Privacy Policy
1. Who we are
Real People Solutions Ltd (“RPS”, “we”, “us” or “our”) is a recruitment agency and employment business. We help individuals find work and help businesses recruit and manage temporary and permanent staff. For the personal information described in this notice, RPS will generally act as a data controller. In some arrangements, a client or service provider may be a separate controller.
Contact: work@rpsrecruitment.co.uk | Post: PO Box 1102, Portsmouth, Hampshire, PO1 9WW. Please put “Privacy enquiry” in the subject line of your message.
2. Who this notice covers
This notice applies to people who use our website, enquire about our services, apply for work, register with us, work through us, represent a client or supplier, or contact us in another business capacity. It should be read alongside any more specific worker or employee privacy information we provide where necessary.
3. Information we collect
Contact and identity details: name, address, telephone number, email address, date of birth and identification documents where required.
Recruitment details: CV, work history, qualifications, licences, skills, availability, preferences, references, interview notes and communications.
Compliance and assignment details: Right to Work evidence, driving or other professional credentials, training, shifts, timesheets, attendance, work performance and relevant incident records.
Pay and employment information where applicable: bank details, National Insurance number, tax and payroll details, pension details, holiday and statutory payment records.
Sensitive information only where needed and lawful: for example health information to arrange reasonable adjustments, equality monitoring information (where provided), or criminal offence information where an appropriate role-specific check is legally justified.
Website and communication details: enquiries, device or browser information, IP address and cookie information where collected through our website or communications systems.
4. Where we obtain information
We collect information directly from you through enquiries, applications, registration forms, interviews, our app, phone calls and emails. Website registration and CV uploads are handled through our Rocket ATS recruitment system. We may also obtain relevant information from job boards, professional networking profiles, referees, clients, training or compliance providers, publicly available sources and other recruitment partners where appropriate. When someone gives us information about another person, we expect them to have authority to do so.
5. How and why we use information
We use personal information only where we have a lawful basis under the UK GDPR. The basis depends on the activity:
Recruitment and matching: assess suitability, discuss vacancies, contact you about relevant roles and introduce you to prospective hirers. Depending on the circumstances, our lawful basis is legitimate interests, steps taken towards a contract, or consent where specifically appropriate. Our legitimate interest is operating an effective recruitment service for candidates and clients.
Assignments and pay: administer bookings, work, timesheets, payment, pension and employment-related arrangements. Our basis is contract and/or legal obligation, as applicable.
Checks and safeguarding: verify identity, Right to Work, licences and eligibility; meet workplace, employment, tax and other legal duties. Our basis is legal obligation and, where applicable, legitimate interests.
Client and supplier relationships: respond to enquiries, provide services, manage accounts, maintain records and resolve disputes. Our basis is contract and/or legitimate interests in running our business.
Security and improvement: protect our systems and people, investigate complaints, prevent misuse and improve our processes. Our basis is legitimate interests and/or legal obligation.
Marketing: send relevant vacancy updates and recruitment news to candidates, and service updates or newsletters to business contacts where permitted by UK GDPR and the Privacy and Electronic Communications Regulations (PECR). For marketing emails or texts to individuals, including candidates and sole traders, we normally require valid consent unless a lawful exception applies. Marketing to corporate business contacts may be based on legitimate interests following an appropriate assessment, with an easy opt-out in every message. Operational messages about applications or assignments are not automatically marketing.
6. Special category and criminal offence information
Where we need health, disability or other special category information, we will identify an additional condition under Article 9 UK GDPR and, where required, the Data Protection Act 2018. This may include meeting employment-law obligations or establishing, exercising or defending legal claims. Where criminal offence information is necessary for a role, we will process it only with an appropriate lawful basis and additional legal condition. We do not ask for sensitive details unless necessary and proportionate.
7. Who we share information with
Where necessary for the purposes above, information may be shared with prospective or current hirers and clients; reference providers; right-to-work, identity, training and compliance providers; recruitment and applicant tracking providers (including Rocket ATS), app, IT and hosting providers; payroll, pensions, banking and invoice finance providers; professional advisers and insurers; and HMRC, regulators, public bodies or law enforcement where required or justified. We share only what is reasonably necessary and use appropriate confidentiality, contractual and security arrangements.
We will not sell your personal information. When approaching a prospective client, we normally share an anonymised candidate profile first. If the client wishes to progress, we may share identifying details or a CV where appropriate for that recruitment opportunity, with the candidate informed and a valid lawful basis. Anonymised profiles must not contain details that could reasonably identify the candidate.
8. International transfers
Some IT, cloud or communications providers may process information outside the UK. Where a restricted transfer occurs, we will apply a lawful transfer mechanism, such as UK adequacy regulations or appropriate contractual safeguards, and any required risk assessment. You can contact us for more information about the safeguards relevant to your information.
9. How long we keep information
We keep personal information only while it is needed for recruitment, employment, legal compliance, dispute handling or other legitimate purposes. For registered candidates with no meaningful recruitment activity for 24 months, we review their records and delete or anonymise information that is no longer needed. The 24-month period is a review point, not an automatic right to retain everything for that duration or a legal minimum. Activity includes meaningful contact, a candidate-initiated update or consideration for a role, rather than automated marketing alone. Recruitment agencies must also follow applicable statutory record-keeping rules, including the Conduct of Employment Agencies and Employment Businesses Regulations 2003, which generally require relevant work-finding records to be held for at least 12 months. For employed workers, Right to Work check records must normally be kept for the duration of employment and two years afterwards; PAYE and other statutory records follow their own retention requirements. Some records may be kept longer where necessary for legal claims or other lawful purposes. We review records periodically and restrict or remove information when the reason for keeping it ends.
10. Cookies and website analytics
Our website is hosted on Squarespace and uses Squarespace Analytics to understand website usage, including visits, pageviews, traffic sources, browsers and devices. We have enabled Squarespace’s option to include activity-log data in Analytics. Depending on the settings and technologies involved, analytics information may include online identifiers such as IP addresses. We use this information to understand website performance and improve our services, relying on legitimate interests where appropriate for personal-data processing, subject to the separate rules governing cookies and similar technologies. Our website also uses Spark Plugin for visual effects and website customisation, and may load resources from third-party providers. Candidate registration and CV uploads take place through Rocket ATS.
We display a Squarespace cookie banner and have enabled its restriction of non-essential cookies. Strictly necessary cookies may be used without consent where legally permitted. Where cookies or similar technologies require consent, they should not be used until consent is obtained; visitors can change their preferences using the website’s cookie controls. Certain exempt analytics uses may follow different legal rules. Our website and embedded third-party services may change, so the specific cookies, purposes and lifetimes should be verified periodically through a cookie audit and described in the website’s cookie information. Squarespace’s controls may not automatically govern every third-party script.
11. Direct marketing and your choices
You can ask us to stop sending direct marketing at any time by using an unsubscribe link where provided or contacting work@rpsrecruitment.co.uk. We will honour your objection to direct marketing and may retain limited suppression information to ensure we respect it. Opting out of marketing does not prevent essential communications about a current application, assignment or contract.
12. Your data protection rights
Subject to the conditions and exceptions in law, you may have rights to access your personal information; correct inaccurate data; request erasure or restriction; object to processing; receive certain information in a portable format; and withdraw consent where processing relies on consent. You also have rights concerning qualifying solely automated decisions. We do not intend to make decisions with legal or similarly significant effects solely by automated means without complying with the applicable requirements.
To exercise your rights, contact work@rpsrecruitment.co.uk. We may need to verify your identity before responding. You also have the right to complain to the Information Commissioner’s Office (ICO) at www.ico.org.uk, although we would welcome the chance to resolve a concern first.
13. Security and third-party links
We use appropriate organisational and technical measures to protect personal information from unauthorised access, loss, alteration or disclosure. No internet-based service can be guaranteed completely secure. Our website may link to third-party sites with their own privacy notices; we are not responsible for those sites’ practices.
14. Changes to this policy
We may update this policy as our services, systems or legal requirements change. The latest version will appear on our website with an updated date. Where the law requires us to bring a material new use of personal information to your attention, we will do so.