This privacy notice is here to explain how we (Headforwards Solutions Ltd) use and protect any information you give us whilst using our site. We want to ensure that your privacy is protected at all times.
This policy was last updated April 2023.
Whilst using our website, software applications or services, you may provide us your personal information (name, address, email, account details, etc.). We will use this information to administer our website, applications, client databases and marketing material. We will ensure that all personal information supplied is held securely in accordance with the General Data Protection Regulation (EU) 2016/679, as adopted into law of the United Kingdom in the Data Protection Act 2018.
How do we collect information?
Headforwards Solutions Ltd collects information in two possible ways:
When you directly give it to us (“Directly Provided Data”)
When you communicate with us, you may choose to voluntarily give us certain information – for example, by filling in text boxes or completing registration forms. All this information requires a direct action by you at that time in order for us to receive it.
When you give us permission to obtain from other accounts (“User Authorised Data”)
Depending on your settings or the privacy policies for other online services, you may give us permission to obtain information from your account with those other services. For example, this can be via social media or by choosing to send us your location data when accessing our website from your smartphone.
How long do we keep your data for?
Headforwards Solutions Ltd will not retain your personal information for longer than necessary. We will hold onto the information you provide either while your account is in existence, or as needed to be able to provide the Services to you, or (in the case of any contact you may have with our Customer Care team) for as long as is necessary to provide support-related reporting and trend analysis only.
We retain all candidate data for a period of 12 months from the time of application. Your personal information will be deleted on one of the following occurrences:
- Deletion of your personal information by you via the Manage Your Data tool or
- Receipt of a written request by you to us.
If legally required, or if it is reasonably necessary to meet regulatory requirements, resolve disputes, prevent fraud and abuse, or enforce our Terms and Conditions, we may also retain some of your information for a limited period of time as required, even after you have closed your account or it is no longer needed to provide the Services to you.
Information we collect from job applicants
If you apply for a job with Headforwards we will collect and store the following information:
- Your name
- Your email address
- Your phone number
- Your CV
- Preferred pronouns
- Age bracket
- Your nationality/citizenship status
- If you contact us, we may keep a record of that correspondence
- Details of your visits to our careers website including, but not limited to, traffic data, location data and other communication data, the site that referred you to our careers website and the resources that you access
We will only ever use this information to process your job application with us on the legal basis that it may lead to us entering into a contract of employment with you.
We use Pinpoint, an online software product provided by The Infuse Group Ltd (t/a Pinpoint Software), to assist with our recruitment process. We use Pinpoint to process personal information as a data processor on our behalf. Pinpoint is only entitled to process your personal data in accordance with our instructions.
You have the option to receive further emails from us regarding new job opportunities, our news, tech learnings and event invites. If you select no, you will never receive these emails. You can unsubscribe from these emails from us by clicking the “unsubscribe” link at the bottom of any email or by contacting us at any time to request this.
We may contact potential candidates via social media to invite them to apply to a position. In the event that we do this we will record the social media contact information for that candidate. If a potential candidate asks us to stop contacting them in this way we will retain enough information on them to ensure that we do not contact them in the future.
Data from applicants will only be retained for the period necessary for us to conclude the recruitment process, however we may retain certain information such as your name and the result of the recruitment process to refer to in the event that you subsequently apply for another role in the future.
Information we collect from other sources
Pinpoint provides us with the facility to link the data you provide to us with other publicly available information about you that you have published on the Internet – this may include sources such as LinkedIn and other social media profiles.
Pinpoint’s technology enables us to search various databases, which may include your personal data, to find possible candidates to fill our job openings. Where we find you in this way we will obtain your personal data from these sources.
Lawful basis for processing
We rely on legitimate interest as the lawful basis on which we collect and use your personal data. Our legitimate interests are the recruitment of staff for our business.
Purposes of processing
We use information held about you in the following ways:
- To consider your application in respect of a role for which you have applied.
- To consider your application in respect of other roles.
- To communicate with you in respect of the recruitment process.
- To enhance any information that we receive from you with information obtained from third party data providers.
- To find appropriate candidates to fill our job openings.
- To help Pinpoint improve their services.
Automated decision making/profiling
We may leverage Pinpoint’s technology to help us select appropriate candidates for us to consider based on criteria we have identified. The process of finding suitable candidates is automatic, however, any decision as to who we will engage to fill the job opening will be made by our team.
We take appropriate measures to ensure that all personal data is kept secure including security measures to prevent personal data from being accidentally lost, or used or accessed in any unauthorised way. We limit access to your personal data to those who have a genuine business need to view it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted through any online means, therefore any transmission remains at your own risk.
The data that we collect from you and process using Pinpoint’s Services will be transferred to and stored at one of several datacentre locations in Amsterdam (Netherlands) and may be synchronised to one of several datacentre locations in London (United Kingdom) for backup and redundancy purposes. By submitting your personal data, you agree to this transfer, storing or processing.
Data we collect from potential customers
If you fill in the contact form on our website we will collect the following information:
- Your name
- Your email address
- Your message
- Where you heard about us
We will only use this information to respond to your enquiry.
Customer information will be stored within our customer relationship management system on the basis that it is in our legitimate business interest to maintain records of communications with previous, current and potential customers.
This data is hosted by HubSpot, Inc. in the United States. HubSpot, Inc. has certified to the EU-U.S. and Swiss-U.S. Privacy Shield Frameworks as administered by the U.S. Department of Commerce, in order to implement appropriate safeguards for such transfers pursuant to Article 46 of the GDPR.
When you apply for a position or contact via our contact form you will also have the option to receive marketing communications from us. If you select no, you will not be added to our marketing mailing list.
We will periodically send marketing communications to you on the basis that you have given us consent to do so. You can withdraw your consent and unsubscribe from receiving marketing emails from us by clicking the “unsubscribe” link at the bottom of any email. Once you do this, you will no longer receive any marketing emails from us.
When you withdraw your consent for marketing communications we will retain that information about you to ensure that we comply with your wishes.
Data used for email marketing will be stored in Mailchimp. Mailchimp comply with the Privacy Shield Principles for all onward transfers of Personal Information from the EU and Switzerland, including the onward transfer liability provisions.
The controller of your personal data is Headforwards Solutions Ltd. Our registered address is The Engine House, Wheal Kitty, St Agnes. TR5 0RD. Our company registration number is 07576641, company registered in England and Wales.
Data Protection Officer
You can contact our Data Protection Officer by sending an e-mail with the subject line GDPR: DPO to the following address: firstname.lastname@example.org
Headforwards sends sales, commercial and marketing emails using Hubspot.
Our Insights newsletters are sent monthly and include information on our services and insights and content relating to software development.
Contacts are automatically subscribed to our mailing list under legitimate interest. You can unsubscribe at any time from the mailing list at the bottom of all Headforwards newsletters. Please note this does not unsubscribe you from our CRM system and you may still be emailed by our team about your specific enquiry.
Recipients of the personal data
Headforwards manages its newsletter service internally. If at any point this service is outsourced, we may transfer your personal data to third party organisations who will provide this service for, and as directed by Headforwards.
Period of data processing
We will process your personal data until you withdraw your consent to receive newsletter from us or for as long as we will be sending the newsletter. You can unsubscribe from our newsletter at any time via the link at the bottom of all Headforwards newsletters.
Due to the fact that we process your personal data you can at any time:
- request access to your data and to correct any errors in it
- withdraw your consent to the processing of your personal data. Please send an email to email@example.com let us know if you would like us to delete your details
- object to the processing of your personal data, on grounds relating to your particular situation, which causes that you don’t want us to process your personal data due to our legitimate interest
- object to the processing of your personal data for direct marketing purposes
- receive personal data that you provided us with, agreeing for their processing or concluding agreement. You will get these data in a structured, commonly used, machine-readable format and you can send these data to another data controller (right to data portability)
- lodge a complaint with the competent supervisory authority if you think that we are processing your personal data with a violation of applicable regulations.
Necessity to provide personal data
Providing your personal data to Headforwards is voluntary, but necessary to engage our services and/or receive our newsletter.
Users of our website: The scope of data and recipients of any personal data
Our websites collect data about its users and their behaviour through:
- All contact forms on the website, where information is voluntarily provided
- Storing “cookies” on telecommunication end devices
- Collecting logs from web-servers
- Additional tools installed on website that allow to communicate with us or provide additional information on our users
We do not disclose information about our website users to any third parties.
Data provided in the website contact forms
- We collect data voluntarily provided by the users.
- We might collect additional data about your connection (like IP address, time stamp or user agent).
- Data provided in the form might contain client’s personal data. We do not pass this on to any third parties and follow GDPR regulations in how we use and store this data.
- We process the data appropriately to the purpose of given webform (e.g. to exercise service demand, reply to commercial communication or exercise recruitment process)
- Some data may be disclosed to entities that provide services on behalf of and on commission of Headforwards, (among others, to the entities that handle our contact forms, newsletter, e-mail, hosting, technical support, consulting services or auditing services).
Information about cookies
- Cookies record information about your online preferences and allow us to tailor the websites to your interests. Information supplied by cookies can help us to analyse your use of our sites and help us to provide you with a better user experience.
- Cookies are used on our Website to ‘remember’ information so that it can be passed from page to page and to collect website statistics. This statistical data collected may be used to help improve our Website and the services that we offer to you, but it is not used to identify you.
- Some cookies are used to store you session identifier, and if you are logged in, this might allow us for your identification.
- Restricting cookies in your browser’s settings might impact some functionalities on our websites. This might lead to improper functioning of our website on your browser.
- Some cookies might also be used by our partners (e.g. by our partners to display advertisements based on your usage of our website).
We are logging some details on our users’ behaviour. This data is only used for server administration purposes and to make ensure our services are running as efficiently as possible.
Browsed pages are identified through URL addresses.
Additionally, we might log:
- Request and response times
- Any errors that might have occurred while processing HTTP requests 404 errors is a typical example of something we track
- Referrer link (the URL user came from)
- Details of user’s browser (User-Agent)
- IP address
We do not identify particular persons based on that data.