Privacy Notice

1. Introduction

This Privacy Notice aims to explain the types of personal data we may collect about you when you interact with us and use our website, Impact Energy Partners, including any data you may provide when you purchase products, goods and services or sign up to our newsletters.

It also explains how we will store and handle your data and keep it safe.

When you are using the Impact Energy Partners website, Impact Energy People Partners Limited (company registration No: 15779421 (England and Wales)) is the data controller.

We understand that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of all our customers and their employees and other people with whom we interact in the course of undertaking our services. This Privacy Notice offers both our customers and their employees with meaningful and accessible guidance on our approach to handling personal data.

2. Who are we?

Impact Energy Partners is a trading style of Impact Energy People Partners Limited, company registration No: 15779421 (registered in England and Wales), and part of Commercial Services Group (CSG).

CSG is the umbrella for all its trading brands, with its ultimate parent organisation being Kent County Council. It provides the support, dependability, and security to allow all brands to thrive independently. CSG are committed to providing an excellent customer and user experience underpinned by social value and a committed and empowered workforce.

Impact Energy Partners collects, uses and processes personal information about you. When we do we are regulated under the UK Data Protection Act 2018 (DPA 2018), the UK General Data Protection Regulation (UK GDPR) and the Data (Use and Access) Act 2025.

3. Our services

We collect your personal information in order to provide you with advice and employment opportunities.

We operate both temporary/contract and permanent recruitment services.

Temporary/contract recruitment

An assignment of temporary work placements with various clients across diverse industries and sectors.

Under the provision of temporary/contract recruitment that we may offer, we collect personal information and retain data to enable us to match you to suitable temporary/contract positions. If you are successful and receive an offer for temporary/contract work, we will process and retain your bank details, national insurance number and statutory tax details in order to fulfil the legal requirement under the HM Revenue and Customs (HMRC) Real Time Information (RTI) regulations.

Permanent recruitment

The provision of promoting and sharing candidate's personal details with clients, resulting in interviews and job offers/employment with those clients' organisation.

Under the provision of permanent recruitment that we may offer, we collect & retain personal data to enable us to match you to suitable permanent positions. If you are successful and receive an offer for permanent work, we will retain your data to fulfil our statutory legal requirements (Conduct of Employment Agencies and Employment Businesses Regulations 2003 (Conduct Regulations)).

In providing these services, it will be necessary for Impact Energy Partners to gather, obtain, record and hold your personal information.

4. Our legal bases to processing your personal information

There are a number of different legal bases that we may use in order to collect and/or process your personal information. These are listed below:

Legitimate Interest

We believe it is reasonable to expect that if you are looking for an employment opportunity and have applied via a jobs board, either directly through our website or via any other means then we have a legitimate interest to collect, use and process your data to offer or provide you with advice and employment services.

Where you have posted your CV on various jobs boards and made your personal data publicly accessible, then we may contact you in relation to either a specific vacancy or speculatively for future employment opportunities. In this instance, we will contact you and gain your consent to further process and retain your personal data.

Consent

We will collect and process your personal information with your consent. Examples of this are when you tick a box to receive job alerts on our website.

You may withdraw your consent at any time by contacting us at dpo@csltd.org.uk or by using the unsubscribe links in our direct marketing emails.

Contractual Obligation

When we have a contract with you we will collect and process your personal information in order to fulfil our contractual obligations. An example of this is where we have a contract for services with you. We will process your personal details to fulfil and manage the recruitment process.

Legal Obligation

We will use your personal information to comply with our legal obligations. This may mean that we need to provide your personal information to HMRC, DVLA and any other public authority. If requested we will provide the police with personal information to assist them with investigations.

5. The personal information we collect and use

The table below summarises the information we collect, use and retain for our services, how and why we do so, how we use it and with whom it may be shared.

We seek to ensure that our information collection and processing is always proportionate. We will notify you of any changes to information we collect or to the purposes for which we collect and process it.

As there is a statutory and contractual basis for collecting your personal data if you do not provide some or all of the details specified in the 'The personal information we collect and use' section, we may be unable to enter into a contract with your organisation.

6. How we use your information to make automated decisions

On some occasions, we may collect or process your personal information using automated decision-making systems (a decision made by automated means and without any human intervention). This enables us to make sure our decisions are quick, fair, efficient and correct, based on what we know. We do this because we want to provide us with communication patterns or summarised calls to improve record accuracy. Automated decision-making is not used without human review. AI is used to support processes not to make independent decisions about candidates. Human oversight is maintained.

We may utilise machine learning technology to match candidates CV information and experiences to various job opportunities based on the selection criteria outlined in job descriptions/specifications, as provided by the client, to create shortlists for reviewing against client vacancies.

Or used to create a candidate profile using publicly accessible information from other online sources (e.g. job boards, LinkedIn etc.). Where profiles are created, we will contact you and gain your consent to further process and retain your personal data for job seeking opportunities and recruitment services.

If you consent to receive Job and Blog alerts, we will use automated profiling based on your requirements, we do this because we want to provide you with information, products and services that are of interest and are most relevant to you.

The use of this type of technology helps us to make quicker and more consistent decisions, particularly in cases where large volume of data needs to be analysed and decisions made efficiently and effectively. These automated decisions can affect the services we may offer you now or in the future.

Automated decision making is allowed in the following circumstances:

1. Where we have notified you of the decision and given you 21 days to request a reconsideration.
2. Where it is necessary to fulfil our contractual obligations and requirements and appropriate measures are in place to safeguard your rights.
3. In limited circumstances, with your explicit consent and where appropriate measures are in place to safeguard your rights.

If an automated decision is made, based on any particularly sensitive personal information, we must have either your explicit written consent or it must be justified in the public interest, and we must put in place appropriate measures to safeguard your rights.

7. How long your personal data will be retained

We will not keep your information for longer than is necessary, for either:

• the purpose of administering your individual record;
• or as is necessary in providing a service to our customer;
• or as required by law.

Upon expiry, your data will either be deleted completely or anonymised, for example by aggregation with other data so that it can be used in a non-identifiable way for statistical analysis and business planning.

For certain data sets, we have the following specific retention periods:

• personal information processed under contractual obligations will be retained for 7 years beyond the date of your temporary last assignment or last permanent placement
• the personal information of temporary workers will be retained for 7 years to fulfil our HMRC obligations
• jobseeker personal information (e.g. CV) will only be retained for 24 months unless you have exercised your right for your personal information to be erased or you have objected to your information being processed
• we will hold your personal information for marketing purposes unless you have opted out or unsubscribed from receiving marketing information

8. Who we share your personal information with

We may share your personal data with the following organisations:

• With potential clients if we deem your application suitable for a role, we will inform you of the organisation and with your consent share your personal data with the hiring client.
• With umbrella companies to enable payment for contractual work.
• With the Cabinet Office National Fraud Initiative, for the purposes of assisting the prevention and detection of fraud under a legal obligation and the HM Revenue and Customs (HMRC) for the purposes of legal compliance with tax and HRMC regulations.

We may also share your personal information with trusted third parties that are under contract with us and where it is necessary to administer our working relationship with you or where we have another legitimate interest in doing so (providing this is not overridden by your interests).

Our trusted third parties may include service providers who supply us with processing services or functions, including our contracted IT suppliers, access to data and systems is only granted where authorised and specifically required in line with our contracts with them.

Management information may be shared within Commercial Services Group, under a Data Sharing Agreement held by its operating company Global Commercial Services Group Ltd, a company registered in England and Wales (Reg No. 11735631). This Agreement reflects the requirements of the UK GDPR, DPA2018 and DUAA2025.

We may also need to share some of the categories of personal information with other parties where a transfer of the business takes place. Usually, information will be anonymised or pseudonymised, but this may not always be possible. The recipient of the information will be bound by confidentiality obligations and legally binding data sharing agreements.

9. Where information may be retained

Information may be retained at our offices and those of our service providers, representatives and agents as described above.

Some of the personal information you provide to us may be transferred to countries outside of the UK, or the EU/EEA. Where this occurs, we will make restricted transfer under UK "adequacy regulations" to protect individuals rights and freedoms for their personal data.

Where the UK has no "adequacy regulations" then the restricted transfer will be subject to appropriate safeguards whereby standard contractual clauses have been entered into with the organisation receiving the data.

10. Your rights

Under the UK GDPR you have a number of rights which allow you to:

We will always seek to comply with your request however we may be required to hold or use your information to comply with legal duties.

You can also withdraw your consent and opt-out from direct marketing by using the unsubscribe link at the bottom of our marketing emails.

Suppression lists will be maintained to screen against direct marketing information being sent to people who have already exercised their right to object to direct marketing. These lists will be held for compliance purposes only, and this does not affect your rights to be erased.

For further information about your rights, including the circumstances in which they apply, see the guidance from the UK Information Commissioners Office (ICO) on individuals' rights under the UK General Data Protection Regulation at https://ico.org.uk/

If you would like to exercise a right or make a complaint about how your personal data is handled by Impact Energy Partners, please contact our DPO via email at dpo@csltd.org.uk or write to Data Protection Officer, Commercial Services Group, 1 Abbey Wood Road, Kings Hill, West Malling, ME19 4YT.

11. Keeping your personal information secure

We have appropriate security measures in place to prevent personal information from being accidentally lost, used or accessed in an unauthorised way. We limit access to your personal information to those who have a genuine business need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.

We also have procedures in place to deal with any suspected data security breach. We will notify you and the ICO as regulator of any suspected data security breach where we are legally required to do so.

12. Who to contact

If you have any questions, suggestions or complaints about the processing of your personal information, or you wish to exercise any of your rights please contact our Data Protection Officer (DPO):

The UK General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority. The supervisory authority in the UK is the Information Commissioner who may be contacted at https://ico.org.uk or telephone 0303 123 1113.

We reserve the right to update this Privacy Notice at any time, and we will provide you with a new Privacy Notice when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal information.