Our policies.
The documents below set out how Prymont Ventures approaches data protection, ethical recruitment and anti-bribery. They are published in good faith and reviewed as the business develops.
GDPR & Data Protection Policy
This policy explains how Prymont Ventures approaches the protection of personal data in its recruitment activities, in line with the UK GDPR and the Data Protection Act 2018.
This policy is intended to outline Prymont Ventures' approach and should be reviewed and adapted to reflect the company's specific operations and legal requirements.
1. Purpose
The purpose of this policy is to set out how Prymont Ventures collects, uses, stores and protects personal data relating to candidates, clients, suppliers and website visitors, and how individuals can exercise their data protection rights.
2. Scope
This policy applies to everyone working for or on behalf of Prymont Ventures, including employees, contractors and consultants, and covers all personal data processed by the company in any format.
3. Our commitment to data protection
Prymont Ventures is committed to processing personal data lawfully, fairly and transparently. We aim to collect only the data we need, keep it accurate and secure, retain it no longer than necessary, and respect the rights of the individuals concerned.
4. Personal data we may collect
Candidate information
- Name, contact details and location
- CV, employment history, education and qualifications
- Right-to-work and identity information where required for a role
- Salary expectations, notice period and availability
- Interview notes, assessment results and client feedback
- References, where provided with your knowledge
- Professional registrations or licences relevant to a role
Client and employer information
- Names, job titles and business contact details of contacts
- Details of vacancies, requirements and recruitment processes
- Contractual, billing and correspondence records
5. How we collect personal data
We may collect personal data directly from you — for example through an application on this website, a CV submission, a telephone conversation or an interview — and from sources such as job boards, professional networking sites, referrals and publicly available information.
6. Why we process personal data
- Recruitment and candidate matching against live vacancies
- Processing CVs and applications, and communicating about them
- Arranging interviews and providing feedback
- Providing recruitment services to our clients
- Keeping records of placements and assignments
- Meeting legal, regulatory and contractual obligations
7. Lawful bases for processing
Depending on the activity, we rely on one or more of the following lawful bases:
- Legitimate interests — operating a recruitment business and matching candidates with relevant opportunities, balanced against your rights and expectations.
- Consent — where you register your CV with us, or where we ask for permission to share your details with a specific client.
- Contract — where processing is necessary to perform a contract with you or a client, or to take steps at your request before entering into one.
- Legal obligation — where we must process data to comply with the law, for example right-to-work or payroll requirements.
Where we rely on consent, you may withdraw it at any time by contacting us at [Privacy Email Address].
8. Recruitment, candidate matching and communication
We use the information in your CV and our records to identify roles that may be suitable and to contact you about them. We aim to make contact relevant rather than frequent, and you can ask us to stop at any time.
9. CV and application processing
When you apply for a vacancy, your details and CV are reviewed against the requirements of that role. We will discuss a role with you before submitting your details to a client and will not send your CV to a client without your agreement.
10. Data sharing
We may share personal data with clients considering your application, with third parties who support the recruitment process (for example reference or background-checking providers where relevant to a role), and with professional advisers, regulators or authorities where we are required to do so. We do not sell personal data.
11. Data processors
We use service providers to host our systems and support our operations, for example website and database hosting, email and document storage. Where a provider processes personal data on our behalf, we put appropriate contractual terms in place requiring them to process it only on our instructions and to keep it secure.
12. International data transfers
Where personal data is transferred outside the UK — for example because a service provider hosts data elsewhere — we take steps to ensure an appropriate level of protection, such as relying on adequacy regulations or appropriate safeguards including standard contractual clauses.
13. Data retention
We keep personal data only for as long as it is needed for the purpose it was collected, or for as long as required by law. Candidate records are reviewed periodically and deleted or anonymised when they are no longer relevant to our recruitment activity. Specific retention periods should be documented and reviewed against the company's actual operations.
14. Data security
We use appropriate technical and organisational measures to protect personal data, including access controls, encrypted connections for data in transit, restricted access to CV and application records, and staff awareness of data protection responsibilities.
15. Your data protection rights
- Right of access — to request a copy of the personal data we hold about you.
- Right to rectification — to have inaccurate or incomplete data corrected.
- Right to erasure — to ask us to delete your data where there is no overriding reason to keep it.
- Right to restrict processing — to ask us to limit how we use your data in certain circumstances.
- Right to object — including to processing based on legitimate interests, and to direct marketing.
- Right to data portability — to receive certain data in a portable format.
To exercise any of these rights, contact [Privacy Email Address]. We will respond within the timescales set out in data protection law.
16. Automated decision-making and profiling
Prymont Ventures does not make decisions about candidates by automated means alone. Where technology is used to help search or sort candidate records, decisions about suitability are always reviewed by a member of our team.
17. Data breach management
We take steps to prevent personal data breaches, and we investigate any suspected breach promptly. Where a breach is likely to result in a risk to individuals' rights and freedoms, we will report it to the Information Commissioner's Office without undue delay and, where required, inform the individuals affected.
18. Cookies and website data
Information about how this website uses cookies and similar technologies is set out in the Cookie Policy below.
19. Complaints
If you are unhappy with how we have handled your personal data, please contact us first at [Privacy Email Address] so that we can try to resolve it. You also have the right to complain to the Information Commissioner's Office (ico.org.uk).
20. Contact details for privacy enquiries
- Privacy Email Address
- [Privacy Email Address]
- Registered Office Address
- [Registered Office Address]
- ICO Registration Number, if applicable
- [ICO Registration Number, if applicable]
- Policy Owner
- [Policy Owner]
21. Policy review
This policy will be reviewed regularly and updated as the business develops. It should be reviewed against Prymont Ventures' actual data-processing activities before publication, and amended to reflect them accurately.
Modern Slavery & Anti-Bribery Policy
This combined policy sets out the Prymont Ventures approach to preventing modern slavery and human trafficking in recruitment and labour supply, and to preventing bribery and corruption in our business dealings.
This policy is intended to outline Prymont Ventures' approach and should be reviewed and adapted to reflect the company's specific operations and legal requirements.
Part A — Modern Slavery
Purpose
To explain our approach to identifying and preventing modern slavery, human trafficking, forced labour and exploitation in our own operations and in the labour supply chains we are part of.
Scope
This part applies to everyone working for or on behalf of Prymont Ventures, and informs how we engage with candidates, clients and suppliers.
Our commitment
Prymont Ventures does not tolerate modern slavery or human trafficking in any form. We are committed to acting ethically in our recruitment activity and to treating every candidate fairly and with respect.
Modern slavery and human trafficking
Modern slavery includes slavery, servitude, forced or compulsory labour and human trafficking. It involves one person depriving another of their liberty in order to exploit them for personal or commercial gain.
Forced labour and exploitation
Recruitment and labour supply carry a recognised risk of exploitation, including workers being charged unlawful fees, having identity documents withheld, being pressured into work or accommodation arrangements, or having wages controlled by a third party. We treat these as serious indicators requiring investigation.
Recruitment practices
- We never charge candidates a fee for finding them work.
- We confirm a candidate's identity and right to work where required for a role.
- We speak to candidates directly rather than through unverified intermediaries.
- We provide clear information about pay, hours and the nature of the work.
Candidate welfare
We aim to ensure candidates understand the terms of any role, know who to contact with concerns, and are never pressured into accepting work that is unsuitable or unsafe.
Supplier and client relationships
We expect the clients and suppliers we work with to share our commitment to ethical labour practices, and we reserve the right to decline or end a relationship where we have credible concerns.
Due diligence
Our due diligence is proportionate to the size of the business and the sectors we recruit for, and includes checks on candidate identity and right to work, awareness of exploitation indicators, and consideration of risk when taking on new clients or suppliers.
Identifying and reporting concerns
Anyone with a concern about modern slavery connected to our activity should report it immediately to [Policy Owner] using the contact details below. Concerns involving immediate risk to a person's safety should be reported to the police, and the Modern Slavery Helpline is available for advice.
Protection from retaliation
Anyone raising a genuine concern in good faith will be supported, and will not face detrimental treatment as a result of doing so — even if the concern turns out to be mistaken.
Training, monitoring and review
Everyone working for Prymont Ventures should understand the indicators of exploitation and how to escalate a concern. This part of the policy is monitored and reviewed as the business and its supply chains develop.
Part B — Anti-Bribery
Purpose
To set out our approach to preventing bribery and corruption, consistent with the principles of the UK Bribery Act 2010.
Scope
This part applies to everyone working for or on behalf of Prymont Ventures, in all dealings with clients, candidates, suppliers and public officials.
What constitutes bribery
Bribery is offering, promising, giving, requesting or accepting a financial or other advantage to induce someone to act improperly, or as a reward for having done so. It is prohibited regardless of whether it is direct or through a third party.
Facilitation payments
We do not make or accept facilitation payments — small payments intended to secure or speed up a routine action — of any kind.
Gifts and hospitality
Reasonable and proportionate business hospitality is acceptable where it is transparent, appropriate to the relationship and not intended to influence a decision. Anything that could reasonably be seen as an inducement should be declined and reported.
Conflicts of interest
Actual or potential conflicts of interest — including personal relationships with a client contact or candidate — must be declared so that they can be managed openly.
Recruitment-related payments
We do not charge candidates fees for finding them work, and we do not make payments to candidates, client contacts or third parties in order to secure a placement or a preferential position.
Client and supplier relationships
Fees, rebates and commercial terms are agreed in writing and recorded. We expect the parties we work with to operate to equivalent standards.
Record keeping and due diligence
We keep accurate records of contracts, invoices, fees and any hospitality given or received, and we consider bribery risk proportionately when engaging new clients, suppliers or introducers.
Reporting concerns and whistleblower protection
Concerns about bribery should be reported to [Policy Owner]. Anyone raising a genuine concern in good faith will be protected from retaliation.
Disciplinary consequences
Breaching this policy may result in disciplinary action, up to and including dismissal, and in the termination of a commercial relationship. Bribery is also a criminal offence.
Training, monitoring and review
Everyone working for Prymont Ventures should be familiar with this policy. It is reviewed periodically and updated to reflect the company's operations and obligations.
- Policy Owner
- [Policy Owner]
- Effective Date
- [Effective Date]
- Review Date
- [Review Date]
- Company Contact Details
- [Company Contact Details]
Privacy Notice
This notice summarises how Prymont Ventures handles personal data collected through this website. It sits alongside, and should be read with, the GDPR & Data Protection Policy above.
What we collect through this website
- Details you submit through a job application, CV registration or contact form
- Any CV or document you choose to upload
- Basic technical information needed to operate and secure the website
How we use it
We use the information you submit to respond to your enquiry, to consider you for relevant vacancies, and to keep a record of our correspondence. We do not sell your data or use it for unrelated purposes.
Your choices
You can ask us at any time to access, correct or delete the information we hold about you, or to stop contacting you, by emailing [Privacy Email Address].
This policy is intended to outline Prymont Ventures' approach and should be reviewed and adapted to reflect the company's specific operations and legal requirements.