Privacy Notice.

What information we collect, use, and why

Personal information we collect for the operation of client or customer accounts

We collect and use the following personal information so we can manage and operate client or customer accounts:

• Names and contact details

• Addresses

• Account information, including registration details

• Technical data, including information about browsers and operating systems

Personal information we collect for recruitment purposes

We collect and use the following personal information so we can assess suitability for roles, carry out necessary checks, and comply with legal obligations:

• Contact details (e.g. name, address, telephone number, personal email address)

• Copies of passports or other photo ID

• Employment history (e.g. job applications, references, secondary employment)

• Education history (e.g. qualifications)

• Right to work information

• Details of any criminal convictions (e.g. DBS, Access NI or Disclosure Scotland checks)

• Security clearance details (e.g. BPSS, CTC, SC, DV)

Lawful bases and your data protection rights

Under UK data protection law, we must have a lawful basis for collecting and using your personal information. The lawful basis we rely on may affect which of your data protection rights apply.

Your data protection rights:

• Right of access

• Right to rectification

• Right to erasure

• Right to restrict processing

• Right to object

• Right to data portability

• Right to withdraw consent

Our lawful bases for using your personal information

Client or customer account data: Contract
Recruitment data: Legal obligation

Consent

In most cases, we do not rely on consent as our lawful basis for processing personal information, because recruitment activities are carried out under legal obligation (for right-to-work, screening and compliance) or contract (for client and customer account management).

However, we may rely on consent in limited situations, such as:

• when you ask us to keep your details on file for future opportunities

• when you request that we share your CV or profile with a specific client

• when you subscribe to marketing updates or newsletters

• when you provide optional information that is not required for recruitment or compliance

Where we rely on consent, you have the right to withdraw your consent at any time. You can do this by contacting us at admin@sqnc.com. Withdrawing consent does not affect the lawfulness of any processing carried out before the withdrawal.

How long we keep your personal information

Retention Schedule:

• Candidate records (active candidates): up to 3 years from last meaningful contact

• Candidate records (placed workers): up to 6 years after assignment ends

• Right to work documentation: 2 years after employment/assignment ends

• Payroll, tax and payment records: 6 years from end of tax year

• Client contact details and account information: duration of relationship + 6 years

• Compliance documentation (DBS, security clearance, references): up to 6 months unless legally required longer

• Website analytics and technical data: up to 12 months

Who we share personal information with

• Clients

• Payroll providers and accountants

• Background screening and verification providers

• Right to work and identity check providers

• Technology and system providers

• Regulators, law enforcement, or government bodies

• Other third parties where required by law

Security of your personal information

We use appropriate technical and organisational measures including access controls, secure storage, encryption where appropriate, staff training, and regular security reviews.

Sharing information outside the UK

We may transfer personal information outside the UK using appropriate safeguards such as adequacy regulations, IDTAs, or SCCs with the UK Addendum.

Cookie Notice

How we use cookies

Our website uses cookies to improve your experience, understand how people use our site, and ensure the website functions properly.

Types of cookies we use:

1. Strictly necessary cookies

2. Performance and analytics cookies

3. Functionality cookies

4. Third-party cookies

Managing cookies

You can control cookies through your browser settings.

Changes to this Cookie Notice

We may update this notice periodically.

How to complain

If you have concerns, contact us at admin@sqnc.com or contact the ICO.

Combined UK/EU/US Data Protection & Privacy Compliance Statement

SEQUENCE operates internationally and is committed to protecting personal information in line with the data protection laws of the regions in which we work. This statement explains how we meet our obligations under UK GDPR, EU GDPR, Swiss data protection law, and relevant US privacy frameworks when handling personal information for recruitment and client services.

Compliance with UK GDPR, EU GDPR and Swiss FADP

We process personal information in accordance with UK GDPR, EU GDPR, and the Swiss Federal Act on Data Protection (FADP). We ensure lawful bases for processing, transparency, data minimisation, appropriate retention, strong security measures, and full respect for data subject rights.

Where we transfer personal information outside the UK, EU or Switzerland, we use approved safeguards such as the UK Addendum/IDTA, EU Standard Contractual Clauses (SCCs), and adequacy decisions.

Compliance with US Privacy Requirements

We align with major US state privacy laws including CCPA/CPRA, CPA, VCDPA, CTDPA, and UCPA. We ensure transparency, no sale of personal information, no unnecessary identifiers, no automated decision-making, strong security controls, and respect for applicable US consumer rights.

We do not collect sensitive US identifiers such as Social Security numbers, financial account numbers, or protected health information.

International Transfers to the United States

When personal information is transferred from the UK, EU or Switzerland to the United States, we ensure appropriate safeguards such as SCCs, UK Addendum/IDTA, and contractual commitments requiring US partners to protect personal information to GDPR-equivalent standards.

Security and Data Protection Standards

We maintain strong security controls including access controls, encryption where appropriate, staff training, vendor due diligence, and regular security reviews.

Your Rights

UK/EU/Swiss individuals

You have full GDPR/FADP rights including access, rectification, erasure, restriction, objection, portability, and withdrawal of consent where applicable.

US individuals

Depending on your state, you may have rights to access, delete, correct, or opt out of certain uses of your personal information.

Contact

For any questions, contact us at admin@sqnc.com.