Legal
Privacy Policy
This policy explains what personal data Hire A Cold Caller collects, why we hold it, who we share it with and what you can ask us to do about it. It covers three separate groups of people, and the section that applies to you depends on how we came to hold your details.
1. Who we are
Hire A Cold Caller builds, launches and manages dedicated cold-calling functions for business-to-business companies. We recruit and employ the caller, build the operation around them and run it day to day on behalf of our client.
For the purposes of data protection law, the operator of this website and the services described on it is 1 Hour Recruitment Ltd, a company registered in England and Wales (company number 13490535), registered at 5 Ducketts Wharf, South Street, Bishop’s Stortford, Hertfordshire, CM23 3AR, United Kingdom, trading as Hire A Cold Caller.
If you have a question about this policy, or you want to exercise any of the rights described in it, write to hello@hireacoldcaller.com.
2. Whose data this policy covers
We hold personal data about three groups of people, for different reasons and under different legal bases. Read the section that applies to you.
- Website visitors and enquirers. People who visit this site, book a call with us or send us an email.
- People we call on behalf of a client. Business contacts we telephone as part of a client campaign. This is the largest category of data we handle.
- People who apply to work as a caller. Candidates who apply to be recruited and employed by us.
Where we call business contacts as part of a client campaign, our client decides who should be contacted, on what basis and for what purpose. In data protection terms the client is usually the controller of that data and we act as their processor. We describe that arrangement in section 4, and it is set out in full in the contract we sign with each client.
3. Website visitors and enquirers
What we collect
- Your name, email address, company and anything else you choose to tell us when you book a call or send an enquiry.
- The date and time of a meeting you book with us, and any answers you give on the booking form.
- Technical data created automatically when you load a page: IP address, browser and device type, referring page and the pages you viewed. This is generated by our hosting provider as part of serving the site.
Why we hold it
To answer your enquiry, to hold the meeting you booked, to keep a record of what was discussed and agreed, and to keep the website working and secure. If we go on to work together, this data becomes part of our client record.
Marketing
We do not sell your details to anyone and we do not add enquirers to a bulk marketing list without asking. If we send you anything other than a direct reply to your enquiry, it will be because you asked us to, and every message will carry a way to stop it.
4. People we call on behalf of a client
This section applies if we telephoned you about a client's product or service. It is the part of our work that involves the most personal data, so we have set it out in detail.
How we got your details
We contact people in a professional capacity, at the organisation they work for, about something relevant to their role. Contact details reach us in one of three ways:
- Supplied by our client from their own records.
- Built by us for a client campaign from business sources, including professional networking sites, company websites, public registers and licensed business data providers.
- Given to us directly by you during a call.
What we hold
- Your name, job title and employer.
- Your business contact details, which may include a direct dial or mobile number and a work email address.
- A record of our contact with you: when we called, whether we reached you, what you said, whether you asked us not to call again, and any follow-up agreed.
- A recording of the call, where recording applies. See section 6.
We do not seek out special category data, and campaign records should not contain it. We do not use automated decision-making or profiling that produces legal or similarly significant effects.
Why we hold it
To carry out a business-to-business campaign on behalf of the client named to you on the call: to reach the right person, to have a relevant conversation, to record the outcome accurately and to make sure that a request not to be contacted is honoured.
Who is responsible
The client whose product or service we called you about decides which market is contacted and why. They are the controller of that data and we act on their instructions as their processor. That means you can raise a request with either of us: we will act on it ourselves for the data we hold, and pass it to the client where it concerns data they control. We will always tell you which client we called on behalf of if you ask.
5. People who apply to work as a caller
We recruit and employ the callers who work on client functions, so we handle candidate data directly and as controller.
- What we collect. Your CV and the information in it, your contact details, your right-to-work status, notes and scores from interviews, and recordings or transcripts of any live calling assessment.
- Why. To assess whether you are suited to the role, to make and document a hiring decision, and to meet our obligations as an employer if we go on to engage you.
- Assessments. Part of our process involves testing candidates on live calls. Where an assessment call is recorded, we will tell you before it starts and explain how the recording will be used.
- If you are not successful. We keep your application for a limited period in case another role suits you, and you can ask us to delete it sooner.
6. Call recording
Calls made as part of a client campaign may be recorded. Recordings are used to review quality, to coach the caller and to confirm what a prospect actually said. They are used by us to manage the function and are not passed to the client.
Where calls are recorded:
- We follow the notification and consent rules that apply in the place the call is made and the place it is received. Requirements differ between jurisdictions, and in some the caller must announce the recording and obtain agreement before it begins.
- You can ask for a copy of a recording of your own call, or ask us to delete it, using the contact details in section 17.
Our callers work to written instructions on how and when to announce recording. If you tell us during a call that you do not wish to be recorded, that is respected.
7. Our legal bases
Where data protection law requires us to identify a legal basis for holding your data, we rely on the following.
- Legitimate interests. For business-to-business outreach to people in a professional capacity, for keeping records of who we contacted and what was said, and for keeping this website secure. We have considered whether our interest in contacting you is outweighed by your interests and rights, and we limit contact to people whose role makes the subject relevant. You can object at any time and we will stop.
- Contract. For delivering services to a client, and for employing a caller.
- Consent. Where consent is the applicable basis, including for call recording in jurisdictions that require it, and for any marketing you have asked to receive. You can withdraw consent at any time.
- Legal obligation. For records we are required to keep, including employment and tax records, and for honouring a request not to be contacted.
Telephone marketing is also governed by rules separate from general data protection law, including screening against official do-not-call registers. Section 12 explains how to stop us calling you.
9. International transfers
We work with clients and call markets in more than one country, and some of the suppliers listed above are based outside the country you are in. Where personal data moves between countries, we rely on the safeguards recognised by the law that applies, which may include an adequacy decision covering the destination country or standard contractual clauses with the supplier. You can ask us which applies to a particular transfer.
10. How long we keep data
- Enquiries that do not become work. Kept for a limited period so we have a record of the conversation, then deleted.
- Client records. Kept for the life of the engagement and then for as long as we need them to meet our legal, tax and accounting obligations.
- Campaign contact records and call recordings. Kept for the campaign and for the period agreed with the client. Contact records are then deleted or returned to the client; recordings are deleted. Where a client instructs us to delete their campaign data, we do so and confirm it.
- Do-not-contact records. Kept indefinitely. If you ask us never to call you again, we have to keep enough information to recognise you and honour that. This is the one record a deletion request does not remove, because deleting it would let us call you again by mistake.
- Unsuccessful applications. Kept for a limited period, then deleted.
11. Your rights
Depending on where you live, you may have some or all of the following rights over the data we hold about you.
- To be told what we hold and to receive a copy of it.
- To have inaccurate data corrected.
- To have data deleted, subject to the exception for do-not-contact records described above.
- To object to us processing your data, including for direct marketing. If you object to marketing, we stop.
- To ask us to restrict what we do with your data while a question about it is resolved.
- To receive data you gave us in a portable format.
- To withdraw consent where consent is what we relied on.
We do not charge for these requests and we will respond within the time limit the applicable law sets. Write to hello@hireacoldcaller.com. We may need to confirm who you are before we act, so that we do not disclose someone else's data to the wrong person.
12. How to stop us calling you
Tell the caller, or email hello@hireacoldcaller.com with the number you want removed. It is recorded against every campaign we run, not only the one that called you.
You do not have to give a reason and you do not have to put it in writing. Saying it on the call is enough. We keep a record of the request so that the number is suppressed for the future, which is the exception to deletion described in section 10.
If we called you on behalf of a client and you want the client to remove you from their own records as well, tell us and we will pass the request on, or contact them directly. We will tell you who the client is.
13. Security
Access to campaign data, recordings and client records is limited to the people who need it to do their work. Accounts are individual, access is removed when someone leaves, and data is held in the business systems described in section 8 rather than on personal devices. If a breach occurs that is likely to present a risk to the people affected, we notify the relevant authority and, where required, the people concerned.
15. Children
Our services are sold to businesses and our campaigns contact people in a professional capacity. This website is not directed at children and we do not knowingly collect data about them. If you believe we hold data about a child, tell us and we will delete it.
16. Changes to this policy
We update this policy when what we do with personal data changes. The date at the top shows when it was last revised. If a change materially affects people whose data we already hold, we will take reasonable steps to tell them rather than relying on the updated page alone.
17. Contact and complaints
For anything in this policy, including access, deletion and objection requests, write to hello@hireacoldcaller.com.
If you are not satisfied with how we have handled your request, you can complain to the data protection authority for your country. In the United Kingdom that is the Information Commissioner's Office at ico.org.uk. We would rather hear from you first, so we get the chance to put it right.