Privacy Notice

X4 Group takes data privacy seriously. This privacy notice applies to X4 Group entities across our global operations. We are committed to safeguarding the privacy and security of the personal data we may collect from candidates, clients, suppliers, website users and/or other contacts while performing our services. This privacy notice aims to help you understand our personal data collection, usage and disclosure practices by explaining:

  • Who we are;
  • What information we collect;
  • How we obtain the personal data about you;
  • How we use your personal data;
  • Your rights;
  • Who we share your personal data with;
  • Which countries we transfer your personal data to;
  • How long we keep your personal data;
  • Safeguarding measures;
  • Consequences of not providing your data;
  • Complaints;
  • Cookies;
  • Contact; and
  • Updating this notice.

Who we are

X4 Group (‘we’ or ‘us’ or ‘our’) is a global recruitment company, the members of which are X4 Group Ltd, X4 Staffing Deutschland GmbH, X4 Tech Staffing Inc and X4 Alpha LLC. We gather and process your personal information in accordance with this privacy notice and in compliance with the relevant data protection regulation and laws. This notice provides you with the necessary information regarding your rights and our obligations, and explains how, why and when we process your personal data. X4 Group Ltd is registered at Quadrant House, 4 Thomas More Square, London, E1W 1YW and are registered in England and Wales under company number 06711498. The company is registered on the Information Commissioner’s Office Register, registration number 00044493711. X4 Staffing Deutschland GmbH is registered at Zimmerstraße 23, UHY Deutschland AG, D-10969 Berlin, and is registered under District Court Charlottenburg (Berlin) HRB 223116 B. X4 Alpha LLC is registered in New York and operates at 10 Grand St Suite 1200, Brooklyn, NY 11249 X4 Tech Staffing Inc. operates in Denver Colorado. X4 Group acts as data controller when processing your data.

What information we collect

X4 Group processes your personal information to meet our legal, statutory and contractual obligations and to provide you with our products and services. We do not collect any unnecessary personal data from you and do not process your information in any way other than as specified in this notice. The personal data that we collect may include:

  • Name;
  • Date of birth;
  • Home address;
  • Personal email;
  • Business email;
  • Home telephone number;
  • Mobile telephone number;
  • National insurance number;
  • Passport;
  • Driving licence;
  • Special category data (i.e. health/medical information, details about religion, sexuality etc); and
  • Employment history.

Sensitive Data

Owing to the services that we offer, X4 Group sometimes needs to process sensitive personal information (also known as special category data) about you, to comply with certain legal obligations, contractual obligations or due to it being essential for a role you have expressed interest in (for example, a DBS check if you will be working with vulnerable people). Where we process sensitive data, we will request and process the minimum amount of data necessary for the specified purpose and identify a compliant legal basis for doing so.

How we obtain the personal data about you

Where we do not collect data directly from you, we may collect and use data obtained from other sources available to us. These sources include but are not limited to:

  • Publicly available sources, publications or similar media, online applications and searching via websites/partner websites such as Hunter, Sourcebreaker, Lusha;
  • Referrals and recommendations from other contacts; and
  • Social media, job boards or other industry job sites such as LinkedIn.

How and why we process your personal data

X4 Group processes data in order to provide our services as a recruitment company and talent partner. Where legally permitted and/or required, the data is also used for reporting purposes as well as monitoring and in order for us to improve our services. We only retain data for as long as is necessary and for the purpose(s) specified in this notice, which include:

  • Contacting candidates and prospect candidates regarding work opportunities;
  • Introducing candidates to clients;
  • Arranging interviews;
  • Assessing suitability of candidates for vacancies;
  • Keeping our records up to date in regard to, for example, contact information and career history;
  • Keeping you up to date on changes to terms and conditions; and
  • Any other activity reasonably associated with recruitment and staffing solutions.

Legal basis for processing

Where we rely on your consent for processing data, we will obtain your explicit consent digitally or otherwise in writing. You can modify or withdraw consent at any time, which we will action as soon as possible, unless there is a legitimate or legal reason for not doing so. Please see below for contact details. For the most part, we will not be seeking explicit consent from you for processing your data. Nevertheless, and in line with the conditions defined in applicable data protection legislation, including the UK GDPR, we shall ensure that our processing falls within scope of the legal basis for processing, being one of more of the following:

  • Legitimate Interest;
  • Contract;
  • Legal Obligation;
  • Vital Interest;
  • Public Interest; or
  • Where we process data on the basis of legitimate interest, we do so with your rights in high regard and we perform a so-called balancing test to ensure your interests are also taken into account.

Data Transfer

We may transfer and process your data to and in one or more other countries, in or outside the European Union. For X4 Group in particular, because of its global structure, those countries include Germany, the United Kingdom and the US. We will only transfer data outside the UK and EU to countries which the European Commission believes offer an adequate level of protection to you, or where we have put appropriate safeguards in place, as required by the UK GDPR and the EU GDPR. For EU-UK transfers we therefore rely upon the adequacy decision of 28 June 2021, whereas we have chosen the Standard Contractual Clauses and the UK Addendum as appropriate safeguard for most EU/UK-US transfers.

Automated Decision Making

Currently we do not carry out solely automated decision-making. Automated decision-making is where a decision is made by automated means, without human involvement. It does not necessarily have to involve profiling, although it often does. Profiling is a process of using personal data to make generalizations about a person, which in recruitment could consist of analysing or trying to predict aspects concerning an individual’s performance at work, reliability, behaviour, or location.

Your Rights

You have the right to access personal information that we processes about you, including:

  • What personal data we hold about you;
  • The purposes of the processing;
  • The categories of personal data concerned;
  • The recipients to whom the personal data has or will be disclosed;
  • How long we intend to store your data; and
  • If we did not collect the data directly from you, information about the source.

If you believe that we hold any incomplete or inaccurate data about you, you have the right to ask us to correct and/or complete the information and we will strive to do so as quickly as possible; unless there is a valid reason for not doing so, at which point you will be notified. You also have the right to request erasure of your personal data, to restrict processing (where applicable) as well as to object to certain processing, in accordance with applicable data protection laws. Where applicable, you also have the right to data portability of your information. Finally, if we are processing your data based on consent, you have the right to withdraw such consent at any time. If you want to object to processing, request an erasure, withdraw consent or exercise any of the other above-mentioned rights, please send an email to dataprotection@thex4group.com and our data protection team will verify your details and make provisions to process your request. The reason why we may need to verify your identity or other details before acting on the request, is to ensure that your data is protected and kept safe. Please note, that if you do exercise your right to object, restrict, if you withdraw your consent or request erasure, our ability to carry out and deliver services to you for your benefit may be affected.

Marketing

If you are a candidate, X4 Group will occasionally send you information on vacancies or requests to update your CV by email or SMS. If you are a client, X4 Group may contact you with promotional offers relevant to you as a customer. You are free to unsubscribe from marketing communication at any time, which can be done here.

Who we share your personal data with

X4 Group uses third parties to provide the below services and business functions; however, all processors acting on our behalf only process your data in accordance with instructions from us and comply fully with this privacy notice, the data protection laws and any other appropriate confidentiality and security measures. Below is a list of the processors acting on our behalf:

Anfold Software Ltd

We use Anfold Software Ltd to provide specialist timesheet software on our behalf, which we refer to as our Timesheet Portal. The only information we provide them with is your name, address and ltd company details in order to meet business and legal requirements. For more information about Anfold Software Ltd, please read their privacy notice at https://www.timesheetportal.com/PrivacyPolicy.aspx

itQED Ltd

We use itQED Ltd to provide specialist outsourced IT support services on our behalf. Given the holistic nature of the support services they offer, any data that we process about you is also in turn processed by itQED Ltd, in order to meet business and legal requirements. For more information about itQED Ltd, please read their privacy notice at http://www.it-qed.co.uk/privacy-policy/

Microdec plc

We use Microdec plc to provide specialist CRM software in order for us to manage our candidate and client relationships. They hold any applicable data relevant to your work-seeking activities, in order to meet business and legal requirements. For more information about Microdec plc, please read their privacy notice at http://www.microdec.com/legal-page/data-protection-policies.

Strategies Online Ltd

We use Strategies Online Ltd to build, host and manage our website. The only information we provide them with would be the information provided by you should you apply through the application or registration forms on our website. For more information about Strategies Online Ltd, please read their privacy notice at https://www.strategies.co.uk/privacy/.

Synergy Office (UK) Ltd

We use Synergy Office (UK) Ltd to provide and host our telecommunications platform. In doing so, they may have access to information relating to you in the form of voice conversations held with our staff. For more information about Synergy Office (UK) Ltd, please read their privacy notice at http://www.synergygrp.co.uk/privacy-policy/

Salesforce and Seven20.io Ltd

We use Salesforce as our CRM and Seven20 to manage this platform. Salesforce is simply providing the software and would not access the data. The data held on the platform however is all candidate, client and placement data. Seven20.io Ltd’s privacy notice can be found at Website-privacy-policy-For-organisations-2020-05-28.pdf (seven20.io).

Xero

Our accounting software, used to facilitate payments to contractors and receive payments from clients. The privacy notice can be found at Privacy Notice | Xero UK.

How Long We Keep Your Data

X4 Group retains personal information for as long as is necessary for the purpose of processing in question and we have strict retention policies in place to meet these obligations. We are under obligation to keep certain data for a set period of time, for example, where we have paid you or used your details to facilitate invoicing we must keep such data for at least 6 years. For further details relating to your data, please get in touch.

Safeguarding Measures

X4 Group Ltd takes your privacy seriously and takes every reasonable measure and precaution to protect and secure your personal data. We work hard to protect you and your information from unauthorised access, alteration, disclosure or destruction and have several layers of security measures in place, including:

  • Securely managed local firewalls;
  • Encrypted servers and back-ups;
  • Securely restricted access permissions;
  • 13-character password policy;
  • Group policies for anti-virus;
  • Restricted downloads and auto-timeouts on physical machines; and
  • Multiple policies to control physical data, including auto-delete of local downloads, a data retention policy for physical data and a comprehensive confidential waste policy.

Consequences of not providing your data

You are not obligated to provide your personal information to X4 Group, however as this information is required for us to provide you with our services and offer a legitimate business solution we will not be able to offer some/all our services without it.

Lodging a complaint

If you wish to raise a complaint regarding the processing of your personal data or are unsatisfied with how we have handled your information, you have the right to lodge a complaint with the supervisory authority.

In the UK this is the Information Commissioner’s Office. You can contact them in the following ways:

Website: https://ico.org.uk/
Phone: 0303 123 1113
Email: casework@ico.org.uk
Post: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF

The Berlin authorities:

Berliner Beauftragte für Datenschutz und Informationsfreiheit

Website: https://www.datenschutz-berlin.de/
Phone: +49 30 13889-0
Email: mailbox@datenschutz-berlin.de
Post: Alt-Moabit 59-61, 10555 Berlin

Contact

If you have any questions about this policy, or wish to get in touch with our DPO, please contact us by:

Email: dataprotection@thex4group.com;
Phone: (+44) 0207 812 7700; or
Post: X4 Group, 58 Victoria Embankment, London, EC4Y 0DS

Updating this notice

We review and update our policy on data protection and this notice on an annual basis in order to make sure it reflects our current data processing activities. We also issue updates with new services or changes in our processing.

Cookie Notice

A ‘cookie’ is a small piece of data sent from a website and stored on the user’s computer by the user’s web browser while the user is browsing. When you visit a site that uses cookies for the first time, a cookie is downloaded onto your computer/mobile device so that the next time you visit that site, your device will remember useful information such as items added in the shopping cart, visited pages or logging in options. Cookies are widely used in order to make websites work, or to work more efficiently, and our site relies on cookies to optimise user experience and for features and services to function properly. Most web browsers allow some control to restrict or block cookies through the browser settings, however if you disable cookies you may find this affects your ability to use certain parts of our website or services. For more information about cookies visit https://www.aboutcookies.org. Please see our full cookie policy here: https://www.thex4group.com/cookie-policy/.