PRIVACY & MODERN SLAVERY STATEMENTS
The term ‘Sparta Global’ or ‘us’ or ‘we’ refers to the owner of the website, Sparta Global Limited, whose registered office is 6thFloor, 125 London Wall, EC2Y 5AS, under company’s registration number 5597367, registered in England and Wales. For the purposes of data protection legislation in force from time to time, the data controller is Sparta Global Limited.
All material published on the website is published in good faith, however we cannot guarantee or warrant representation of accuracy or reliability of such information. This website is for information only unless otherwise stated. There is no guarantee expressed or otherwise, that the contents or operation of the website will be error-free. Although it may be possible to obtain access to other websites from this website, there is no endorsement or responsibility for those websites, their contents or any damage or loss arising out of those websites. We reserve the right to modify, update or close this website at any time.
Those who choose to access this website are responsible for the compliance to the laws applicable. This notice and disclaimer are governed by and construed in accordance with the English laws.
At Sparta Global Limited we are committed to and hugely passionate about protecting and respecting your privacy. Whether you deal with us as a Spartan, Candidate, Client, Supplier or Partner we will always make sure we do the right thing.
The General Data Protection Regulation (GDPR) (Regulation (EU) 2016/679) is a relatively recent regulation which has replaced the Data Protection Regulation (Directive 95/46/EC). The Regulation aims to harmonise data protection legislation across EU/EEA member states, enhancing privacy rights for individuals and providing a strict framework within which commercial organisations can legally operate. We welcome this piece of legislation as it’s all about understanding you and putting you first, which is what we do every single day.
Even though the UK has expressed its intention to leave the EU in March 2019, the Government intends for the GDPR to continue in UK law post Brexit and has also introduced a Data Protection Bill to replace the current Data Protection Act.
Our Legitimate Business Interests
Our legitimate interests in collecting and retaining your personal data is described below:
As a Business Consulting Services provider, we introduce our Spartans and Candidates to clients for temporary work placements, permanent placements or through service provider agreements.
The exchange of personal data of our candidates, Spartans and our client contacts are a fundamental and essential part of this process.
In order to support our Candidates’ and Spartans’ career aspirations and our clients’ resourcing needs we require a database of personal data containing historical information as well as current resourcing requirements.
To successfully match our Candidates and Spartans with the clients we need to retain information such as name, contact details, location, job title, area of expertise and additionally for candidates their curriculum vitae, education and training data, identification and right to work documents, salary and rate details.
To deliver our ancillary services we need to detail and map different market sectors with their relevant companies. We make note of organisation’s structures and who is currently employed in certain roles. This then facilitates the necessary understanding of who is responsible for the relevant teams and/or who may be the best point of contact to progress our working relationship further.
This is data about you that you give us by filling in forms on our third-party providers such as HR Systems, CRM Systems and Background Screening Systems or by communicating with us by phone, video calls, e-mail, personal meetings or otherwise. It includes information you provide when you register to use our site, to enter our database, subscribe to our services, attend our events, enter a promotion or survey, and when you report a problem with our site.
The information you give us or we collect about you may include your name, address, company name, private and corporate e-mail address and phone number, financial information, compliance documentation and references verifying your qualifications and experience and your right to work in the relevant country, identification documents, curriculum vitae and photograph, emergency information, links to your professional profiles available in the public domain e.g. LinkedIn, Twitter, business Facebook or corporate website.
When you register with Sparta Global you may elect to have information about jobs, marketing, opportunities or other Sparta Global services sent to your email address. The information you provide when registering is stored in our internal systems and is controlled and processed by dedicated members of staff.
Disclosure of Personal Data
Sparta Global may disclose some of these details to our internal teams and, if required, our end Client. We may also share your data with any Government or regulatory authority as may be necessary from time to time in order to comply with any statutory obligations or regulatory requirements. We might share your personal information with members of our group both in the EEA and outside of the EEA.
Selected third parties including:
Clients for the purpose of introducing candidates;
Candidates for the purpose of arranging interviews and engagements;
Clients, business partners, suppliers and sub-contractors for the performance and compliance obligations of any contract we enter into with them or you;
Analytics and search engine providers that assist us in the improvement and optimisation of our site;
Credit reference agencies, our insurance broker, compliance verification partners and other sub-contractors for the purpose of assessing your suitability for a role where this is a condition of us entering into a contract with you.
We will disclose your personal information to third parties:
If Sparta Global Limited or substantially all of its assets are acquired by a third party, in which case personal data held by it about its clients will be one of the transferred assets.
The lawful basis for the third-party processing will include:
Their own legitimate business interests in processing your personal data, in most cases to fulfill their internal resourcing needs;
The satisfaction of their contractual obligations to us as our data processor;
For the purpose of a contract in place or in contemplation;
To fulfill their legal obligations.
Personal Data Retention, Storage, Access & Rights
We understand our legal duty to retain accurate data and only retain personal data for as long as we need it for our legitimate business interests (in-line with LIA) and that you haven’t requested your data to be removed. Accordingly, we have a data retention notice and run data routines to remove data that we no longer have a legitimate business interest in maintaining.
We do the following to try to ensure our data is accurate:
Prior to making an introduction, we check that we have accurate information about you
We keep in touch with you, so you can let us know of changes to your personal data
We will contact you at least once every two years in an attempt to update your information on our database
We segregate our data so that we keep different types of data for different time periods. The criteria we use to determine whether we should retain your personal data includes:
The nature of the personal data;
Its perceived accuracy;
Our legal obligations;
Whether an interview or placement has been arranged; and
Our consultancy expertise and knowledge of the industry by country, sector and job role.
We may pseudonymise parts of your data, particularly following a request for suppression or deletion of your data, to ensure that we do not re-enter your personal data on to our database unless requested to do so.
For your information, pseudonymised data is created by taking identifying fields within a database and replacing them with artificial identifiers, or pseudonyms.
Our current retention notice is available upon request.
You have the right to ask us not to process your personal data for marketing purposes. We will usually inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes and we will collect express consent from you if legally required prior to using your personal data for marketing purposes.
You can exercise your right to accept or prevent such processing by checking certain boxes on the forms we use to collect your data. You can also exercise the right at any time by contacting us at email@example.com
Our site may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
Information we obtain from other sources
We also obtain information about you from other sources such as LinkedIn, Google natural search and other corporate websites, job board websites, online CV libraries, your business card and personal recommendations. In this case we will inform you, by sending you this privacy notice, within a maximum of 30 days of collecting the data of the fact we hold personal data about you, the source the personal data originates from and whether it came from publicly accessible sources, and for what purpose we intend to retain and process your personal data.
We are working closely with third parties including business partners such as management and umbrella companies, search information providers and general Background Screening Companies. We may receive information about you from them for the purposes of our consultancy services and ancillary support services.
Technology related to information collection
Third-Party Services related to information collection
Google Analytics. We have enabled Google Analytics to collect data about our traffic through the use of Google Advertising Cookies and other Anonymous Identifiers. We use Google Analytics Cookies and other Cookies to compile data to better understand Users and provide Users with a more tailored experience. You can opt out of Google Analytics by visiting Google’s Opt-Out Browser Add-on website.
What can you do if you are not happy with the way that your information has been processed?
If you are dissatisfied with how Sparta Global uses your data you can make a complaint to the government body in charge (Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF or atwww.ICO.org.uk).
Quality Systems & Information Management Systems
Sparta Global is ISO 27001 and ISO 9001 certified for quality and information security management systems. An ISMS is a framework of policies and procedures that includes all legal, physical and technical controls involved in an organisation’s information risk management processes.
SPARTA GLOBAL LIMITED STATEMENT AGAINST MODERN SLAVERY
At Sparta Global we believe in the importance of equality in the workplace. Being a responsible corporate citizen is not only the right thing to do, it is good for the long-term viability of our business. We are committed to preventing acts of modern slavery and human trafficking from occurring within our business and the supply chain. We believe employment should be chosen. There must be no forced, bonded or involuntary prison labour. Supplier employees must not be required to lodge monies or identity papers in order to work and must be free to leave employment after the giving of reasonable notice.
Our Operations and People Director provides constant support to all members of staff and ensures all employees and Trainees are getting the relevant training and development needed in order for them to achieve all they can here at Sparta Global. We pride ourselves highly on promoting human rights within the business and ensure all members of staff are happy and content within their working environment. We encourage weekly catch ups and constant suggestions via our company portal on how we can strengthen the ways in which we protect our employees’ rights and company benefits.
We hold our suppliers, business partners and all other stakeholders to the same standards that we hold ourselves. We run a safe and ethical business that extends well beyond Sparta Global. Our code of conduct is an overview of the guiding principles and values which govern how we make ethical decisions in conducting our business.
Please see below the following steps we have taken and continue to take in adherence to the Modern Slavery Act:
Our supply chain is not very complex however we work with a vast range of suppliers that provide services across a number of varied categories that range from cyber security, IT, telecoms, technology sales, data analytics and other services which can be seen on our company website. We keep very respectable relationships with our suppliers which allows us to have a good understanding and visibility of our supply chain.
Due to the strong relationships we have with our suppliers and contractors and Spartans we consider the risk of exploitation, human trafficking and breach of human rights very low. Nonetheless we are committed to ensuring such occurrences do not take place within our business or supply chain due to our procedures and due diligence.
Our contracts include a provision for all suppliers to warrant that it has not and will not engage in any activity, practice or conduct which would constitute an offence under the Modern Slavery Act 2015.
All Sparta Global employees have access to channels in which they can communicate concerns, via local reporting mechanisms or internal whistleblowing procedures, which encourage all staff to report any wrong behaviour or breaches of our policies. Sparta Global are committed to protecting its employees when disclosing malpractice and we take this very seriously. All employees must be provided with a clear contract of employment which complies with local legislation. All contracts are received before employees join Sparta Global which gives new employees the opportunity to read through all of our company policies and raise any queries prior to starting, which encourages a smooth onboarding process for all parties.
Sparta Global hold a zero-tolerance policy on Modern Slavery and are committed to the highest level of ethical standards. A
ll employees are under duty to comply and understand this policy. The prevention, detection and reporting of modern slavery and human trafficking within businesses or any supply chains is the responsibility of those working for Sparta Global. Employees are encouraged to avoid any behaviour that would suggest a clear breach of this policy.
Verification and Risk Assessment
Sparta Global require a due diligence process of supply chain risk based on international indices, supplier performance and other indicators of suppliers and contractors and have a supporting audit process. Our standard supplier contracts contain Compliance with Laws provisions which oblige the parties to comply with all laws applicable to their activities under the contract.
Verification of code conformance and assurance through our own supplier audit process including demonstration from our supply chain that they have passed down Sparta Global’ requirements to their own suppliers and contractors and have supporting audit process.
Sparta Global ensure that any updates of changes to our code of conduct in relation to modern slavery and human trafficking are fed to all employees and all necessary and/or recommended training takes place. All employees within any Sparta Global group subsidiary are expected to comply with all laws and act in accordance with local guidelines and regulations and act with integrity and honesty.