Our privacy policy.

Coburg Banks is a recruitment brand of The Angel Services Group Ltd. Recruitment services are provided by Coburg Banks IT Ltd, a group company registered in England and Wales with company number 05714291. Our office is at 15 Wrens Court, South Parade, Sutton Coldfield, B72 1RT.

The Angel Services Group Ltd is the controller of the personal information described in this policy, and is registered with the Information Commissioner's Office (ICO) under registration number ZA116467. Our group's recruitment brands are Coburg Banks, Response, Temps 4 Care and Recruits 4 Care. In this policy, "we" and "us" mean The Angel Services Group Ltd and these brands.

Anthony Hughes is responsible for data protection across The Angel Services Group, including Coburg Banks. You can contact him at [email protected], on 0121 362 2300, or by post at the address above.

This policy covers candidates, clients and their contacts, and visitors to our website. It explains what we collect, why, who we share it with, how long we keep it and your rights.

Candidates. To help you find work we may hold:

• your name, contact details, location and LinkedIn or other profile links;
• your CV and the information in it, such as your work history, education, qualifications, skills and references;
• details of the roles you are interested in, your salary expectations, notice period and availability;
• notes from our conversations with you, interview feedback and the outcome of applications;
• right to work documents, and any other checks a role legally requires; and
• anything else you choose to send us.

Clients and contacts. Names, job titles, work contact details, details of the roles you are recruiting for, and records of our dealings with you.

Website visitors. Information you enter in our forms, and technical data such as your IP address, browser, device and the pages you visit, collected through cookies and similar technologies. Our Cookie Policy explains these and how to control them.

Special category information. We do not ask for information about your health, ethnicity, religion, sexual orientation or similar unless there is a clear reason, for example to make reasonable adjustments for an interview, or where you choose to include it in your CV. Where we process it, we do so only as the law allows, such as to meet employment law obligations or with your explicit consent. We only process information about criminal convictions where a role legally requires a check, and only as the law permits.

Most of it comes from you, when you apply for a role, send us your CV, register with us, fill in a form or speak to us.

We also collect it from other sources, including job boards and CV databases you have posted your details on, professional networking sites such as LinkedIn, referrals and references, and our clients (for example interview feedback). If we obtain your details from somewhere other than you, we will tell you within a month, at the latest when we first contact you, and point you to this policy.

Data protection law says we must have a lawful basis for each way we use your information. Ours are:

• Legitimate interests, which is our main basis for recruitment. It is in our interests, and normally in yours as a candidate, for us to find you suitable roles, assess your suitability, put you forward to clients, arrange interviews and keep in touch about relevant opportunities. For clients, it covers managing our relationship and telling you about candidates and services. We have assessed these interests against your rights and you can object at any time (see Your rights).
• Contract, where we need your information to provide a service you have asked for, or to enter into or carry out a contract with you, including terms of business with clients and arrangements with candidates we place.
• Legal obligation, for example checking right to work, keeping records required by the Conduct of Employment Agencies and Employment Businesses Regulations 2003, tax and accounting rules, and responding to lawful requests from authorities.
• Consent, where we ask for it for a specific purpose, such as some marketing emails or non-essential cookies. You can withdraw consent at any time; this does not affect anything we did before you withdrew it.

We will only put your CV forward to a client for a specific role after we have discussed that role with you.

We use artificial intelligence (AI) tools to help our recruiters work more efficiently. These tools may be used to:

• reformat CVs into our house style and apply our branding;
• anonymise CVs by removing names, contact details and other identifying information before they are shared with clients;
• summarise, shorten or tidy the wording of a CV, without adding experience or skills you do not have;
• draft job adverts, emails and notes; and
• check documents for missing information or inconsistencies.

A person always makes the decisions. We do not use AI to decide whether you are suitable for a role, to shortlist or reject you, or to make any other decision about you without meaningful human involvement. A Coburg Banks recruiter reviews any AI-assisted document before it is used or sent to a client, and remains responsible for it.

Who provides the AI. We use AI services from established providers, such as Anthropic (Claude) and OpenAI, only through their business API services, never through consumer chat apps. They process your information on our behalf and only on our instructions, under data processing terms that prohibit them from using it to train their AI models. They may keep it for a limited period for security and to prevent misuse, then delete it. These providers are based in the United States; see International transfers for how your information is protected.

Our lawful basis for using AI in this way is our legitimate interest in running an efficient recruitment service and presenting candidates to clients clearly and consistently, which also helps candidates by getting their details in front of employers faster. We only send the AI tools the information needed for the task.

If you would prefer that your CV is not processed using AI tools, email [email protected] and we will handle it manually. This will not affect the roles we put you forward for. You can also use the same address to ask us to keep your details within Coburg Banks only, rather than sharing them across our group's brands.

We never sell your personal information. We share it only where needed:

• Clients: with candidates' agreement, we share CVs and relevant details with prospective employers for specific roles. Where we send an anonymised CV, we remove your name, contact details and other details that would identify you.
• Service providers who process information on our behalf under contract, including IT, email and cloud hosting, recruitment software and databases, AI providers (see How we use AI tools), job boards, background and right to work checking services, payroll and accounting providers, and professional advisers.
• Our other group brands: we make candidates' CVs and details available across our group's recruitment brands (Coburg Banks, Response, Temps 4 Care and Recruits 4 Care) so you can be considered for roles any of them are recruiting for. Your information is used only for recruitment and in line with this policy. You can ask us to limit your details to Coburg Banks only.
• Authorities and regulators, such as HMRC, the Home Office or the police, where the law requires it.
• A buyer of our business, if we sell or merge all or part of it, in which case your information would continue to be protected in line with this policy.

Our main systems are in the UK, but some service providers, including our AI providers, process information outside the UK, mainly in the United States. When this happens we make sure your information is protected to a standard not materially lower than in the UK, by using the UK-US data bridge where the recipient is certified under it, or the UK International Data Transfer Agreement or Addendum, together with the provider's own security measures. You can contact us for more information about these safeguards.

We keep information only as long as we need it:

• Candidates: 12 months from our last meaningful contact with you, after which we delete or anonymise your information unless you ask us to keep it. You can ask us to delete it sooner.
• Candidates we place: records needed for legal, tax and contractual reasons are kept for up to six years after the placement ends.
• Clients: for as long as we have a business relationship and up to six years afterwards for contract and accounting purposes.
• AI processing: documents created with AI tools are kept in the same way as the CV or record they relate to. The AI providers do not keep them beyond the limited period described above.

We use appropriate technical and organisational measures to protect your information, including access controls so that only staff who need it can see it, secure sign-in to our systems, encryption in transit, and contracts with our service providers requiring them to keep it secure. No system is completely secure, but if a breach happens that is likely to put you at risk, we will tell you and the ICO as the law requires.

You have the right to:

• access the personal information we hold about you and get a copy of it;
• correct information that is inaccurate or incomplete;
• delete your information, where we have no good reason to keep it;
• restrict how we use your information in some circumstances;
• object to us using your information on the basis of legitimate interests, including the use of AI tools, and to stop direct marketing at any time;
• data portability, to receive information you gave us in a common electronic format or have it sent to another organisation, where the law allows;
• withdraw consent where we rely on it; and
• ask for human review of any decision about you, and express your view or challenge it. We do not make decisions about you using solely automated means.

To use any of these rights, contact us using the details in Who we are. We will respond within one month, and there is normally no charge. We may need to confirm your identity first.

To stop marketing emails, use the unsubscribe link in any email or contact us.

If you are unhappy with how we have handled your personal information, please tell us first by emailing [email protected] with the subject line "Data protection complaint", or by writing to us at the address above. We will acknowledge your complaint within 30 days, look into it, keep you updated and tell you the outcome without undue delay.

You also have the right to complain to the Information Commissioner's Office (ICO) at ico.org.uk or on 0303 123 1113. The ICO usually expects you to have raised the matter with us first.

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Our website may link to sites we do not run. We are not responsible for their content or privacy practices, so please read their privacy policies.

We review this policy regularly and will update it when the way we handle personal information or the law changes. The date at the top shows when it was last updated. If we make a significant change, we will tell you where appropriate.

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