This privacy notice provides a framework of understanding about the personal data collected by Right Management Limited (the Data Processor), on behalf of the Ministry of Defence (the Data Controller); this agreement is known as the Career Transition Partnership (CTP). Our registered office is in 50 Bank Street, Canary Wharf, London, E14 5NS, United Kingdom.
At Right Management Limited privacy is important to us and we place great care in the responsible, transparent and safe handling of data.
This notice is in compliance with data privacy law, including the provisions of the European Union’s General Data Protection Regulation (GDPR) and the UK Data Protection Act 2018.
This privacy notice does not apply to Right Management Limited employees or associates.
This privacy notice describes the types of personal data and information we collect, how we use it, how long we process and store it, how we protect it, with whom we share it, to whom we transfer it and the rights that you can exercise regarding our use of your personal data.
We also describe how you can contact us to further enquire about our privacy practices or to exercise your rights. You can click on one of the links below to jump to the listed section:
When permitted by applicable law, a data subject can exercise under Articles 15 to 22 of the EU GDPR, the following specific rights:
a) Right of access: You have the right to access your personal data to verify your personal data is processed in accordance to the law. This is more commonly referred to as a Subject Access Request;
b) Right to rectification: You have the right to request the rectification of any inaccurate or incomplete data held about you, in order to protect the accuracy of such information and to adapt it to the data processing. If you believe any of the data we process about you is incorrect or incomplete, please contact us and we will take reasonable steps to check its accuracy and correct it where necessary;
c) Right to erasure: Otherwise known as ‘The Right to be Forgotten’; you have the right to request that we no longer process your personal data and erase all information about you. Please be aware this is not an absolute right and there may be legal or regulatory reasons why data cannot be erased at the time of the request;
d) Right to restriction of processing: You have the right to request we restrict the processing of your data for certain purposes;
e) Right to data portability: You have the right to request data portability from the Data Controller, meaning that you can receive your personal data in a structured and commonly used format, or that you can request the transfer of your data to another Data Controller;
f) Right to object: At any time and without having to justify your decision, you have the right to object to the processing of your data for direct marketing purposes. Please note: if you withdraw your consent, the previous processing of data that we have done with your consent will remain lawful;
g) Right not to be subject of automated individual decision-making: You have the right not to be subject to a decision based solely on automated processing, including profiling, if such profiling produces a legal effect or similarly significantly affects you. Right Management Limited do not use processes in which automated decision-making (including profiling) takes place;
h) Right to lodge a complaint with a supervisory authority: You have the right to lodge a complaint with a supervisory authority, in particular in the EU Member State of your habitual residence, place of work or place of the alleged GDPR infringement. The supervisory authority in the UK is the Information Commissioners’ Office (ICO). More information can be found at https://ico.org.uk/
Whenever the processing is based on consent, as under Article 7 of the GDPR, while you may withdraw your consent at any time, there may be circumstances where we will still need to process a portion of your data for legal or official reasons. We will inform you if this is the case. Where this is the case, we will restrict the data to only what is necessary for the purpose of meeting those specific requirements.
If you wish to exercise any of your rights in relation to data privacy, please refer to the How to Contact Us section below.
Give explicit consent for Right Management Limited to process your data for resettlement purposes via electronic registration on JPA, paper MOD Forms 1173/1173A, or via Opt-In forms, where appropriate. Thereafter, when you;
- Visit our Sites including our social media channels outlined above;
- Apply for/engage in career counselling/a workshop/assessment/event – this could be in person, on the telephone or online;
- Enter your details on myPlan or CTP RightJob;
- Message us via our social media channels or any ctp.org.uk email address;
- Otherwise use our services.
We may collect a selection of personal data, including, but not limited to (as permitted under local law):
- Contact information (including full name, alias, personal email address, work email address, personal telephone number, work telephone number, home address, work address);
- Personal details, which may include Service number, job title, rank, enlistment date, discharge date, date of birth, reason for leaving;
- Other information you may provide to us during the course of career guidance or in evaluation surveys, including, but not limited to, details on your CV e.g. employment history, current salary details, salary expectations, academic or vocational qualifications, language proficiencies, industry preferences, new employment details;
- Information you provide on any potential barriers to employment, including criminal convictions and medical conditions; none of this data is recorded without your consent;
- Information you provide in any email sent to a ctp.org.uk address;
- Username and password when you register on our online platforms;
- User IP address;
- If you book a course with us, depending on the method of payment, we ask for your long card number, expiry date and CVV number in order to process the payment. We do not record your card details, but we do keep the Merchant copy of your payment receipt (which contains long card number and expiry date only) to reconcile payments and for financial regulatory purposes.
- Identification information you may be asked to provide, should you wish to exercise specific data rights.
The CTP uses the data gathered for the following purposes (as permitted under local law):
- To support Service leavers in their career transition or development and to fulfil the services contracted. The data gathered helps us understand your circumstances, ensure the information is accurate and guide you in achieving your outcome sought;
- To enable us to effectively handle any potential queries and/or concerns you may have;
- To register you with any appropriate certification/awarding bodies, if you book a Vocational Training Course through CTP. Some registrations are done CTP training providers and we pass a small quantity of personal data to them to facilitate this. This data sharing is protected by bespoke Service Level Agreements with each training provider. Every training provider we use has been Right Management Limited vetted and MoD approved;
- To communicate information and content appropriate to your resettlement with you, via email and text message; including, but not limited to, the CTP Focus Newsletter, Employment Bulletins, details of Employment Events and Training Courses;
- To send you notification of potential job matches, if you have given your consent for this on the CTP RightJob platform;
- To allow employers to contact you via CTP RightJob with a vacancy that may be of interest to, if you have provided consent for your anonymous profile on CTP RightJob to be published;
- If you apply for a job on CTP RightJob, and submit your CV via the platform, you are agreeing for your CV data to go to a third party organisation. While Right Management quality assures the legitimacy of the vacancies advertised on CTP RightJob, and all employers must agree to Terms and Conditions of fair use, please be aware that Right Management Limited has no liability or control over how third parties manage and store your data. It is recommended you check the company’s own privacy notice, which can be found on their website, should you have any privacy related queries;
- If you wish to apply for a Northern Ireland based vacancy on CTP RightJob, with your prior consent, we will email your CV and covering letter directly to the hiring manager;
- To record any job you have apply for on or via RightJob on your resettlement file;
- To administer participation in evaluation surveys that aim to help us continuously assess and improve the service we offer;
- For the effective operation, evaluating and improving our service. This includes reporting, developing, enhancing, analysing and improving our services; managing our communications; performing data/statistical analysis; and performing accounting, auditing and other internal functions;
- To comply with and enforce all applicable legal requirements, relevant industry standards, contractual obligations and our policies;
- To generate invoices and process payment for services provided;
- To identify, protect against, and attempt to prevent fraud and other unlawful activity, claims and other liabilities;
- We use various IT resources and productivity tools, such as e-mail, to communicate with each other and with you. We keep a history of this for as long as is needed for follow-up, accountability and security. This data is stored and backed up on UK based servers;
- In order to optimise your user experience and to better tailor our offer to you, we use Cookies and similar technology, where permitted under law and consistent with our Cookie Policy.
All processing will be carried out based on adequate legal grounds which may fall into a number of categories, including:
- Fulfilment of Contract;
- Explicit consent from you, where required by applicable law e.g. when you tick a box to receive specific content. For certain processing we ask for your permission/consent in advance. If you do not give permission and/or object to the processing, this may have consequences for the service we provide to you;
- Legitimate interest e.g. letting the user access the website to be provided with the services offered. Please see our section on Legitimate Interests below to learn more about these interests and when we may process information in this way.
We may process personal data for certain legitimate business purposes, which includes some, or all, of the following:
- Where the process enables us to enhance, modify, personalise or otherwise improve our services/communications for the benefit of our clients, candidates and associates;
- To identify and prevent fraud;
- To enhance security of our network and information systems;
- To better understand how people interact with our websites;
- For emailing content appropriate to your resettlement;
- To determine the effectiveness of our communications;
Whenever we process data for these purposes we will ensure that we keep your rights in high regard and take account of these rights. You have the right to object to such processing (more details in section Your Rights as a Data Subject, above). Please bear in mind that if you exercise your right to object, this may affect our ability to carry out and deliver services to you for your benefit.
We maintain administrative, technical and physical safeguards designed to protect the personal data you provide against accidental, unlawful or unauthorised destruction, loss, alteration, access, disclosure or use.
We process the personal data we collect for the purposes defined in this notice and for a period only as long as necessary for the purposes we collected it; following this time all data is archived. Different laws and contractual obligations may also require us to process different data for different periods of time.
All data gathered by Right Management Limited, in association with the MoD agreement, is stored and backed up on UK based servers and treated with the strictest confidence and integrity.
We do not disclose personal data that we collect about you, except as described in this privacy notice or in separate notices provided in connection with particular activities.
We may share personal data with vendors who perform services on our behalf based on our instructions. When we use the services of other parties to process data on our behalf, we ensure due diligence takes place to ensure they are GDPR compliant and, where necessary, that processing agreements are in place with these parties, so that they too handle your personal data carefully. We never sell your data to third parties.
In addition, we may disclose personal data about you on the following basis:
- To law enforcement authorities or other government officials based on a lawful disclosure request;
- If we are required to do so by law or legal process;
- When we believe disclosure is necessary or appropriate to prevent physical harm or financial loss, or in connection with an investigation of suspected or actual fraudulent or illegal activity.
This privacy notice (including any addenda) may be updated periodically to reflect changes in our privacy practices and legal updates. For significant changes, we will notify you by posting a prominent notice on our Sites indicating at the top of each Notice when it was most recently updated.
If you have any questions/comments about this privacy notice, if you would like to exercise your rights, or you think you have identified any weakness or data privacy related concern on one of our Sites, please email us at:
[email protected]
Or write to us at:
The Data Privacy Officer
Right Management Ltd
50 Bank Street
Canary Wharf
London E14 5NS
United Kingdom