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Company Name:  Jaymes Byron Talent Ltd (‘the Company’)

Company Contact details:  Sebastian Volney, support@jaymesbyron.co.uk, +44(0)20 7046 94294

Document DP1:  Privacy Notice

Topic:  Data protection

Date:  01/01/2021

Version:  V2


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 this privacy statement. At all times we will comply with current data protection laws.



  1. Collection and use of personal data
    • Purpose of processing and legal basis
    • Legitimate interest
    • Statutory/contractual requirement
    • Recipients of data
  2. Information to be provided when data is not collected directly from the data subject
    • Categories of data
    • Sources of data
  3. Overseas transfers
  4. Data retention
  5. Your rights
  6. Cookies
  7. Login files
  8. Links to external websites
  9. Sale of business
  10. Data security
  11. Changes to this privacy statement
  12. Complaints or queries
  13. Appendix I: Cookie Policy
  14. Appendix II: Retention Policy


Collection and use of personal data

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.

We must have a legal basis to process your personal data. The legal bases we rely upon to offer our work-finding services to you are:

  • Your consent
  • Where we have a legitimate interest


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;
  • Providing work-finding services to you and our clients;
  • Contacting you to seek your consent where we need it;
  • Giving you information about similar products or services that you have used from us recently


Statutory/contractual requirement

The Company has certain legal and contractual requirements to collect personal data (e.g. to comply with the Conduct of Employment Agencies and Employment Businesses Regulations 2003, immigration and tax legislation, and in some circumstances safeguarding requirements.)  Our clients may also require this personal data, and/or we may need your data to enter into a contract with you. If you do not give us personal data we need to collect we may not be able to continue to provide work-finding services to you.


Recipient/s of data

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

  • Clients (whom we may introduce or supply you to)
  • Former employers whom we may seek references from
  • Payroll service providers who manage payroll on our behalf or other payment intermediaries whom we may introduce you to
  • Other recruitment agencies in the supply chain
  • “Recruit So Simple”, who as CRM provider, acts as The Company’s data processor


Information to be provided when data collected not from the data subject

Categories of data: The Company may collect, use and store the following personal data on you:

Personal data:

  • Name
  • Date of birth
  • Contact details, including telephone number, email address and postal address
  • Experience, training and qualifications
  • CV
  • National insurance number
  • LinkedIn Profile
  • Nationality (through right to work check)


Sensitive personal data:

  • Health information including whether you have a disability (In order to ensure inclusivity with Clients)
  • Criminal conviction


Source of the personal data: Where we have not received data from you directly, The Company will have sourced your personal data/sensitive personal data from one of the following. If this is the case, we will communicate the details of this to you in writing:

  • From LinkedIn
  • Job Boards or online CV libraries
  • A former employer
  • A referee whose details you previously provided to us
  • Cookies listed in section 7


Overseas Transfers [Optional]

The Company will not transfer the information you provide to us to countries outside the European Economic Area (‘EEA’) for the purposes of providing you with work-finding services. The EEA comprises the EU member states plus Norway, Iceland and Liechtenstein.


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. For example, 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. This is currently 3 to 6 years.

Where the Company has obtained your consent to process your personal data and sensitive personal data we will do so in line with our Retention Policy as set out below, Appendix II. 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/sensitive personal data.


Your rights

Please be aware that you have the following data protection rights:

  • The right to be informed about the personal data the Company processes on you;
  • The right of access to the personal data the Company processes on you;
  • The right to rectification of your personal data;
  • The right to erasure of your personal data in certain circumstances;
  • The right to restrict processing of your personal data;
  • The right to data portability in certain circumstances;
  • The right to object to the processing of your personal data that was based on public or legitimate interest;
  • The right not to be subjected to automated decision making and profiling; and
  • The right to withdraw consent at any time.

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 Sebastian Volney, at support@jaymesbyron.co.uk. Please note that if you withdraw your consent to further processing, that does not affect any processing done prior to the withdrawal of that consent, or which is done according to another legal basis.

There may be circumstances where the Company will still need to process your data for legal or official reasons. Where this is the case, we will tell you and we will restrict the data to only what is necessary for 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.



We may obtain data about you from cookies.  Please refer to Appendix I, our Cookie Policy below.


Login Files

We use IP addresses to analyse trends, administer the site, track users’ movements, and to gather broad demographic information for aggregate use.  IP addresses are not linked to personally identifiable information.


Links to external websites

The Company’s website may contain links to other external websites. Please be aware that the Company is not responsible for the privacy practices of such other sites.  When you leave our site, we encourage you to read the privacy statements of each and every website that collects personally identifiable information.  This privacy statement applies solely to information collected by the Company’s website. 


Sale of business

If the Company’s business is sold or integrated with another business your details may be disclosed to our advisers and any prospective purchasers and their advisers and will be passed on to the new owners of the business.


Data Security

The Company takes every precaution to protect our users’ information. SSL Encryption, username and passwords secure data transferred from the Company website. All data is then stored via our highly secure Data Processor system, details of which can be viewed via https://recruitsosimple.com/gdpr/.

Only employees who need the information to perform a specific job (for example, consultants, our accounts clerk, and marketing assistant) are granted access to your information, and use of usernames and passwords are used to limit access.

The Company uses all reasonable efforts to safeguard your personal information. However, you should be aware that the use of email/ the Internet is not entirely secure and for this reason, the Company cannot guarantee the security or integrity of any personal information which is transferred from you or to you via email/ the Internet.

If you share a device with others, we recommend that you do not select the “remember my details” function when that option is offered.

If you have any questions about the security at our website, you can email Sebastian Volney at support@jaymesbyron.co.uk


Changes to this privacy statement

We will update this privacy statement from time to time.  We will post any changes on the statement with revision dates.  If we make any material changes, we will notify you.


Complaints or queries

If you wish to complain about this privacy notice or any of the procedures set out in it, please contact; Sebastian Volney, Managing Director at support@jaymesbyron.co.uk

You also have the right to raise concerns with Information Commissioner’s Office on 0303 123 1113 or at https://ico.org.uk/concerns/, or any other relevant supervisory authority should your personal data be processed outside of the UK, if you believe that your data protection rights have not been adhered to.






A cookie is a small text file that a website saves on your computer or mobile device when you visit the site. In general, cookies have two main purposes: to improve your browsing experience by remembering your actions and preferences and to help us analyse our website traffic.

What to do with Cookies?

We use cookies to help us analyse traffic to the Website, to help us improve website performance and usability, and to make the Website more secure. Third-party cookies help us use Google Analytics to count, track and analyse visits to the Website. This helps us understand how people are using our websites and where we need to make improvements. These third-party cookies do not specifically identify you.

Types & Categories of Cookies used

List category of cookies used in https://jaymesbyron.co.uk/


If you sign in to https://jamesbyron.com, cookies help us show users the right information and personalise the experience for the users.


We use cookies to enable and support our security features, and to help us detect malicious activity violations of our Terms and Conditions.

Performance, Analytics, Research & Advertising

Cookies help us learn how well our site and web products perform in different locations. We also use these to understand, improve, and research products, features, and services, including when you access this site https://jamesbyron.com/ from other websites, applications, or devices such as your work computer or your mobile device. We also use third-party cookies to improve and personalize our marketing messages/communications with you.

Control cookies

You are always free to delete cookies that are already on your computer through your browser settings, and you can set most browsers to prevent them from being added to your computer. However, this may prevent you from using certain features on the Website.




This policy sets out how long employment/recruitment-related information will normally be held by us and when that information will be confidentially destroyed.


Sebastian Volney, Managing Director is responsible for implementing and monitoring compliance with this policy.
They will undertake an annual review of this policy to verify that it is in effective operation.

Our process

Information (hard copy and electronic) will be retained for the period specified in our Records Retention Schedule.
All information must be reviewed before destruction to determine whether there are special factors that mean destruction should be delayed, such as potential litigation, complaints or grievances.
Hard copy and electronically-held documents and information must be deleted at the end of the retention period unless there is a requirement to delay deletion (as per paragraph 3.2)
Hard copy documents and information must be disposed of by confidential shredding

Records Retention Schedule

This Record Retention Schedule sets out the time periods that different types of records must be retained for business and legal purposes.

The retention periods are based on business needs and legal requirements and should be read in accordance with Jaymes Byron Talent Limited’s data protection policy. If you maintain any types of records that are not listed in this schedule and it is not clear what retention period should apply, please contact Sebastian Volney, Managing Director for guidance.

Any deviance from the retention periods in this schedule must be approved in advance by Sebastian Volney, Managing Director.

The first section of this policy will address employment records, the second section will address work-seeker records.

Work-seeker record

Record Retention Period   Lawful basis and reference

Work-seeker records

  • Name/address and if under 22, date of birth
  • Any terms between recruitment business and the work-seeker and any variations
  • Details of the work-seeker’s training, experience, qualifications and any authorisation to undertake particular work
  • Names of hirers to whom the work-seeker is introduced or supplied
  • Details of any resulting engagement and date from which it takes effect
  • Details of any enquiries made under Regulations 19, 20 and 22 about the work-seeker and the position concerned

Kept for one year after work-finding services are last provided by The Company


Legal obligation

  • Kept in line with the Conduct of Employment Agencies and Employment Businesses Regulations 2003 (Reg 29) Legitimate business interest
  • To protect the business against any legal claims for breach of contract o Kept in line with the Limitation Act 1980 (s.5)
  • To keep records to demonstrate that safeguarding processes are adhered to and followed
  • To contact the candidate for any further work-finding services
  • To protect your business against any legal claims

Records relating to/demonstrating compliance with Working Time Regulations 1998:

  • Registration of work and rest periods
  • Working time opt-out forms

Kept for two years from the date on which the record was made


Legal obligation

  • Kept in line with the Working Time Regulations 1998 (Reg 9)
Copies of identification documents/right to work

Kept for two years from the date of termination of employment


Legal obligation

  • Kept in line with the Working Time Regulations 1998 (Reg 9)

Criminal records information

  • Information forms
  • DBS check forms
  • DBS certificates

Kept for six months


Legitimate business interest

  • To demonstrate that safeguarding processes were followed

Gender pay gap reporting information

Kept available for a period of at least three years beginning with the date of publication


Legal obligation

  • Kept in line with the Equality Act 2010 (Gender Pay Gap Information) Regulations 2017 (Regulation 15)