perform the contract we are about to enter into or have entered into with you;
where it is necessary for our legitimate interests (as further explained in the relevant section applicable to you above) and your interests and fundamental rights do not override those interests; or
where we need to comply with a legal or regulatory obligation.

Generally, we do not rely on consent as a legal basis for processing your personal data. However, in the case of Consultants, your consent to process your personal data will be required for the purposes of onboarding for a particular Client role.

If you do not provide certain information when requested, we may not be able to perform a contract we have entered into with you (such as sourcing and/or matching you with a Client or Consultant), or may be prevented from complying with our legal obligations, such as to perform required or requested Consultant screening.

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.

If we need to use your personal data for an unrelated purpose, we will notify you and explain the legal basis which allows us to do so. We may also process your personal data without your knowledge or consent where this is required or permitted by law.

Please see the relevant section below to see the categories of personal data about you that we collect, store, and use, the purposes of processing and our lawful basis for doing so.

Access to Change Mechanics’ website

You are not required to provide any personal data to access public areas of our website. However, when you visit our website, the server may record your IP address and the date, time and duration of your visit. An IP address is an assigned number, like a telephone number, which allows your computer to communicate over the Internet and is considered personal data under GDPR. This processing is required to allow the website to load and function, which is in our legitimate interests in providing the website to our Clients, Consultants, and business contacts.

Change Mechanics’ Clients

If you have been in contact with a representative of Change Mechanics, for example through emails, phone calls or an in-person meeting, we may collect, use and store limited amounts of personal data relating to you, such as:

your name;
job title;
employer organisation;
financial information;
marketing preferences;
contact details; and
any other personal data included in the communications.

We may collect and store this personal data for the purposes of:

prospecting and business development;
onboarding you as a Client;
organising meetings;
facilitating a contact between you, your Change Mechanics representative and/or Consultant;
maintaining a record of our business contacts;
processing of contracts, invoices and sums due;
maintaining our relationship with you as a Client;
informing you of updates to our privacy policy; and
if appropriate, sending you periodic updates about Change Mechanics’ business, activities and opportunities by email.

You can opt out of receiving updates at any time by contacting us at enquiries@change-mechanics.com

The legal basis for collecting, using and storing this personal data is that such processing is necessary for:

the performance of a contract with you;
to comply with a legal obligation
our legitimate interests in running and promoting our business.

We may, from time to time, share the personal data we hold with companies or individuals which process personal data on Change Mechanics’ behalf, professional advisors, such as accountants, lawyers, or other consultants, Change Mechanics’ auditors, as well as applicable regulators and other governmental agencies anywhere in the world.

Once you are no longer a Client we will not keep any personal data about you for any longer than is necessary for the purposes for which the personal data is processed or for which we are legally required or recommended to retain a copy and may securely destroy it after this point.

Change Mechanics’ professional advisers

If you are an individual associated with a professional advisor of Change Mechanics, we will collect, use and store limited amounts of personal data relating to you, including your name, job title, qualifications, employer or parent organisation and contact details.

We will collect, use and store this personal data for the purposes of administering and maintaining records of services or advice we have received, and for the commissioning of further services.

The legal basis for collecting, using and storing this data that you provide to us is that such processing is necessary for our legitimate interests in running and promoting our business.

The personal data we hold about individuals associated with professional advisers may be shared with companies which process personal data on Change Mechanics’ behalf, professional advisors, such as accountants, lawyers, or other consultants, and applicable regulators and other governmental agencies anywhere in the world.]

Consultants

Change Mechanics may collect personal data about Consultants to prospect for business and perform business development, either directly from Consultants or sometimes from third parties (such as recruitment agencies, former employers, business contacts or Consultant screening organisations). Companies (such as recruitment agencies) which collect and use your personal data, including for the purpose of introducing you as a candidate to Change Mechanics, act as the controller of your personal data for that purpose and so are subject to a separate privacy notice provided by the agencies to you.

The personal data we require in order to onboard you as a Consultant may include personal contact details such as:

name;
title;
addresses;
telephone numbers;
personal email addresses;
date of birth;
gender;
current and expected day rates or salary;
compensation history;
annual leave;
pension and benefits information;
current notice period and other records from previous roles;
actual and preferred start date & location of employment or assignment;
recruitment information (including copies of right to work documentation, references and other information included in a CV or cover letter or as part of the application process); and
visual images and photographs provided for business purposes.

Usually, we will use your personal data to take steps prior to entering a contract with you – e.g. for prospecting and business development.

The legal basis for collecting, using and storing this personal data is that such processing is necessary for:

the performance of a contract with you;
our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests; and/or
where we need to comply with a legal or regulatory obligation.

Once you are no longer a Consultant we will not keep any personal data about you for any longer than is necessary for the purposes for which the personal data is processed or for which we are legally required or recommended to retain a copy and may securely destroy it after this point.

4. DATA SHARING & INTERNATIONAL TRANSFER

Change Mechanics will share your personal data with third parties only where required by law, where it is necessary to administer our relationship with you or where we have another legitimate interest in doing so. This may involve cross border transfers including transfers outside of the UK/EEA.

External third parties may include:

Clients;
Service providers acting as processors on Change Mechanics’ written instructions based both inside and outside the UK/EEA who provide IT and system administration services;
Professional advisers acting as processors on Change Mechanics’ written instructions or controllers responsible for their handling of personal data including lawyers, bankers;
auditors and insurers based both inside and outside the UK/EEA who provide consultancy, banking, legal, insurance and accounting services;
Tax authorities, regulators and other authorities acting as processors on Change Mechanics’ written instructions or controllers responsible for their handling of personal data who require reporting of processing activities in certain circumstances;
Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.

We will work with all third parties to ensure that they respect the security of your personal data and to treat it in accordance with the law. Except where needed for their own direct relationship with you, we do not allow our third-party service providers to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions.

International Transfer

Whenever we transfer your personal data out of the UK/EEA, we ensure a similar degree of protection is afforded to it by implementing at least one of the following safeguards:

We may transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
We use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.
Any data transfer mechanism approved by the European Commission or the UK authorities as appropriate, such as an equivalent to the Privacy Shield or updated Model Contracts approved by the EU Commission or the UK government.

5. DATA SECURITY

Change Mechanics have put in place appropriate measures to protect the security of your personal data and prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to access it. They will only process your personal data on our instructions and they are subject to a duty of confidentiality. Third parties will only process your personal data where they have agreed to treat the personal data confidentially and to keep it secure. 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.

6. RETENTION

Change Mechanics may only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, accounting, or reporting requirements. To decide on the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised 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.

In some circumstances we may anonymise your personal data 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 Client, Consultant, business contact, or professional advisor, with whom Change Mechanics conducts business we may retain and securely destroy your personal data in accordance with our data retention policy.

7. RIGHTS OF THE INDIVIDUAL

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Under certain circumstances, under the GDPR you have the right to:

Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data 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 data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have exercised your right to object to processing (see below).
Object to processing of your personal data 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 data for direct marketing purposes.
Request the restriction of processing of your personal data. This enables you to ask us to suspend the processing of personal data about you, for example if you want us to establish its accuracy or the reason for processing it.
Request the transfer of your personal data to another party.

If you want to review, verify, correct or request erasure of your personal data, object to the processing of your personal data, or request that we transfer a copy of your personal data to another party, please contact us.

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee or refuse to comply with the request, if it is clearly unfounded or excessive.

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 data is not disclosed to any person who has no right to receive it.

In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal data 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 us. 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.