About Our Privacy Policy

Last Updated: 25th May 2018

This privacy policy explains what we do with your Personal Data, whether we are in the process of:

  • Helping you find a job or interim assignment
  • Continuing our relationship with you once you have found a role,
  • Providing you with recruitment services or offering these services to you
  • Receiving a service from you,
  • Using your data to ask for your assistance in relation to one of our candidates or vacancies,

or;

  • Providing a fully-functional experience when you are visiting our website.

It describes how we collect, use and process your Personal Data, and how, in doing so, we comply with our legal obligations to you. Your privacy is important to us, and we are committed to protecting and safeguarding your data privacy rights.

This Privacy Policy applies to the Personal Data of our Website Users, Candidates, Clients, Suppliers and other people whom we may contact in order to find out more about our Candidates or whom they indicate as an emergency contact. It also applies to the emergency contacts of our Employees.

For the purpose of applicable data protection legislation (including but not limited to the General Data Protection Regulation (Regulation (EU) 2016/679 (the GDPR)), the company responsible for your Personal Data (“Jarvis Johnson Ltd” or “Us”) can be found in Appendix 1.

Changes to the Privacy Policy. Please review the “Last Updated” legend at the top of this page to determine when this Privacy Policy was last amended. Any changes to this Privacy Policy will become effective on the “Last Updated” date indicated above. By accessing our website or providing information to us following such changes, you will have accepted the amended Privacy Policy. If Jarvis Johnson is going to use Personal Data collected in a manner materially different from that stated at the time of collection, then Jarvis Johnson will notify you via email and/or by posting a notice on Jarvis Johnson’s Site for 30 days prior or by other means as required by law.

If you are unhappy with any aspect of our Privacy Policy, you may have legal rights and, where relevant we have described these below.

SECTION A – Concise Privacy Policy

A1 – WHAT KIND OF PERSONAL DETAIL DO WE COLLECT?

(i) CANDIDATE DATA
In order to provide the best possible employment or interim opportunities that are tailored to your skills, we need to process certain information about you.

We will only ask for details that will genuinely help us to help you, such as your name, contact details, education / training details and employment history along with any other information you choose to share with us. For a more comprehensive list of data we collect about candidates see Section B1 (i).

When you access our website we also collect certain data from you if you would like more information about this see Section B10 [“Cookies Policy”].

(ii) CLIENT DATA
If you are a customer of Jarvis Johnson we need to collect information about you or individuals at your organisation for the reason of finding you candidates who are a right fit for your organisation. For more detailed information on the data we collect about clients see Section B1 (ii).

When you access our website we also collect certain data from you. If you would like more information about this see Section B10 [“Cookies Policy”].

(iii) SUPPLIER DATA
We need a small amount of data from our suppliers to ensure things run smoothly. We need contact details for relevant individuals at your organisation, so we can communicate with you. We also need information such as bank details, so we can pay for the services you provide.

For more detailed information on the data we collect about suppliers see Section B1 (iii) [“Supplier Data”].

When you access our website we also collect certain data from you if you would like more information about this see Section B10 [“Cookies Policy”).

(iv) PEOPLE WHOSE DATA WE RECEIVE FROM CANDIDATES AND STAFF, SUCH AS REFEREES AND REFERRALS
In order to provide candidates with suitable employment opportunities safely and securely and to provide for every eventuality for them and our employees we need some basic background information. We only ask for the very basic contact details, so we can have a further conversation regarding a reference or to offer you the opportunity to become a client or candidate.

For more detailed information on the data we collect from the above category of individuals see Section B1 (iv).

(v) WEBSITE USERS
We collect a small amount of data from our website users which we use to help us improve your experience when using our website and help us manage the services we provide. This includes information such as how you use our website and the frequency of your visits.

For more detailed information on the data we collect from website users see Section B1 (v) and Section B10 [“Cookies Policy”].

NOTE ABOUT PERSONAL DATA AND THE PERFORMANCE OF CONTRACTUAL AGREEMENTS

Depending on the type of Personal Data in question and the grounds on which we may be processing it, should you decline to provide us with such data, we may not be able to fulfil our contractual requirements or, in extreme circumstances, may not be able to continue with our relationship.

For details of the legal bases that we rely on to be able to use and process your Personal Data see Section B11 [“Legitimate Interests”], B12 [“Consent”], B13 [Establishing, Exercising or Defending Legal Claims”].

A2 – HOW DO WE COLLECT YOUR PERSONAL DATA?

(i) CANDIDATE DATA
There are 2 main ways that we may collect your data, as a candidate;

1) Directly From you; or
2) From a third party.

For more detailed information on how we collect your data see Section B2 (i).

When you access our website, read or click on an email from us we also collect certain data from you if you would like more information about how we collect candidate data see Section B2 (i) and Section B10 [“Cookies Policy”].

(ii) CLIENT DATA
There are 2 main ways that we may collect your data as a client;

1) Directly From you or an individual within your company; or
2) From a third party (e.g. our candidates) and other limited sources

For more detailed information on how we collect client data see Section B2 (ii) [“Client Data”].

When you access our website, read or click on an email from us we also collect certain data from you if you would like more information about this see Section B2 (ii) and Section B10 [“Cookies Policy”].

(iii) SUPPLIER DATA
As a supplier of ours, we collect your Personal Data during the course of our work with you.

When you access our website, read or click on an email from us we also collect certain data from you if you would like more information about how we collect supplier data see Section B10 [“Cookies Policy”].

(iv) PEOPLE WHOSE DATA WE RECEIVE FROM CANDIDATES AND STAFF, SUCH AS REFEREES AND REFERRALS
If you fit in the above description, we collect your contact details only where a candidate, member of our staff or a client passes this information to us as: 1) an emergency contact, 2) referral or; 3) in order to obtain a reference.

(v) WEBSITE USERS
We collect your data automatically via cookies when you visit our website, in line with cookie settings in your browser. If you would like to find out more about cookies, including how we use them and what choices are available to you please see Section B2 (iii) and Section B10 [“Cookies Policy”].

We will also collect data from you when you contact us via the website, for example by using the contact form.

A3 – HOW DO WE USE YOUR PERSONAL DATA?

(i) CANDIDATE DATA
As a candidate, the main reason for us using your Personal Data is to help you find employment that might be suitable for you. The more information we have about you, your skillset and your ambitions, the more bespoke we can make our service. Where appropriate and in accordance with local laws and requirements, we may also use your Personal Data for things such as marketing and profiling. Where appropriate, we will seek your consent to undertake some of these activities.

For more details on how we use your Personal Data, please see Section B3 (i).

(ii) CLIENT DATA
The main reason for using information about clients is to ensure that the contractual arrangements between us can be properly implemented so that the relationship can run smoothly. This will mainly involve identifying candidates who we think will be the right fit for your organisation. The more information we have, the more bespoke service we can provide.

For more details on how we use your Personal Data, please see Section B3 (ii).

(iii) SUPPLIER DATA
The main reason for using information about suppliers is to ensure that the contractual arrangements between us can be properly implemented so that the relationship can run smoothly, and to comply with legal requirements.

For more details on how we use your Personal Data, please see Section B3 (iii).

(iv) PEOPLE WHOSE DATA WE RECEIVE FROM CANDIDATES AND STAFF, SUCH AS REFEREES AND REFERRALS
We use referees’ Personal Data to help our candidates to find employment which is suited to them. If we are able to verify their details and qualifications, we can make sure that they are well matched with prospective employers. We may also use referees’ Personal Data to contact them in relation to recruitment activities that may be of interest to them. We use the personal details of staff members emergency contacts in the case of accident of emergency affecting that member of staff.

For more details on how we use your Personal Data, please see Section B3 (iv).

(v) WEBSITE USERS
We use your data to help us to improve your experience of using our website, for example by analysing your recent job search criteria to help us to present jobs to you that may be of interest to you. If you are also a candidate or client of Jarvis Johnson, we may use data from your use of our website to enhance other aspects of our communications with, or service to, you.

If you would like to find out more about cookies, including how we use them and what choices are available to you please see Section B10 [“Cookies Policy”].

In general, the lawful premise for this activity is:

Please note that communications to and from Jarvis Johnson staff including emails may be reviewed as part of internal or external investigations or litigation.

A4 – WHO DO WE SHARE YOUR PERSONAL DATA WITH?

(i) CANDIDATE DATA
As a candidate, we may share your Personal Data with various parties, in various ways and for various reasons. Primarily we will share your information with prospective employers to increase your chances of securing the job you want. Unless you specify otherwise, we may also share your information with any of our subsidiary companies and associated third parties such as our service providers where we feel this will help us to provide you with the best possible service.

If you would like to see a list of who we may share your Personal Data with, please see Section B4.

(ii) CLIENT DATA
If you are one of our clients, we will share your data: primarily to ensure that we provide you with a suitable pool of candidates and to enable us to offer you a wider range of relevant recruitment services. Unless you specify otherwise, we may share your information with associated third parties such as our service providers to help us meet these aims.

If you would like to see a list of who we may share your Personal Data with, please see Section B4.

(iii) SUPPLIER DATA
If you are a supplier of ours, unless you specify otherwise, we may share your information with any of our subsidiary companies and associated third parties such as our service providers and organisations to whom we provide services.

If you would like to see a list of who we may share your Personal Data with, please see Section B4.

(iv) PEOPLE WHOSE DATA WE RECEIVE FROM CANDIDATES AND STAFF, SUCH AS REFEREES AND REFERRALS
If you fit the description above, unless you specify otherwise, we may share your information with any of our subsidiary companies and associated third parties such as our service providers and organisations to whom we provide services.

If you would like to see a list of who we may share your Personal Data with, please see Section B4.

(v) WEBSITE USERS
Unless you specify otherwise, we may share your information with the providers of web analytics services, marketing automation platforms and social media services to make sure any advertising you receive is tailored to you.

A5 – HOW DO WE SAFEGUARD YOUR PERSONAL DATA?

We care about protecting your information. That is why we put in place appropriate measures that are designed to prevent unauthorised access to, and misuse of, your Personal Data.

For more information on the procedures we put in place, please see Section B5.

A6 – HOW LONG DO WE KEEP YOUR PERSONAL DATA FOR?

If we have not had meaningful contact with you (or, where appropriate, the company you are working for or with) for a period of 5 years, we will delete your Personal Data from our systems unless we believe in good faith that the law or any other regulation requires us to preserve it (for example, in connection with any anticipated litigation).

For more information on our policy for the retention of Personal Data, please see Section B6.

A7 – HOW CAN YOU ACCESS, AMEND OR TAKE BACK THE PERSONAL DATA THAT YOU HAVE GIVEN TO US?

Even if we already hold your Personal Data, you still have various rights in relation to it. To get in touch about these, please contact us at enquiries@jarvisjohnnson.co.uk. We will seek to deal with your request without undue delay, and in any event in accordance with the requirements of any applicable laws. Please note that we may keep a record of your communications to help us to resolve any issues which you raise.

(i) Right to object: If we are using your data because we deem it necessary for our legitimate interests to do so, and you do not agree, you have the right to object. We will respond to your request within 30 days (although we may be allowed to extend this period in certain cases). Generally, we will only disagree with you if certain limited conditions apply.

(ii) Right to withdraw consent: Where we have obtained your consent to process your Personal Data for certain activities (for example profiling your suitability for certain roles), or consent to market to you, you may withdraw your consent at any time.

(iii) Data Subject Access Requests (DSAR): You have the right to ask us to confirm what information we hold about you at any time, and you may ask us to modify, update or delete such information. At this point we may comply with your request or additionally do one of the following:
– We may ask you to verify your identity or ask for more information about your request; and
– Where we are legally permitted to do so, we may decline your request, but we will explain why if we do so.

(iv) Right to erasure: you have the right to request us to “erase” your Personal Data. We will respond to your request within 30 days (although we may be allowed to extend this period in certain cases) and will only disagree with you if certain limited conditions apply.

(v) Right of data portability: if you wish, you have the right to transfer your data from us to another data controller. We will provide you with a copy in a commonly used machine-readable format.

(vi) Right to lodge a complaint with a supervisory authority: you also have the right to lodge a complaint with your local supervisory authority, details of which can be found in Appendix 2.

If your interests or requirements change, you can unsubscribe from part or all of our marketing content (for example job role emails or Jarvis Johnson Newsletters) by clicking the unsubscribe link in the email.

If you would like to know more about your rights in respect of the Personal Data we hold about you, please see Section B7.

A8 – HOW DO WE STORE AND TRANSFER YOUR DATA INTERNATIONALLY?

In order for us to offer the level of service that we do, we may have to transfer or store your data internationally.

For more information on the steps we take when we transfer and store your data internationally, please see Section B9.

A9 – WHAT ARE COOKIES AND HOW DO WE USE THEM?

A “cookie” is a bite sized piece of data that is stored on your devices memory. They are used by nearly all website and do not harm your system. We use them to track your activity to help ensure you get the smoothest possible experience when visiting our website. We can use the information from cookies to ensure we present you with options tailored to your preference on your next visit. We can also use cookies to analyse traffic and for advertising purposes.

If you want to check or change what types of cookies you accept, this can usually be altered within your browsers settings.

If you want to find out more about cookies, including how we use them and what choices are available, please see Section B10 [“Cookies Policy”].

A10 – HOW TO REJECT COOKIES

If you don’t want to receive cookies that are not strictly necessary to perform basic features of our site, you may choose to opt-out by changing your browser settings. Most web browsers will accept cookies but if you rather we didn’t collect data in this way you can choose to accept all or some or reject cookies in your browser’s privacy settings. However, rejecting all cookies means that you may not be able to take full advantage of all our website’s features and experience limited functionality. Each browser is different, so check the “help” menu of your browser to learn how to change your cookie preferences.

For more information generally on cookies, including how to disable them, please refer to www.aboutcookies.org.

Section B – DETAILED PRIVACY POLICY

Here is a more detailed look at the information we may collect. The information described below is, of course, in addition to any Personal Data we are required by law to process in any given situation.

(i) CANDIDATE DATA

As a candidate, depending on the relevant circumstances and applicable local laws and requirements, we may collect some or all of the information listed below to enable us to offer you employment opportunities which are tailored to your circumstances and your interests.

  • Name
  • Contact Details
  • Education Details
  • Employment History
  • Date of birth
  • Referee details
  • Nationality/citizenship/place of birth
  • A copy of your driving licence and or passport
  • National Insurance Number
  • Details about your current remuneration, pensions and benefits arrangements
  • Your salary / daily rate requirements
  • Notice Period / Availability
  • Information on your interests and needs regarding future employment, both collected directly and inferred, for example from jobs viewed or articles read on our website
  • Extra information that you choose to tell us
  • In the case of Interim Managers – Limited Company details and insurance arrangements
  • Extra information that your referee chooses to tell us about you
  • Extra information that our clients may tell us about you (such as interview feedback)
  • Extra information that is available from other third-party sources such as job sites, CV databases or social media (mainly LinkedIn)
  • IP address
  • The dates, times and frequency with which you access our services.
  • Records of conversations and emails between Jarvis Johnson and yourself
  • history of vacancies / assignments you have applied for and the outcome of each of these

Please note that the above list of categories of Personal Data we may collect is not exhaustive.

To the extent that you access our website we will also collect certain information from you. If you would like more information about this, please see Section B10 [“Cookies Policy”].

 

(ii) CLIENT DATA

We generally only need to have your contact details or the details of individual contacts at your organisation (such as names, job titles, telephone numbers and email addresses) to enable us to ensure that our relationship runs smoothly. We may also hold extra information that someone in your organisation has chosen to tell us. If we need any additional Personal Data for any reason, we will let you know. Depending on the relevant circumstances and applicable local laws and requirements, we may collect some or all of the information listed below to allow us to tailor our recruitment services to you:

  • Extra information that is available from other third-party sources such as social media (mainly LinkedIn)
  • IP address if you access our website
  • The dates, times and frequency with which you access our services.
  • Records of conversations and emails between Jarvis Johnson and yourself.

To the extent that you access our website we will also collect certain data from you. If you would like more information about this, please click here see Section B10 [“Cookies Policy”].

 

(iii) SUPPLIER DATA

We don’t collect much information about suppliers – we simply need to make sure that our relationship runs smoothly. We will collect the details for our contacts within your organisation, such as: names, job titles telephone numbers and email addresses. We will also collect company bank details, so that we can pay you. We may also hold extra information that someone in your organisation has chosen to tell us.  We will also keep records of conversations and emails between Jarvis Johnson and yourself.

To the extent that you access our website we will also collect certain data from you. If you would like more information about this, please click here see Section B10 [“Cookies Policy”].

(iv) PEOPLE WHOSE DATA WE RECEIVE FROM CANDIDATES AND STAFF, SUCH AS REFEREES AND REFERRALS

All we need from referees is confirmation of what you already know about our candidate or prospective member of staff, so that they can secure an attractive job. To ask for a reference, we require the referee’s contact details (such as name, email address and telephone number) Emergency contact details give us someone to call in an emergency. We need these details if our member of staff has named you as their emergency contact, so we can contact you in the event of an accident or emergency.

(v) WEBSITE USERS
We collect a limited amount of information from our website users which we use to help us improve your experience when using our website and to help us manage the services we provide. This includes information such as how you use our website, the frequency with which you access our website, your browser type, the location you view our website from, the language you choose to view it in and the time of day you visit. If you use our contact us function, we will collect any information you provide to us, for example your name, contact details and the site from which your access to Jarvis Johnson’s site was directed

If you would like to find out more information about what data we collect about you when you visit our website, please click here see Section B10 [“Cookies Policy”].

(i) CANDIDATE DATA
We collect candidate Personal Data in three primary ways:

1. Personal Data that you, the candidate, give to us;
2. Personal Data that we receive from other sources; and
3. Personal Data that we collect automatically.

 

  1. Personal Data you give to us

Jarvis Johnson needs to know certain information about you in order to provide a bespoke service. This will enable us to provide you with the best opportunities and should save you time in not having to consider a lot of information about jobs and services that aren’t relevant to you.

There are numerous ways you can share your information with us

These may include, but not limited to:

  • Entering your details on Jarvis Johnson’s website or via an online application form as part of the registration process;
  • Giving a hard copy CV to one of our consultants or sending a copy to our office;
  • Emailing your CV to Jarvis Johnson or being interviewed / screened by a Jarvis Johnson employee (this could be face to face or over the phone)
  • Applying for jobs through a Job aggregator (such as Indeed) or Job Board which may redirect you to Jarvis Johnson’s website
  • Contacting Jarvis Johnson or one of Jarvis Johnson’s employees through a social media channel such as; LinkedIn, Facebook or Twitter.

 

  1. Personal Data we receive from other sources

We also receive Personal Data about candidates from other sources. Depending on the relevant circumstances and applicable local laws and requirements these may include Personal Data received in the following situations:

  • Your referees may disclose personal information about you with us;
  • Our clients may share personal information about you with us;
  • We may obtain information about you from searching for potential candidates from third party sources, such as LinkedIn and job sites / CV databases
  • if you ‘like’ our page on Facebook or ‘Follow Us’ on Twitter we will receive your personal information from those sites
  1. Personal Data we collect automatically

To the extent that you access our website or read or click on an email from us, where appropriate and in accordance with any local laws and requirements, we may also collect your data automatically or through you providing it to us. For more information please see Section B10 [“Cookies Policy”].

 

(ii) CLIENT DATA
We collect Client Personal Data in three primary ways:

  1. Personal Data that we receive directly from you;
    2. Personal Data that we receive from other sources; and
    3. Personal Data that we collect automatically.

 

  1. Personal Data that we receive directly from you

We will receive data directly from you in 2 ways:

  1. i) Where you contact us proactively, usually by phone, email or social media channels (e.g. LinkedIn, Facebook, Twitter); and/or:
  2. ii) Where we contact you or from an individual within your company (e.g. receptionist), either by phone or email or social media channels (e.g. LinkedIn, Facebook, Twitter) and, through our consultants’ business development activities

 

  1. Personal Data we receive from other sources

Where appropriate and in accordance with local laws and requirements, we may seek more information about you or your colleagues from other sources generally by way of due diligence or other marketing intelligence including;

  • From third party market research companies and by analysing online and offline media (e.g. job advertisements);
  • From delegate lists at relevant events (e.g. exhibitions); and from other limited sources and third parties (e.g. from our candidates to the extent that they provide us with your details to act as a referee for them)
  • From an individual within your company (e.g. receptionist) or from information made publicly available e.g. LinkedIn (via a connection to the Jarvis Johnson LinkedIn page or a connection to a Jarvis Johnson employee)

 

  1. Personal Data we collect via our website

To the extent that you access our website or read or click and email us, where appropriate and in accordance with any local laws and requirements, we may also collect your data automatically or through you providing it to us. For more information please see Section B10.

 

(iii) WEBSITE USERS
When you visit our website there is certain information that we automatically collect, whether or not you decide to use our services. This includes your: IP address, the date and times and frequency with which you access our website and the way you browse its content. We will also collect data from you when you contact us via the contact form.

We collect your data automatically via cookies, in line with cookie settings in your browser. If you are also a candidate or client of Jarvis Johnson, we may use data from your use of our website to enhance other aspects of our communications with or service to you. If you would like to find out more about cookies, including how we use them and what choices are available to you, please see Section B10 [“Cookies Policy”].

Having obtained data about you, we may then use it in a number of ways.

 

(i) CANDIDATE DATA:
We generally use candidate data in four ways:

  1. a) Recruitment activities
    b) Marketing activities
    c) Equal opportunities monitoring and
    d) To help us to establish, exercise or defend legal claims

Here are some more in-depth details about each:

 

(a) Recruitment Activities.

Our main area of work is recruitment – matching the right candidates with the right jobs. We’ve listed below various ways in which we may use and process your Personal Data for this purpose, where appropriate and in accordance with any local laws and requirements. Please note this is not an exhaustive list:

  • Collecting your data from you and other sources such as LinkedIn;
  • Storing your details (and updating them when necessary) on our database, so that we can contact you in relation to recruitment opportunities;
  • Providing you with our recruitment services and to facilitate the recruitment process;
  • Assessing data about you against vacancies which we think may be suitable for you;
  • Sending your information to clients, in order to apply for jobs or to assess your eligibility for jobs (with your express consent), preparation of employment contracts / interim assignment contracts
  • Enabling you to submit your CV, apply online for jobs or to subscribe to alerts about jobs we think may be of interest to you;
  • Allowing you to participate in the interactive features of our services when you choose to do so;
  • Carrying out our obligations arising from any contracts entered into between us;
  • Carrying out our obligations arising from any contracts entered into between Jarvis Johnson and third parties in relation to your recruitment;
  • Facilitating our invoicing processes;
  • Carrying out customer satisfaction surveys;
  • Verifying details you have provided, using third party resources (such as psychometric evaluations or skill tests), or to request information (such as references, qualifications and potentially and criminal convictions), to the extent that is appropriate and in accordance with local laws;
  • Complying with our legal obligations in connection with the detection of crime or the collection of taxes or duties; and;
  • Processing your data to enable us to send you targeted, relevant marketing materials or other communications which we think are likely to be of interest to you.

We may also use your Personal Data for the above purposes if we deem it necessary to do so for our legitimate interests. If you want to know more about what this means, please see Section B11 (i). If you are not happy about this, you have the right to object and can find out more about how to do this in Section B7 (a).

 

(b) Marketing Activities

We may periodically send you information that we think you may find interesting, or to ask for your help connecting other candidates with jobs. In particular, we may use your data for the purposes listed below, where appropriate and in accordance with any local laws and requirements. Please note that this list is not exhaustive.

Personal Data may be collected and processed for marketing to:

  • Enable us to develop and market other products and services;
  • market our full range or recruitment services (for example permanent recruitment or interim contracts)
  • Send you newsletters, details of reports, promotions, offers, networking and client events, and general information about the industry sectors we think might be of interest to you; and
  • Display promotional excerpts from your details on Jarvis Johnsons website(s) as a testimonial (only where we have obtained your express consent to do so).
  • Occasionally (but always via Jarvis Johnson) send you details of relevant services offered by third parties e.g. Interim Management / Specifications Training courses / CV writing services etc.

If you are not happy about our approach to marketing, you have the right to withdraw your consent at any time and can find out more about how to do this in Section B7 (b).

All our marketing is based on what we think will serve our clients and candidates best, but we know we won’t always get it right for everyone. We may use your information to show you adverts and other content on other websites, for example Facebook. If you do not want us to use your data in this way, please turn off the “Advertising Cookies” option (please refer to our Cookies Policy in Section B10 [“Cookies Policy”]). Even where you have turned off advertising cookies it is still possible that you may see a Jarvis Johnson advert, but in this case, it won’t have been targeted at you personally, but rather at an anonymous audience.

 

(c) Equal opportunities monitoring and other sensitive Personal Data

We are committed to ensuring that our recruitment processes are aligned with our approach to equal opportunities. Some of the data we may (in appropriate circumstances and in accordance with local law and requirements) collect about you comes under the umbrella of “diversity information”. This could be information about your ethnic background, gender, disability, age, sexual orientation, religion or other similar beliefs, and/or social -economic background. Where appropriate and in accordance with local laws and requirements, we’ll use this information on an anonymised basis to monitor compliance with our equal opportunities policy. We may also disclose this (suitably anonymised where relevant) data to our clients where this is contractually required, or the client specifically requests such information to enable them to comply with their own employment processes.

This information is categorised as ‘sensitive’ personal information and stricter data protection rules apply to it. We therefore need to obtain your express consent before we can use it. We’ll ask for your consent by offering you an opt-in. this means that you have to expressly and clearly tell us that you agree to us collecting and using this information.

We may collect other sensitive Personal Data about you, such as health-related information, religious affiliation, or details of any criminal convictions if this is appropriate in accordance with local laws and is required for a role that you are interested in applying for. We will never do this without your express consent.

If you would like to find out more about consent, please see Section B12 [“Consent”].

If you are not happy about this, you have the right to withdraw your consent at any time and you can find out how to do so in Section B7 (b).

(d) To help us to establish, exercise or defend legal claims in more unusual circumstances, we may use your Personal Data to help us establish, exercise or defend legal claims.

 

(ii) CLIENT DATA
We use client data for

  1. a) Recruitment Activities;
    b) Marketing Activities; and
    c) To help us establish, exercise or defend legal claims.

Here are some more details about each:

 

(a) Recruitment Activities

Our main area of work is permanent recruitment and interim management services, through:

Providing you with candidates

We have listed below the various ways in which we use your data in order to facilitate this.

  • Storing your details (and updating them where necessary) on our database, so that we can contact you in relation to recruitment activities;
  • Keeping records of our conversations, emails and meetings, so that we can provide targeted services to you;
  • Undertaking customer satisfaction surveys;
  • Processing your data for the purpose of targeting appropriate marketing campaigns

We may use your Personal Data for these purposes if we deem this to be necessary for our legitimate interests. If you would like to know more about what this means, please see Section B11 [“Legitimate Interests”]. If you are not happy about this, in certain circumstances you have the right to object and can find out more about how to do this in Section B7 (a).

(b) Marketing Activities

From time to time we may contact you with very relevant updates regarding our permanent recruitment and interim management services

We may use your Personal Data for these purposes if we deem this to be necessary for our legitimate interests. If you would like to know more about what this means, please see Section B11 [“Legitimate Interests”]. If you are not happy about this, in certain circumstances you have the right to object and can find out more about how to do this in Section B7 (a).

If you are not happy about this, you have the right to opt-out of receiving marketing materials from us and can find out more about how to do so in Section B7 (b).

(c) To help us to establish, exercise or defend legal claims in more unusual circumstances, we may use your Personal Data to help us establish, exercise or defend legal claims.

 

(iii) SUPPLIER DATA
We will only use your information:

  • To store (and update where necessary) your details on our database, so that we can contact you in relation to our agreements;
  • To offer services to you or to obtain support and services from you;
  • To perform certain legal obligations;
  • To help us target appropriate marketing campaigns; and
  • In more unusual circumstances, to help us establish, exercise or defend legal claims.

 

We may use your Personal Data for these purposes if we deem this to be necessary for our legitimate interests. If you want to know more about what this means, please see Section B11 (iii).

We will not, as a matter of course, seek your consent when sending marketing materials to a business postal or email address.

If you are not happy about this, you have the right to object and can find out more about how to do so in Section B7 (a).

 

(iv) PEOPLE WHOSE DATA WE RECEIVE FROM CANDIDATES AND STAFF, SUCH AS REFEREES AND REFERRALS
We will only use the information that our candidates or a member of staff gives us about you for the following purposes:

  • If our staff members nominate you as an emergency contact, we’ll contact you in the case of an accident or emergency affecting them; or
  • if you were nominated by our candidate or a prospective member of staff as a referee, we will contact you in order to take up a reference. This is an important part of our candidate quality assurance process and could be the difference between the individual getting a job or not.
  • If you were nominated by our candidate or prospective member of staff as a referee, we may sometimes use your details to contact you in relation to recruitment activities that we think may be of interest to you, in which case we will use your data for the same purposes for which we use the data of clients, if you would like to find out more about what this means, please see Section B3 (ii).

 

We may use your Personal Data for these purposes if we deem this to be necessary for our legitimate interests. If you would like to find out more about what this means, please see Section B11 (iv).

If you are not happy about this, you have the right to object and can find out more about how to do so in Section B7 (a).

 

(v) WEBSITE USERS
We use your data to help us improve your experience of using our website, for example by analysing your recent job search criteria to help us to present jobs or candidates to you that we think you’ll be interested in.

If you would like to find out more about cookies, including how we use them and what choices are available to you, please see Section B10 [“Cookies Policy”].

Where appropriate and in accordance with local laws and requirements, we may share your Personal Data, in various ways and for various reasons, with the following categories of people;

  • Individuals and organisations who hold information related to your reference or application to work with us, such as current, past or prospective employers, educators and examining bodies and employment and recruitment agencies;
  • Tax, audit, or other authorities, when we believe in good faith that the law or other regulation requires us to share this data (for example, because of a request by a tax authority or in connection with any anticipated litigation);
  • Third party service providers who perform functions on our behalf (including external consultants, business associates and professional advisors such as lawyers, auditors and accountants, technical support functions and IT consultants carrying out testing and development work on our business technology systems);
  • Third party outsourced IT, system administration and document storage providers where we have an appropriate processing agreement (or similar protections) in place;
  • Marketing technology platforms and suppliers;

 

In the case of candidates (with express consent):

  • Potential employers and other recruitment agencies/organisations to increase your chances of finding employment;
  • Third party partners, job boards and job aggregators where we consider this will improve the chances of finding you the right job;

In the case of candidates and our candidates’ and staff referees: third parties who we have retained to provide services such as reference, qualification and criminal conviction checks, to the extent that these checks are appropriate and in accordance with local laws;

If Jarvis Johnson merges with or is acquired by another business or company in the future, (or is in meaningful discussions about such a possibility) we may share your Personal Data with the (prospective) new owners of the business or company.

We require all third parties to whom we transfer your data to respect the security of your Personal Data and to treat it in accordance with the law. We only allow such third parties to process your Personal Data for specified purposes and in accordance with our instructions.

Before we share your Personal Data with any third party for their own marketing purposes we will obtain your express consent.

We are committed to taking all reasonable and appropriate steps to protect the personal information that we hold from misuse, loss, or unauthorised access. We do this by having in place a range of appropriate technical and organisational measures. These include measures to deal with any suspected data breach.

If you suspect any misuse or loss of or unauthorised access to your personal information please let us know immediately. Details of how to contact us can be found in Appendix 1.

We will delete your Personal Data from our systems if we have not had any meaningful contact with you (or where appropriate, the company you are working for or with) for 5 years (or for such longer period as we believe in good faith that the law or relevant regulators require us to preserve your data) after this period, it is likely your data will no longer be relevant for the purposes for which it was collected.

When we refer to “meaningful contact”, we mean, for example, communication between us (either verbal or written), or where you are actively engaging with our online services. If you are a candidate, we will consider there to be meaningful contact with you if you submit your updated CV onto our website. We will also consider it meaningful contact if you communicate with us about potential roles, either by verbal or written communication, on or off-line applications or click through from any of our marketing communications. Your receipt, opening or reading of an email or other digital message from us will not count as meaningful contact – this will only occur in cases where you click through or reply directly.

One of the GDPR’s main objectives is to protect and clarify the rights of EU citizens and individuals in the EU with regards to data privacy. This means that you retain various rights in respect of your data, even once we have obtained it or you have given it to us. These are described in more detail below.
To get in touch about these rights, please contact us at enquiries@jarvisjohnson.co.uk. We will seek to deal with your request without undue delay, and in any event within one month (subject to any extensions to which we are lawfully entitled). Please note that we may keep a record of your communications to help us resolve any issues which you raise.

 

(a) Right to object

This right enables you to object to us processing your Personal Data where we do so for one of the following four reasons: (i) our legitimate interests; (ii) to enable us to perform a task in the public interest or exercise official authority; (iii) to send you direct marketing materials; and (iv) for scientific, historical, research, of statistical purposes.

The “legitimate interests” and “direct marketing” categories above are the ones most likely to apply to our website users, candidates, clients and suppliers. If your objection relates to us processing your Personal Data because we deem it necessary for our legitimate interests, we must act on your objection by ceasing the activity in question unless:

  • We can show that we have compelling legitimate grounds for processing which overrides your interests; or:
  • We are processing your data for the establishment, exercise or defence of a legal claim.
    If your objection relates to direct marketing, we must act on your objection by ceasing this activity.

 

(b) Right to withdraw consent

Where we have obtained your consent to process your Personal Data for certain activities (for example, for our marketing arrangements for automatic profiling), you may withdraw this consent at any time and we will cease to carry out the particular activity that you previously consented to unless we consider that there is an alternative reason to justify our continued processing of your data for this purpose in which case we will inform you of this condition.

 

(c) Data subject access requests (DSAR)

You may ask us to confirm what information we hold about you at any time, and request us to modify, update or delete such information. We may ask you to verify your identity and for more information about your request. If we provide you with access to the information we hold about you, we will not charge you for this unless your request is “manifestly unfounded or excessive”. If you request further copies of this information from us, we may charge you a reasonable administrative cost where legally permissible. Where we are legally permitted to do so, we may refuse your request. If we refuse your request, we will always tell you the reason for doing so.

 

(d) Right to erasure

You have the right to request that we erase your Personal Data in certain circumstances. Normally, the information must meet the following criteria:

  • The data is no longer necessary for the purpose for which we originally collected and/or processed it;
  • Where previously given, you have withdrawn your consent to us processing your data, and there is no other valid reason for us to continue processing;
  • The data has been processed unlawfully (for example in a manner which does not comply with GDPR);
  • It is necessary for the data to be erased in order for us to comply with our legal obligations as a data controller; or
  • If we process the data because we believe it necessary to do so for our legitimate grounds for our continued processing.

 

We would only be entitled to refuse to comply with your request for one of the following reasons:

  • To exercise the right of freedom of expression and information;
  • To comply with legal obligations or for the performance of a public interest task or exercise official authority;
  • For public health reasons in the public interest;
  • For archival, research or statistical purposes; or -to exercise or defend a legal claim.

When complying with a valid request for the erasure of data we will take all reasonably practical steps to delete relevant data.

 

(e) Right to restrict processing

You have the right to request that we restrict our processing of your Personal Data in certain circumstances. This means that we can only continue to store your data and will not be able to carry out any further processing activities with it until either: (i) one of the circumstances listed below is resolved; (ii) you consent; or (iii) further processing is necessary for either the establishment, exercise or defence of legal claims, the protection of the rights of another individual, or reasons of important EU or Member State public interest.

The circumstance in which you are entitled to request that we restrict the processing of your Personal Data are:

  • Where you dispute the accuracy of the Personal Data that we are processing about you. In this case, our processing of your Personal Data will be restricted for the period during which the data is verified;
  • Where you object to our processing of your Personal Data for our legitimate interests. Here, you
    can request that the data be restricted while we verify our grounds for processing your Personal Data;
  • Where our processing of your data is unlawful, but you would prefer us to restrict our processing of it rather than erasing it; and
  • Where we have no further need to process your Personal Data, but you require the data to establish, exercise, or defend legal claims.

If we have shared your Personal Data with third parties, we will notify them about the restricted processing unless this is impossible or involves disproportionate effort. We will, of course, notify you before lifting any restriction on processing your Personal Data.

 

(f) Right to rectification

You also have the right to request that we rectify any inaccurate or incomplete data that we hold about you. If we have shared this Personal Data with third parties, we will notify them about the rectification unless this is impossible or involves disproportionate effort. Where appropriate, we will also tell you which third parties we have disclosed the inaccurate or incomplete Personal Data to. Where we think that it is reasonable for us not to comply with your request we will explain our reasons for this decision.

 

(g) Right of data portability

If you wish, you have the right to transfer your Personal Data between data controllers. In effect this means that you are able to transfer your details to another platform. To allow you to do so, we will provide you with your data in a commonly used machine-readable format so that you can transfer the data to another online platform. Alternatively, we may directly transfer the data for you. This right of data portability applies to: (i) Personal Data that we process automatically (for example without any human intervention); (ii) Personal Data provided by you; and (iii) Personal Data that we process based on your consent in order to fulfil a contract.

 

(h) Right to lodge a complaint with a supervisory authority

You also have the right to lodge a complaint with your local supervisory authority. Details of how to contact them can be found in Appendix 2.

If you would like to exercise any of these rights or withdraw your consent of processing of your Personal Data (where consent is our legal basis for processing your Personal Data), details of how to contact us can be found in Appendix 1. Please note that we may keep a record of your communications to help us resolve any issues which your raise.

You may ask to unsubscribe from job alerts at any time.

It is important that the personal information we hold about you is accurate and current. Please keep us informed of your personal information changes during the period for which we hold your data.

You can find out which Jarvis Johnson entity is responsible for processing your Personal Data and where it is located in Appendix 1.

If you have any comments or suggestions concerning this Privacy Policy, please contact us via the details in Appendix 1. We take privacy very seriously, so we’ll get back to you as soon as possible.

In order to provide you with the best service and carry out the purposes described in this Privacy Policy, your data may be transferred to the following sources outside of the UK:

  • Between and within Jarvis Johnson’s entities and employees
  • To third parties (such as advisors or other suppliers to Jarvis Johnson’s business);
  • To overseas clients (with your express consent);
  • To clients within the UK (with your express consent) who may, in turn, transfer your data internationally;
  • To a cloud-based data storage provider (e.g. Dropbox); and
  • To other third parties, as referred to in Section B4.

Whenever we transfer your Personal Data out of the EEA, we do our best to ensure a similar degree of security of data by ensuring at least one of the following safeguards is in place:

  • We will only transfer your Personal Data to countries that the European Commission have approved as providing an adequate level of protection for Personal Data by; or
  • Where we use certain service providers, we may use specific contracts or codes of conduct or certification mechanisms approved by the European Commission which give Personal Data the same protection it has in Europe; or
  • If we use US-based providers that are part of EU-US Privacy Shield, we may transfer data to them, as they have equivalent safeguards in place.

If none of the above safeguards is available, we may request your express consent to the specific transfer. You will have the right to withdraw this consent at any time.

(i) What is a cookie?

A cookie is a piece of information that is stored on your device’s hard drive and which records your navigation of a website so that, when you revisit that website, it can present tailored options based on the information stored about your last visit. Cookies can also be used to analyse traffic and for advertising and marketing purposes.

Cookies are used by nearly all websites and do not harm your device. If you want to check or change what types of cookies you accept, this can usually be altered within your browser settings.

(ii) How do we use cookies?

We use cookies to do two things:

  • to track your use of our website. This enables us to understand how you use the site and track any patterns that emerge individually or from larger groups. This helps us to develop and improve our website and services in response to what our visitors want and need; and
  • to help us advertise jobs to you that we think you’ll be interested in. hopefully this means less time for you searching through never ending pages of adverts and will get you into the employment you want or a new contract more quickly.

Cookies are either:

Session cookies: these are only stored on your computer during your web session and are automatically deleted when you close your browser – they usually store an anonymous session ID allowing you to browse a website without having to log into each page, but they do not collect any information from your computer; or

Persistent cookies: a persistent cookie is stored as a file on your computer and it remains there when you close your web browser. The cookie can be read by the website that created it when you visit that website again. We may use persistent cookies for Google Analytics and for personalisation.

Cookies can also be categorised as follows:

  • Strictly necessary cookies:these cookies are essential to enable you to use the website effectively, such as when applying for a job, and therefore cannot be turned off. Without these cookies, the services available to you on our website cannot be provided. These cookies do not gather information about you that could be used for marketing or remembering where you have been on the internet.
  • Performance cookies: these cookies enable us to monitor and improve the performance of our website. For example, they allow us to count visits, identify traffic sources and see which parts of our website are most popular.
  • Functionality cookies: these cookies allow our website to remember choices you make (such as your username, language and region you are in) and provide enhanced features. For instance, we may be able to provide you with news or updates relevant to the services you use. These cookies can also be used to remember changes you have made to text size, font and other parts of web pages that you can customise. They may also be used to provide services you have requested such as viewing a video or commenting on a blog. The information these cookies collect is usually anonymised.
  • Personalisation cookies:these cookies help us to advertise details of potential job opportunities that we think may be of interest. These cookies are persistent (for as long as you are registered with us) and mean that when you log in or return to the website, you may see advertising for jobs that are similar to jobs you have previously browsed.

Article 6(1)(f) of the GDPR states that we can process your data where it “is necessary for the purposes of the legitimate interests pursued by [us] or by a third party, except where such interests are overridden by the interests or fundamental rights or freedoms of [you] which require protection of Personal Data”.

We don’t believe that any of the activities specified in sections A3 and B3 prejudice individuals in any way – in fact, they help us to offer you a more tailored, efficient service. However, you do have the right to object to us processing your Personal Data on this basis. If you would like to know more about how to object, please contact us at enquiries@jarvisjohnson.co.uk.

 

(i) CANDIDATE DATA

We think that it is reasonable to expect that if you have applied for a vacancy / interim assignment, emailed your CV to Jarvis Johnson or submitted your CV through Jarvis Johnson’s website or have posted your CV on a job board or professional networking site, you are happy for us to collect and otherwise use your Personal Data to offer or provide our recruitment services to you, share that information with prospective employers (with your express permission) and assess your skills against our bank of vacancies. If we have not had any meaningful contact with you within a 5-year period we do no not feel we have a legitimate interest to hold your data so will remove it from our database unless you have opted in to continue to hear from us. For more details on how long we keep your Personal Data for please refer to section B6 [“How Long Do We Keep Your Personal Data For”].

We want to provide you with tailored job recommendations and other relevant information to help you on your job hunt. We therefore think it’s reasonable for us to process your data to make sure that we send you the most appropriate content.

We have to make sure our business runs smoothly, so that we can carry on providing services to candidates like you. We therefore also need to use your data for our internal administrative activities, like invoicing where relevant.

We have our own obligations under the law, which is a legitimate interest of ours. We may therefore share your data in connection with crime detection, or actual or anticipated litigation.

 

(ii) CLIENT DATA
To ensure that we provide you with the best service possible, we store your Personal Data/or the Personal Data of individual contacts at your organisation as well as keeping emails and records of our conversations, meetings, registered jobs and placements. From time to time we may contact you with very relevant updates regarding our permanent recruitment and interim management services and occasionally we may also ask you to undertake a customer satisfaction survey. We think this is reasonable – we deem the uses of your data as described in section B3 (ii) to be necessary for our legitimate interest as an organisation providing or introducing our various recruitment services to you.

If we have not had any meaningful contact with you within a 5-year period we do no not feel we have a legitimate interest to hold your data so will remove it from our database unless you have opted in to continue to hear from us. For more details on how long we keep your Personal Data for please refer to section B6.

 

(iii) SUPPLIER DATA
We use and store the Personal Data of individuals within your organisation in order to facilitate the receipt of services from you as one of our suppliers. We also keep emails and records of our conversations, meetings We also hold your financial details, so that we can pay you for your services. We deem all such activities to be necessary within a range of our legitimate interests as a recipient of your services.

 

(iv) PEOPLE WHOSE DATA WE RECEIVE FROM CANDIDATES AND STAFF, SUCH AS REFEREES, REFERRALS AND EMERGENCY CONTACTS

If you have been nominated by a candidate or a prospective member of staff as one of their referees, we use your Personal Data in order to contact you for a reference. This is a part of our quality assurance procedure and so we deem this to be necessary for our legitimate interests as an organisation offering recruitment services and employing people ourselves.

In certain circumstances, we are required to obtain your consent to the processing of your Personal Data in relation to certain activities. Depending on exactly what we are doing with your information, this consent will be opt-in consent or soft opt-in consent.

Article 4(11) of the GDPR states that (opt-in) consent is “any freely given, specific, informed and unambiguous indication of the data subjects wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of Personal Data relating to him or her” in plain language, this means that:

  • You have given us your consent freely, without us putting you under any type of pressure;
  • You have to know what you are consenting to; we’ll make sure we give you enough information;
  • You should have control over which processing activities you consent to and which you don’t;
  • You need to take positive and affirmative action in giving us your consent – we’re likely to provide a tick box for you to check so that this requirement is met in a clear and unambiguous fashion.

We will keep records of the consents that you have given in this way

We have already mentioned that, in some cases, we will able to rely on soft opt-in consent. We are allowed to market products or services to you which are related to the recruitment services we provide as long as you do not actively opt-out from these communications.

As we have mentioned, you have the right to withdraw your consent to these activities. You can do so at any time, and details of how to do so can be found in Section B7 (b).

Sometimes it may be necessary for us to process Personal Data and, where appropriate and in accordance with local laws and requirements, sensitive Personal Data in connection with exercising or defending legal claims. Article 9(2)(f) of the GDPR allows this where the processing is “necessary for the establishment, exercise or defence of legal claims or whenever courts are acting in their judicial capacity”.

This may arise for example where we need to take legal advice in relation to legal proceedings or are required by law to preserve or disclose certain information as part of the legal process.

B14 (a) VITAL INTERESTS

Where as a Data Subject, your Personal Data has been provided to us as an emergency contact, this may be collected, held and processed under an emergent need to protect somebodies’ life.

APPENDIX 1 – HOW TO CONTACT US

Country in which you use Jarvis Johnson services or supply Jarvis Johnson with services: UK
Jarvis Johnson entity responsible for processing the Personal Data of Website users: Jarvis Johnson Ltd
Jarvis Johnson entity responsible for the processing of Personal Data of candidates, clients, suppliers and the emergency contacts and referees of candidates and Jarvis Johnson staff: Jarvis Johnson Ltd

Jarvis Johnson Subsidiaries: None

How to get in touch with us:
To access, amend or take back the Personal Data you have given to us.

If you suspect any misuse or loss or unauthorised access to your personal information to withdraw your consent to the processing of your Personal Data with any comments or suggestions regarding this privacy policy.  You can write to us at the following address:

Jarvis Johnson Limited

83 Copley Road,

Doncaster,

South Yorkshire,

DN1 2QP

 

Alternatively, you can send an email to: enquiries@jarvisjohnson.co.uk

To get in touch regarding updating your marketing / contact preferences:
You can send an email to enquiries@jarvisjohnson.co.uk or by clicking the unsubscribe link in any marketing email we send you.

 

APPENDIX 2 – HOW TO CONTACT YOUR LOCAL SUPERVISORY AUTHORITY

Details of your local supervisory authority:

The Information Commissioner’s Office (ICO)
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Phone: 0303 123 1113
Email: casework@ico.org.uk

In line with the ICO guidance, we would be grateful if you would contact us first if you do have a complaint so that we can try to resolve it for you.

 

The ICO provide guidance on making a complaint on their website:

https://ico.org.uk/for-the-public/raising-concerns/

An excerpt from this page is shown below:

 

Should I raise my concern with the ICO?

If the organisation (Jarvis Johnson) has been unable, or unwilling, to resolve your information rights concern, you can raise the matter with us (the ICO).  We (the ICO) will use the information you have provided, including the organisation’s response to your concerns, to decide if your concern provides an opportunity to improve information rights practice.

If we think it does provide that opportunity, we will take appropriate action. This could take a variety of forms.

You should raise the matter with us (the ICO) within three months of your last meaningful contact with the organisation concerned (Jarvis Johnson).

 

GLOSSARY

Candidates: includes applicants for all roles advertised or promoted by Jarvis Johnson, including permanent, part-time, temporary positions and contract roles with Jarvis Johnson clients; as well as people who have supplied a speculative CV to Jarvis Johnson not in relation to a specific job. Individual contractors, interim managers, freelance workers and employees of suppliers or other third parties put forward for roles with Jarvis Johnson will be treated as candidates for the purposes of this Privacy Policy.

Clients: while it speaks for itself, this category covers our customers, clients and others to whom Jarvis Johnson provides or offers services to in the course of its business.

Delete: while we will endeavour to permanently erase your Personal Data once it reaches the end of its retention period or where we receive a valid request from you to do so, some of your data my still exist within our systems, for example if it is waiting to be overwritten. However, while it still exists on an archive system, this cannot be readily accessed by any of our operational systems, processes or staff.

General Data Protection Regulation (GDPR): is a legal framework that sets guidelines for the collection and processing of personal information of individuals within the European Union. It has an effective date of 25 May 2018, and any references to it should be construed accordingly to include any national legislation implementing it.

Suppliers: refers to partnerships and companies (including sole traders), who provide services to Jarvis Johnson.

Website users: any individual who accesses Jarvis Johnson’s Website. www.jarvisjohnson.co.uk