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Our Website and Data Policy


From 25 May 2018, the General Data Protection Regulation 2016 will come into force, this replaces the Data Protection Act 1998.

CLS (UK) Infrastructure Limited’s privacy and data policy sets out the basis on which we process any personal data that we collect from you or about you that you provide to us or that we receive from other sources. If we ask you to provide information from which you can be identified, including as a result of using our website, it will be used in accordance with this privacy policy.

Catherine Fell at CLS has been appointed our Data Protection Officer and she will undertake this role following the principles laid down by the GDPR. She will also be involved in processing any information data. Any issues/queries relating to the regulations and data should be addressed in writing to Catherine Fell. CLS is registered as a data controller with the Information Commissioner’s Office under ICO registration reference: ZA398315, company number 9201504.


About the Website

 *References made to: "The Company" within this document refer to CLS Construction Labour Solutions (UK) Infrastructure LTD.

What information do we collect?

The Company is a recruitment business which provides work-finding services to its clients and work-seekers. The Company must process personal data (including sensitive personal data) so that it can provide these services – in doing so, the Company acts as a data controller.

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


1. Collection and Use of Personal Data

a. Purpose of Processing and Legal Basis


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

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

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

Your consent

Where we have a legitimate interest

To comply with a legal obligation that we have

To fulfil a contractual obligation that we have with you

b. Legitimate Interest


This is where the Company has a legitimate reason to process your data provided it is reasonable and does not go against what you would reasonably expect from us.

Where the Company has relied on a legitimate interest to process your personal data our legitimate interests is/are as follows:

  • Managing our database and keeping work-seeker records up to date

  • Contacting the individual to seek your consent where it is needed

  • Providing work-finding services to the individual, including sending your information to our clients where they have demonstrated an interest in doing that particular type of work but not expressly consented to you passing on their CV

  • Contacting the individual with information about similar products or services that they have used from you recently

  • Passing work-seeker’s information to debt collection agencies


c. Recipient/s of Data


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

Clients that we introduce and supply individuals to

Candidates’ former or prospective new employers that you obtain or provide references to

Any umbrella companies that we pass candidate data to

Our insurers

Our legal advisers

  • Any public information sources and third-party organisations that we may use to carry out suitability checks on work-seekers e.g. Companies House, the Disclosure and Barring Service (DBS), National College for Teaching and Leadership (NCTL), Nursing and Midwifery Council (NMC), General Medical Council (GMC), DVLA, credit reference agencies

  • Government, law enforcement agencies and other regulators e.g the Police, Home Office, HMRC, Employment Agencies Standards Inspectorate (EASI), Local Authority Designated Officers (LADOs), GLAA,

  • Any other organisations an individual asks you to share their data with.


d. Statutory/Contractual Requirement


Your personal data is required by law and/or a contractual requirement (e.g. our client may require this personal data), and/or a requirement necessary to enter into a contract. You are obliged to provide the personal data and if you do not the consequences of failure to provide the data are:

  • Delays in Payment

  • Unable to introduce or supply individual to Clients


 2. Data Retention


The Company will retain your personal data only for as long as is necessary for the purpose we collect it. Different laws may also require us to keep different data for different periods of time.

The Conduct of Employment Agencies and Employment Businesses Regulations 2003, require us to keep work-seeker records for at least one year from (a) the date of their creation or (b) after the date on which we last provide you with work-finding services.

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

Where the Company has obtained your consent to process your personal and sensitive personal data, we will do so in line with our retention policy. Upon expiry of that period the Company will seek further consent from you. Where consent is not granted the Company will cease to process your personal data and sensitive personal data.


3. Your Rights


Your rights in relation to your personal data: Under Data Protection Laws you have the following rights in relation to your personal data:


  • right to access your personal data by subject access request;

  • right to have your personal data rectified if inaccurate/incomplete;

  • right to object to direct marketing;

  • in certain circumstances, the right:

  • to have your data erased or removed, and where the personal data has been made public, that other controllers processing the personal data also erase links to, or copy or replication of, such personal data;

  • to restrict the processing of your data;

  • of data portability, namely to obtain and reuse your data for your own purposes across different services;

  • to not be subjected to automated decision making (including profiling) where it produces a legal effect or a similarly significant effect on you; and

  • the right to bring a civil action if there is a breach of the Data Protection Laws.

Where you have consented to the Company processing your personal data and sensitive personal data you have the right to withdraw that consent at any time by contacting our Data Protection Officer, Catherine Fell.

There may be circumstances where the Company will still need to process 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 reasons.

If you believe that any of your data that the Company processes is incorrect or incomplete, please contact us using the details above and we will take reasonable steps to check its accuracy and correct it where necessary.

You can also contact us using the above details if you want us to restrict the type or amount of data we process for you, access your personal data or exercise any of the other rights listed above.


Security of your information

We take our duty to protect your personal information and confidentiality seriously. We are committed to taking all reasonable measures to ensure the confidentiality and security of personal data for which we are responsible, whether computerised or on paper.

All staff are required to undertake annual information governance training and are provided with an information governance user handbook that they are required to read, understand and agree to adhere to. The handbook ensures that staff are aware of their information governance responsibilities and follow best practice guidelines ensuring the necessary safeguards and appropriate use of person-identifiable and confidential information.

Everyone working for The Company is subject to the common law duty of confidentiality. Information provided in confidence will only be used for the purposes advised and consented to by the service user, unless it is required or permitted by the law.


By entering your details in the fields requested, you enable The Company and its service providers to provide you with the services you select. Any information you provide to The Company will only be used by us, our agents and service providers and will not be disclosed unless we are obliged or permitted to by law to do so.


The types of personal information we use include:

Examples of personal data that you may provide to us when accessing this Website or when otherwise communicating or interacting with The Company, and which we may collect and process, are:


  • personal details such as: your name, address, email address, telephone number and occupation;

  • employment details such as:  length of service or employment history/ curriculum vitae were provided by you in relation to any application for a role made by you via this Website where you have applied for a role via the “Candidates” section on this Website and provided explicit consent via a separate consent form referencing this privacy notice;

  • employee referrer name and email address details and name and email address contact details of prospective referral applicants for job applicant referrals where individuals being referred have provided explicit consent via a separate consent form referencing this privacy notice;

  • details in relation to you or personal of The Company, its clients, customers, suppliers, subcontractors, business partners or joint venture partners or members of the public in respect of whistleblowing reports, reported concerns or non-compliance with Our Code of Conduct in accordance with our separate privacy policy set out at Privacy and Data Protection.

Privacy and sharing of your information

We take the privacy of your data very seriously. Unless stated as part of the service we do not share your information with any third parties.

There are a number of reasons why we might share information.


This can be due to:

Our obligations to comply with current legislation

Our duty to comply with a Court Order

You have consented to disclosure


The Data Protection Act and GDPR

Under the Data Protection Act and General Data Protection Regulation, we have a legal duty to protect any information we collect from you. We use leading technologies and encryption software to safeguard your data and keep strict security standards to prevent any unauthorised access to it.

We do not pass on your details to any third party.


Use of cookies

When we provide services, we want to make them easy, useful and reliable. Where services are delivered on the internet, this sometimes involves placing small amounts of information on your device, for example, computer or mobile phone. These include small files known as cookies. They cannot be used to identify you personally.


These pieces of information are used to improve services for you through, for example:

Enabling a service to recognise your device so you don’t have to give the same information several times during one task

Recognising that you may already have given a username and password so you don’t need to do it for every web page requested

Measuring how many people are using services, so they can be made easier to use and there’s enough capacity to ensure they are fast.

You can manage these small files yourself through your browser setting.


Please note that the cookie providers listed below may distribute the gathered cookie information with other third-party websites for the purpose of activity tracking. You can find out more about the policy of each cookie provider on their respective privacy pages.


Current cookies

As an example, we use the following cookies on some of our services (please be aware the below suppliers may change their cookie names without notice):


Cookie: Google Analytics

Example name: _utma, _utmb, _utmc, _utmz, GAPS, LSID, LSOSID, OTZ

Purpose:   These cookies are used to collect information about how visitors use our websites, which we use to help improve them. The cookies collect information in an anonymous form, including the number of visitors to the site, where visitors have come to the site from and the pages they visited. More information about Google cookies.


Cookie: YouTube

Example name: PREF, VISITOR_INFO1_LIVE, use_hitbox

Purpose: To track visitor views, and to remember user preferences when viewing YouTube videos embedded in our websites.   More information about YouTube cookies.

Third party cookies

This website uses a number of supplies who also set cookies on our website on our behalf in order to deliver the services that they are providing. A list of all third-party cookies that are used on this website and what each is used for appears below.


Social media & sharing tools


This website utilises social media and sharing tools throughout the website including but not limited to Facebook, Twitter, YouTube, LinkedIn, StumbleUpon, Digg and Delicious. Using these elements of the website allows these service providers to set cookies on your device and track your behaviours within their platforms. Social media and sharing tool providers may also detect your presence on this website if you are logged into their services. The cookies set and tracking carried out by these third-party providers is not under our control.


How to control and delete cookies

We will not use cookies to collect personally identifiable information about you.

However, if you wish to restrict or block the cookies which are set by our websites, or indeed any other website, you can do this through your browser settings. The ‘Help’ function within your browser should tell you how.

Alternatively, you may wish to visit which contains comprehensive information on how to do this on a wide variety of browsers. You will also find details on how to delete cookies from your machine as well as more general information about cookies.

Please be aware that restricting cookies may impact on the functionality of our services.

If you wish to view your cookie code, just click on a cookie to open it. You’ll see a short string of text and numbers. The numbers are your identification card, which can only be seen by the server that gave you the cookie

For information on how to do this on the browser of your mobile phone you will need to refer to your handset manual.

To opt-out of third-parties collecting any data regarding your interaction on our services, please refer to their websites for further information.


Data Export and Removal Requests

Information we hold about you can be exported or removed at any time. To put in a request please contact us

IT Data Security

This section of our Data Policy is dedicated to ensuring the security and integrity of our digital information. At CLS, we implement a range of security measures designed to protect our data against unauthorised access, alteration, or destruction. Key strategies include robust access controls, data encryption, and the regular updating of security protocols in line with emerging threats and technological advancements.


Our commitment to data security extends to all levels of the organisation. Employees, contractors, and third-party partners are expected to adhere to our security guidelines and participate in regular training sessions to stay informed about best practices and potential risks. This overarching approach ensures that our data remains secure, confidential, and available to authorised users, thereby maintaining the trust of our stakeholders and complying with applicable data protection regulations.

Changes to our policy

If our privacy policy changes in any way, we will place an updated version on this page. Regularly reviewing the page ensures you are always aware of what information we collect, how we use it and under what circumstances, if any, we will share it with other parties.


Policy changes


This policy replaces all previous versions and is correct as at January 2024. We reserve the right to change the policy at any time. Any changes to this policy will be posted here.

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