Privacy Policy


2020-Recruitment (“the Company”) is a recruitment business which provides work-finding services to its clients and work-seekers. The Company must process personal data (including special category or ‘sensitive’ personal data) so that it can provide these services. In so doing, the Company acts as a data controller.

You may give your personal details to the Company directly, such as on an application or registration form, CV, or via our website, or we may collect them from another source, such as a jobs board. The Company must have a legal basis for processing your personal data. See below for more details. We will only use your personal data in accordance with the terms of this notice for the purposes of providing you with work-finding services and/or information relating to roles relevant to you.

  1. Information About Us

Euthenia Recruitment Limited t/a 2020-Recruitment

A limited company registered in Scotland under company number SC571447

Registered address: 72 Whitecraigs Road, Glenrothes, KY6 2RX

Main trading address: Office 18, John Smith Business Park, Kirkcaldy, KY2 6HD

VAT number: 283768847

Representative: Robert Gilchrist

Email address: [email protected]

Telephone number: 01592 805600

Postal address: Office 18, John Smith Business Park, Kirkcaldy, KY2 6HD

We are regulated by the Information Commissioner’s Office


  1. What Does This Notice Cover?

This Privacy Notice explains how we use your personal data: how it is collected, how it is held, and how it is processed. It also explains your rights under the law relating to your personal data.


  1. What Is Personal Data?

Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “UK GDPR”), as it forms part of the law of England and Wales, Scotland and Northern Ireland by virtue of section 3 of the European Union (Withdrawal) Act 2018, and the Data Protection Act 2018 (collectively, “the Data Protection Legislation”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.

Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.

The personal data that we use is set out in Part 5, below.


  1. What Are My Rights?

Under the Data Protection Legislation, you have the following rights, which we will always work to uphold:

  1. The right to be informed about our collection and use of your personal data. This Privacy Notice should tell you everything you need to know, but you can always contact us to find out more or to ask any questions using the details in Part 11.
  2. The right to access the personal data we hold about you. Part 10 will tell you how to do this.
  3. The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in Part 11 to find out more.
  4. The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we hold. Please contact us using the details in Part 11 to find out more.
  5. The right to restrict (i.e. prevent) the processing of your personal data.
  6. The right to object to us using your personal data for a particular purpose or purposes.
  7. The right to withdraw consent. This means that, if we are relying on your consent as the legal basis for using your personal data, you are free to withdraw that consent at any time.
  8. The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.
  9. Rights relating to automated decision-making and profiling. Part 6 explains more about how we use your personal data, including automated decision-making and profiling.

For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Part 11.

It is important that your personal data is kept accurate and up-to-date. If any of the personal data we hold about you changes, please keep us informed as long as we have that data.

Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.

If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office. We would welcome the opportunity to resolve your concerns ourselves, however, so please contact us first, using the details in Part 11.


  1. What Personal Data Do You Collect and How?

The Company may collect and hold some or all of the following personal data and special category or ‘sensitive’ personal data:


Data CollectedHow We Collect the Data
Candidate Data


Contact Details (Mobile/Email)


National Insurance Number

Nationality (for evidence of right to work)

Education/Qualification Details

Employment History

Reference Contacts

Emergency Contacts

Bank Details

Passport/Birth Certificate (ID)

Any other relevant information required


Sensitive personal data that may include:

Any Criminal Convictions

Medical Information

Directly from yourself

Job Sites

Media Sites (such as LinkedIn)

Social Media



Client Data

If you are a client of 2020, we need to collect and process information about you, or individuals within your organisation, in the course of providing you or offering you services such as sourcing candidates who are the right fit for your Company, assistance with interviews, payroll services, any other relevant industry information.

Directly from yourself


Media Sites (such as LinkedIn)

Social Media


Market Research





Supplier Data

A small amount of information is required from our Suppliers in order for us to  communicate effectively as well as pay for the services provided.

We collect your data during the course of our work with you.
Referees/Emergency Contacts

We collect your contact details only where a Candidate gives them to us in order for you to act as a referee or where a member of our Staff or a Candidate lists you as their next of kin.

We use referee details in assisting our Candidates find suitable employment. We use emergency contacts in the event of an accident or emergency.
Web Users

We will collect your data automatically using cookies when you visit our website.


We use your data to help improve your experience of using our website. If you are a candidate or a client we may use your data from the website to improve our communications or service to you.


You are under no obligation to provide the Company with data. However, if you do not provide certain information, we will not be able to provide work-finding services.


  1. How Do You Use My Personal Data?

The Company needs to collect and process data in order to offer work-finding services to you.

The Company will process your personal data for the purposes of providing you with work-finding services. This includes, for example, contacting you about job opportunities, assessing your suitability for those opportunities, updating our databases, putting you forward for job opportunities, arranging payments to you, and developing and managing our services and relationship with you and our clients.

In some cases, the Company may be required to collect and process your data for the purpose of investigating, reporting, and detecting crime, and also to comply with laws that apply to us. We may also use your information during the course of internal audits to demonstrate our compliance with certain industry standards.

We use the following automated systems for carrying out certain kinds of decision-making and profiling. If at any point you wish to query any action that we take on the basis of this or wish to request ‘human intervention’ (i.e. have someone review the action themselves, rather than relying only on the automated method), the Data Protection Legislation gives you the right to do so. Please contact us to find out more using the details in Part 11.

  • The following automated decision-making methods may be used:

We may occasionally use an automated decision-making tool when advertising through third party job boards as an assessment too. For example we may ask if the candidate has a full driving licence if the job they are applying for requires it. If ‘no’ is selected then they would be automatically rejected for that particular position. This is seen as a logical measure to ensure only relevant candidates details are considered for further progression through our recruitment process. The significance for the candidate would be that their details would not be processed by the company and would not be successful in their application for the advertised job.

  • The following automated profiling may take place:

As a candidate we may ask you to participate in psychometric testing, assessments, complete tests and/or questionnaires for certain job opportunities where prospective employers request it. Your responses will be provided to and held by our third party provider of which a copy will be sent to us and the prospective employers.

The legal bases we rely upon to offer our services to you are:

  • Your consent (e.g. to register you as a new candidate or to manage our relationship with you);
  • Where we have a legitimate interest (e.g. managing our database and keeping work records up to date, providing work finding services to you and our clients, and contacting you to seek your consent where it is needed);
  • To comply with a legal obligation that we are subject to (e.g. in order to check your entitlement to work in the UK or to comply with safeguarding requirements).

The Company will only use your personal data for the purposes for which it was originally collected, unless we reasonably believe that another purpose is compatible with those original purposes and need to use your personal data for that purpose. If we do use your personal data in this way and you wish us to explain how the new purpose is compatible with the original, please contact us using the details in Part 11.

If we need to use your personal data for a purpose that is unrelated to, or incompatible with, the purposes for which it was originally collected, we will inform you and explain the legal basis which allows us to do so.

In some circumstances, where permitted or required by law, we may process your personal data without your knowledge or consent. This will only be done within the bounds of the Data Protection Legislation and your legal rights.


  1. How Long Will You Keep My Personal Data?

The Company will only hold your personal data for as long as is necessary to fulfil the purposes for which we collected it.

Different laws may also require us to keep data for different periods of time.

The Conduct of Employment Agencies and Employment Businesses Regulations 2003 require us to keep work-seeker records for at least one year from:

  • the date of their creation; or
  • after the date on which we last provide you with work-finding services.

The Company must also keep your payroll records, holiday pay, sick pay, and pensions auto-enrolment records. These records are retained for as long as is legally required by HMRC and associated national minimum wage, social security, and tax legislation.

Where the Company has obtained your consent to process your personal and sensitive data, we will do so in line with our Data Protection Policy. Upon expiry of the period to which you have consented, the Company will seek further consent from you. Where consent is not granted, we will not continue to process your data.


  1. How and Where Do You Store or Transfer My Personal Data?

Data is stored in a range of different places, including on your application record, in the Company's candidate management systems and in other IT systems (including the Company's email system).

We will only store or transfer some of your personal data within the UK and the European Economic Area (the “EEA”). The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein. This means that your personal data will be fully protected under the Data Protection Legislation, GDPR, and/or to equivalent standards by law. The reason for this is that we work with global organisations and the personnel we deal with may work outwith the UK and the EEA. We will inform you of any known data transfer internationally.


  1. Do You Share My Personal Data?

The Company will process your personal data and/or sensitive personal data with the following recipients:

  • HMRC;
  • Clients of the Company;
  • Any applicable legal or government authorities;
  • Previous employers (e.g. in respect of references);
  • Payroll service providers;
  • Any addition third parties as required.

When your personal data is shared with a third party, as described above, we will take steps to ensure that your personal data is handled safely, securely, and in accordance with your rights, our obligations, and the third party’s obligations under the law, as described above in Part 8.


  1. How Can I Access My Personal Data?

If you want to know what personal data we hold about you, you can ask us for details of that personal data and for a copy of it. This is known as a “subject access request”.

All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 11.

There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.

We will respond to your subject access request within 2 weeks, and, in any case, not more than one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.


  1. How Do I Contact You?

To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the following details for the attention of Robert Gilchrist:

Email address: [email protected]

Telephone number: 01592 805600

Postal Address: Office 18, John Smith Business Park, Kirkcaldy, KY2 6HD


  1. Changes to this Privacy Notice

We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection.

This Privacy Notice is subject to review. You can stay up to date by visiting this page as any changes will be posted here.

Date Approved : 06.01.2021