Privacy Policy

Privacy at a Glance

• ✓ We collect only data necessary for staffing services
• ✓ Your data is encrypted and stored securely in UK/EU
• ✓ We never sell your personal data to third parties
• ✓ You have rights under UK GDPR (access, rectification, erasure in certain circumstances, portability where applicable)
• ✓ AI assistants help but don't make critical decisions
• ✓ Compliant with UK GDPR & Data Protection Act 2018

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Contents

1. Who We Are
2. Data We Collect
3. How We Use Your Data
4. AI Platform Assistant
5. Who We Share Data With
6. International Transfers
7. Data Retention
8. Your Rights
9. Security Measures
10. Cookies
11. Children's Privacy
12. Policy Changes
13. Contact & Complaints

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1. Who We Are

Data Controller: Prisma Staffing Limited ("Prisma Staffing", "we")

Prisma Staffing engages and supplies temporary workers to hirers through our web platform and WhatsApp. The platform is the Opus app, which Opus Platforms Limited, a connected company of ours, runs on our behalf as our processor. This policy explains how we collect, use, and protect your personal data in compliance with UK GDPR and the Data Protection Act 2018.

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2. Data We Collect

2.1 Worker Registration

2.1A Profile Photo

What we collect: your profile photo. When you complete a right-to-work check with a digital verification provider that includes a live selfie, we use that selfie as your default profile photo. Otherwise you can upload a photo yourself.

Why: so that the hirer you work for can confirm that the person who arrives is the person we have checked, and so that we can check your identity at work.

How it is checked: a profile photo you upload is scanned for viruses and then a member of our team compares it with your right-to-work evidence. You are asked for a new photo if it is not clear or does not match. Prisma Staffing does not use any automated face detection, facial recognition or facial matching on your photo, and no third party receives it for that purpose. The facial comparison in your right-to-work check is performed by the verification provider (see section 2.2).

Photo taken from your right-to-work check: where your right-to-work check passes and the provider's report contains your live selfie, we copy that selfie image out of the report and use it as your profile photo. It is marked as verified by our system because the provider has already compared it with your identity document. The original report is never changed. This photo is locked: you cannot replace it yourself. If you want a different photo, you can send a change request from your profile and a member of our team decides it. Prisma Staffing keeps the selfie inside your right-to-work report as statutory evidence (section 2.2 and section 7) and reuses a copy of it as your profile photo. It is not used for any other purpose, and Prisma Staffing does not run facial recognition on it.

Who sees it: you; hirers you are booked with; hirers browsing the talent pool, unless you have opted out of it; and authorised Prisma Staffing staff. We do not show your photo to the public or to people who are not signed in. If you opt out of the talent pool in your account settings, hirers browsing the talent pool will not see your profile or your photo; hirers you are already booked with, and Prisma Staffing staff, still see it so that they can confirm who is attending.

Lawful basis: legitimate interests (Article 6(1)(f) UK GDPR) in confirming the identity of the people we place with hirers. The selfie held in your right-to-work report is kept to meet a legal obligation (see section 2.2 and section 7). You have the right to object to the use of your photo as a profile photo (Article 21): contact the Data Protection Lead (section 13) and we will stop using the selfie as your profile photo, unless we have compelling grounds. Objecting does not delete the right-to-work report, which we must keep by law. You can opt out of the talent pool at any time from your account settings.

How long: a profile photo you uploaded is kept until you change it or your account is closed (then per erasure rules). A photo taken from your right-to-work check follows the retention of the right-to-work evidence it came from (section 7).

Changing it: if you uploaded the photo, replace it any time from your profile; a replacement is checked again. If the photo came from your right-to-work check, send a change request; the current photo stays until a member of our team approves the new one.

2.2 Identity Verification (Right to Work)

Name on your account: enter your name exactly as it appears on your passport or right-to-work document. If the name on your account differs from your document only by additional middle names, the check still passes; we record the name shown on your document as your verified legal name and use it for official checks and payroll. A different first name or surname is sent for review by our team.

Immigration Permission & Work Restrictions: If you hold immigration permission subject to work restrictions, Prisma Staffing will apply the work conditions shown by the Home Office right to work check and your immigration permission, including any restrictions on hours or type of work.

2.3 DBS Background Checks

2.4 Employment & Attendance

2.4A Pre-Placement Forms for Fixed-Term Placements

On some fixed-term placements the hirer asks workers to complete a form before they start, for example a site induction, a site-safety check, a protective-clothing (PPE) size form or a short declaration. We ask you to complete it in your account. These forms are not designed to collect health, trade-union, biometric or other special category data, and our staff cannot publish a form that asks for it.

How the form is scored: the form is scored by fixed rules we set out in advance. No AI model or profiling decides a result. A form that fails or is marked as needing review is always looked at by a member of our staff before it stops a placement from starting, so no placement is refused on the score alone. Your rights to ask for a person to look again, to give your view and to contest a result are in section 8 (Automated Decision-Making).

What the hirer sees: see section 5.2. We do not use your answers for any other purpose.

2.5 Financial Data

2.6 Employer Data

2.7 Automatically Collected

2.8 CV Analytics & Candidate Scoring (Workers Only)

CV parsing data minimisation (updated 31 July 2026): We use Affinda's EU endpoint to parse an uploaded CV for base staffing under the Article 6 basis described in our records of processing; there is no separate parsing-consent flag. We retain only skills, job titles, dates/durations, education qualification/level/field/completion year, work and education counts, total experience, seniority, sector keywords, inferred certification IDs and sanitised parse-status metadata. We do not retain parser response text, raw or masked CV text, names or contact details parsed from the CV, organisations, institutions, grades or free-text responsibilities. Masking is not anonymisation. Every request uses deleteAfterParse=true, we attempt explicit deletion, and we investigate a deletion failure. Separate headhunting consent is required before creating a candidate profile or disclosing identity to an employer; withdrawal deletes that profile and prevents it being recreated unless consent is granted again.

CV parsing vendor: Affinda (EU endpoint, deleteAfterParse=true, Affinda does not retain your CV after parsing). Raw CV text is not stored by Prisma Staffing; only structured extracted fields are retained. Affinda is a third-party machine-learning CV parser. The CV file buffer is sent to Affinda's EU endpoint solely to extract structured fields (work history, education, skills); Affinda is contracted not to retain the document. See §6 for the transfer mechanism and §8 for the full three-layer disclosure of how CV data flows through to recruiter-facing actions.

Scoring: All scores are calculated by deterministic rules; no AI or machine learning is involved on the Prisma Staffing side. See the formula in §8 (Automated Decision-Making).

2.9 Local On-Device Storage of Pending Writes (PWA / Offline Mode)

If you use Prisma Staffing from a browser or installed PWA while offline (or with poor connectivity), the service worker queues certain writes locally on your device until connectivity returns. The queue is stored in your browser's IndexedDB under the database opus-sync-queue, object store pending. Queued writes currently cover three flows:

Entries are replayed automatically when your device regains connectivity (Background Sync API) and removed from IndexedDB after successful replay. Clearing your browser data deletes any pending entries. See §9 for the security framing.

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3. How We Use Your Data

We process your data for these purposes:

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3A. Checking who you are when you contact us

When you contact us, our staff need to be sure they are speaking to the account holder before they discuss the account or change anything. We do this in three steps:

• Finding your account. You can give us your account reference (for example OPX-XXXX-XXXX). It is shown in your account menu and in your welcome email. Giving it is optional. Without it we find your account using your name and your registered email address or phone number.
• Low-risk questions. For questions such as shift times or the status of an application, we may ask for the last 4 digits of the phone number registered on your account.
• Account and money changes. For changes to your bank details, email address, phone number, payouts or an agreement, we send a one-time 6-digit code by SMS or WhatsApp to the phone number registered on your account. You read the code back to us. The code is stored only in scrambled (hashed) form, it expires after 10 minutes, and it cannot be tried more than 5 times. Each attempt to use a code is recorded in our activity log, with its result.

We will never ask you for your password, and we will not ask you to read out a full bank account number to confirm who you are.

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4. AI Platform Assistant

How AI Works at Prisma Staffing: Prisma Staffing provides AI-powered assistants via web chat and WhatsApp to help you find shifts, check compliance status, and manage your work. Here's what you need to know.

4.1 What AI Can Do

• Workers: Browse shifts, check earnings, view compliance status, manage availability via available AI assistant capabilities
• Employers: View shift fill rates, check worker compliance, assist with timesheet review (human approval required for final approval) via available AI assistant capabilities
• All users: Get instant answers to platform questions 24/7

An AI also parses what you type or say to determine which tool to invoke. This routing AI does not itself make decisions about you; downstream tools that can act on your behalf have their own controls (see §8).

4.2 What AI Cannot Do

Critical Decisions Are Always Human/Rule-Based:

• AI does NOT calculate your pay (deterministic payroll system)
• AI does NOT determine your compliance status (rule-based RAG system)
• AI does NOT approve shift assignments (first-valid-wins or employer approval)
• AI does NOT make hiring/firing decisions

4.3 Data Processing

• Queries processed by: the Z.AI GLM-4.7-Flash language model (model ID zai.glm-4.7-flash), invoked through Amazon Web Services (AWS) Bedrock in the AWS Europe (London, eu-west-2) region, under the AWS data processing agreement. Text embeddings use Amazon Titan Text Embeddings V2 on the same service. See §5.1.
• Data shared: Your query text, user role, relevant context (shift data, compliance status)
• Data NOT shared: Passwords, full bank details, biometric data
• Translation: If you set a language preference, platform communications (e.g., WhatsApp notifications) are translated using AI processing by our LLM providers
• Retention: Full AI conversation turn content is retained for your 20 most recent conversation sessions (older turns are hard-deleted nightly); a summary of each session is retained for 2 years for audit/improvement purposes

4.4 Conversational Memory

To make the AI assistant more useful across sessions, Prisma Staffing operates a memory service that, after a conversation completes, extracts durable facts and preferences from the transcript and persists them in your AI profile. These remembered facts are injected into the system context of your future AI sessions so the assistant can personalise responses (for example, recalling your preferred shift type or commute radius).

Conversational memory does not change your compliance status, your assignments, your pay, or any other deterministic platform decision. It only personalises the AI assistant's responses.

Your controls:

• Opt out: use the training opt-out setting in Account Settings → Privacy. This stops new memories being persisted from your conversations.
• Delete existing memory: use the in-app memory clear control, or submit a DSAR via §8.
• Global killswitch: Prisma Staffing operates an admin-level killswitch that disables the memory feature platform-wide if needed for incident response.

A Data Protection Impact Assessment covers this processing and is available on request via support@prismastaffing.co.uk.

4.5 AI Governance & Human Oversight

Prisma Staffing operates a tiered governance framework for AI actions on the platform:

All AI tool executions are performed under a dedicated controlled system identity and recorded in a permanent audit log (retained for 6 years, see §7). High-impact (Tier 2) actions generate approval requests that are reviewed by authorised Prisma Staffing staff through an internal approval workflow before taking effect. Tier 3 actions are never performed by AI; they are handled exclusively by deterministic, rule-based systems.

No AI action on the platform bypasses human oversight for high-impact decisions.

4.6 Model Training & Improvement

We may use de-identified and anonymised interaction data (e.g., query patterns, tool usage statistics) to train and improve AI models that power the platform, including:

• Intent routing models (understanding what you're asking)
• Safety classification models (detecting misuse)
• Tool parameter extraction models (improving accuracy)

Safeguards:

• All training data is stripped of personally identifiable information before use
• Training datasets require Data Protection Lead approval
• A Data Protection Impact Assessment (DPIA) is maintained for AI model training
• No biometric data, financial details, or identity documents are used in training
• Prisma Staffing does not send your data to model providers for the purpose of training their models, and AWS Bedrock does not use the content you or we send to it to train the underlying models

Opt-out: You may opt out of your de-identified data being used for model training by contacting support@prismastaffing.co.uk or via Account Settings → Privacy → AI Data Preferences. Opting out does not affect your access to AI features.

4.7 Your Controls

You can opt out of AI features by contacting support@prismastaffing.co.uk. Core platform functionality remains available without AI assistance.

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5. Who We Share Data With

5.1 Service Providers (Data Processors)

5.2 Employers

When you accept a shift, we share with that employer:

• Your name, phone number, and email
• Compliance status (RTW verified, training completed)
• Your profile photo, with a note of whether we have checked it against your right-to-work evidence
• Attendance records (clock times, GPS coordinates if enabled, QR attendance records if enabled)
• Performance ratings from previous shifts

Data Controller Relationship: Prisma Staffing and hirers generally act as independent controllers for the personal data each processes for its own purposes. Where Prisma Staffing and a hirer jointly determine the purposes and means of a specific processing activity, an arrangement under Article 26 UK GDPR will be put in place. Where relevant to an accepted assignment, Prisma Staffing may share QR attendance confirmations and GPS coordinates with the hirer for attendance verification, dispute resolution, and operational management. Contact the hirer directly for their privacy practices.

For a fixed-term placement where the hirer asked for a pre-placement form (section 2.4A), we also tell that hirer, for its own placement only:

• The outcome of your form (passed, failed or needs review) and any decision our staff made on it
• The PPE sizes that the form asked for

We do not give the hirer your score, your answers or the answer key. A hirer may give us its own paper form so that our staff can build the digital version; only our staff see that paper form. No new service provider or transfer outside the UK is involved.

5.3 Legal & Regulatory Authorities

• HMRC: Tax and National Insurance reporting (legal obligation)
• Home Office: Right to Work compliance verification
• ICO: Data protection investigations if required
• Law enforcement: If required by court order or statutory duty
• The Pensions Regulator: Auto-enrolment compliance

5.4 User-Initiated MCP Client Integrations

Prisma Staffing exposes a Model Context Protocol (MCP) endpoint that lets you connect authenticated third-party MCP clients, for example, OpenAI ChatGPT or Anthropic Claude Desktop, to read or act on the data your role permits inside the Opus app. These integrations are user-initiated: nothing flows to a third-party MCP client unless you authenticate and authorise that client yourself.

• What data the third-party client can see: whatever the MCP tools your role grants would return (the same scope your normal Prisma Staffing session has).
• Who controls the data once it leaves Prisma Staffing: the third-party MCP client you chose, under your contract with that provider. Prisma Staffing does not act as the controller of the onward use.
• What Prisma Staffing retains: an MCP audit log of which tools were invoked, by which client, with what correlation ID (retained for 6 years for payroll/employment audit reasons). The audit log does not include the third-party client's downstream processing.
• Revocation: you can disconnect a connected MCP client at any time from Account Settings → Integrations.

OpenAI and Anthropic are not Prisma Staffing processors in this flow; they are recipients you have chosen as the user. See the ROPA entry "User-initiated MCP client integrations" for the full framing.

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6. International Transfers

Your data is primarily stored in UK/EU AWS regions. Some services involve transfers outside the UK:

SCCs = Standard Contractual Clauses approved by the UK ICO. Request copies at support@prismastaffing.co.uk

Note on UK Extension to the EU-US Data Privacy Framework (DPF): Every recipient above is backed by a live DPA naming SCCs/UK IDTA as a standing fallback regardless of DPF certification status, so a documented safeguard is always in force. As of the 2026-08-08 verification below, nine of the ten US recipients (Stripe, AWS Bedrock, HubSpot, Twilio, Freshdesk, PagerDuty, Slack and, as checked on 2026-10-24, Sentry and New Relic) hold active UK Extension to the EU-US DPF certification; WhatsApp (Meta) does not invoke the UK Extension for UK transfers and instead relies on SCCs/UK IDTA as its primary (not fallback) mechanism, per Meta's/WhatsApp's own published UK privacy policy.

Verification commitment: Per-recipient DPF certification status is checked against the US Department of Commerce's public register (dataprivacyframework.gov/list) at least quarterly and before any new sub-processor is added. Last verified: 2026-08-08 (Sentry and New Relic added and checked 2026-10-24). Framework-level legal risk (flagged 2026-07-03): following the June 2026 U.S. Supreme Court ruling in Trump v. Slaughter (removing the FTC's for-cause removal protections), the privacy advocacy group NOYB has publicly stated an intention to challenge the EU-US DPF's legal validity, on the basis that FTC independence, a condition of the European Commission's adequacy decision, is now in question. Prisma Staffing is monitoring this development. If the European Commission suspends or the CJEU annuls the DPF adequacy decision, every "UK Extension to EU-US DPF" row above falls back to its stated SCC/UK IDTA safeguard automatically (already contractually in place today, not a future action to be taken), and this policy will be updated to reflect the change in the operative primary mechanism.

This static document is a point-in-time summary, not a substitute for the live DPF register, contact support@prismastaffing.co.uk for the current certification status of a specific recipient.

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7. Data Retention

After retention periods expire, data is securely deleted or anonymized.

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8. Your Rights Under UK GDPR

Access (Art. 15)

Request a copy of all data we hold about you. Free of charge, response within 1 month.

Rectification (Art. 16)

Request correction of inaccurate data. Update in account settings or contact us.

Erasure (Art. 17)

Request deletion when data is no longer needed. Some data retained for legal obligations. If you ask us to erase your account, we keep your right-to-work evidence (including the selfie image and document images in the provider's report) until the date in section 7, because the law requires us to keep it (Article 17(3)(b)). Once the deletion grace period has ended (you can cancel the request until then), your account is pseudonymised: your name, contact details and other personal data are removed from the live account and the evidence is kept separately, restricted to staff who need it for legal and compliance purposes. We delete the evidence securely after the retention date.

Restriction (Art. 18)

Limit processing while disputes are investigated.

Portability (Art. 20)

Receive your data in machine-readable format (JSON) for transfer.

Object (Art. 21)

Object to processing based on legitimate interests or direct marketing. This includes the use of your right-to-work selfie as your profile photo (section 2.1A). Right-to-work evidence we must keep by law is not affected by an objection.

How to Exercise Your Rights

• Online: Account Settings → Privacy → Data Rights
• Email: support@prismastaffing.co.uk
• Response time: Within 1 month (may extend to 3 months for complex requests)
• Verification: We may request ID to prevent unauthorized access

Automated Decision-Making

Since the Data (Use and Access) Act 2025, automated decision-making is governed by Articles 22A to 22D UK GDPR. Wherever this policy describes a decision taken solely by automated means that has a significant effect on you, you have the safeguards in Article 22C: to be told about the decision, to make representations, to obtain human intervention and to contest it.

Compliance RAG gating (UK GDPR Articles 22A to 22D). Prisma Staffing operates a Red/Amber/Green (RAG) compliance system that determines whether a worker is eligible to be assigned to shifts. RAG gating is a solely automated decision within the meaning of UK GDPR Articles 22A to 22D: it is performed by deterministic rules (not AI or machine-learning profiling), it does not involve a human in the loop at the moment of decision, and it has a significant effect on you because a non-green status blocks access to shifts and therefore to earnings. The rules check current Right-to-Work validity, contract status, site-specific DBS where required, and structured mandatory credentials. Optional or unrelated credentials and generic pre-placement training do not make your RAG status non-green.

Your safeguards under Articles 22A to 22D:

• Right to human review on request: email support@prismastaffing.co.uk and a human operator will re-examine your status.
• Right to contest: submit a contest through Profile → Challenge an AI Decision in the app (select "Compliance Status (RAG)"), or by email as above. In-app appeals are logged, tracked with a reference ID, and reviewed by a human. We aim to respond within 5 business days and will tell you if we need longer.
• Right to an explanation of the logic: see our published RAG rules summary for the deterministic criteria applied.

Shift eligibility gates (student-visa weekly-hours cap, AWR equal-treatment pay parity, geofence/attendance eligibility). Before you accept a shift, Prisma Staffing runs deterministic, rule-based eligibility checks, a student-visa weekly-hours cap (Right to Work condition compliance), an AWR equal-treatment pay-parity check after 12 weeks on an assignment, and geofence/attendance eligibility checks. These are solely automated decisions within the meaning of UK GDPR Articles 22A to 22D with a significant effect (blocking you from a specific shift). Your Article 22 safeguards for these decisions:

• Right to human review on request: email support@prismastaffing.co.uk with the shift ID or date and a human operator will re-examine the eligibility check.
• Right to contest: submit a contest through Profile → Challenge an AI Decision in the app (select "Shift Eligibility"), mentioning the shift ID or date. In-app appeals are logged, tracked with a reference ID, and reviewed by a human. We aim to respond within 5 business days and will tell you if we need longer.
• Right to an explanation of the logic: the rules are: student-visa weekly-hours cap, AWR equal-treatment pay parity after the 12-week qualifying period, and geofence-based attendance eligibility.

Pre-placement form scoring (fixed-term placements). A form a hirer asks for (section 2.4A) is scored by fixed rules, not by AI. A fail or a "needs review" result does not on its own stop a placement: a member of our staff decides every "needs review" result, and every failed form the hirer has made a condition of starting, before the placement is blocked. Because a person makes that decision, it is not taken solely by automated means. We still give you the Article 22C safeguards:

• Right to human review on request: email support@prismastaffing.co.uk with the placement and form name and a member of staff will look at the result again, including an extra attempt or a reasonable adjustment where that is appropriate.
• Right to contest: email the same address to contest a result. We aim to respond within 5 business days and will tell you if we need longer.
• Right to an explanation of the logic: the form shows which sections you did not pass; the scoring is a fixed marking scheme and the hirer's pass mark.

Shift visibility and employer-selected audience

Prisma Staffing uses deterministic rules to decide which shifts you may discover or act on. The lawful basis is legitimate interests (UK GDPR Art. 6(1)(f)): matching workers to usable opportunities, respecting an employer's selected audience, reducing failed applications, and protecting confidential shift and employer information.

Hard rules include current legal/compliance status, Right-to-Work at shift start, site-specific DBS where required, structured mandatory certifications, shift status/capacity/application cutoff, overlapping work/rest and statutory-hours controls, booking freeze, and the employer's saved audience (all, worked before, or a named talent pool). A current invitation or offer may give you a time-limited relationship to that specific shift. Match score, job/distance/availability preference, optional certifications, generic training, notification preferences, quiet hours, daily caps, and fairness rotation do not hide a shift. No generative AI or LLM makes this decision.

Because hiding a shift can materially affect access to work, Prisma Staffing applies the Articles 22A to 22D safeguards on a precautionary basis. You may ask for a plain-language explanation of the categories used, correct a wrong input, contest the outcome, and request independent human review through Profile → Challenge an AI Decision or support@prismastaffing.co.uk. Compliance/Data Protection Lead review is carried out by a person; we aim to complete it within 14 calendar days and will tell you if we need longer; faster Right-to-Work and DBS correction routes remain available. To protect other people and employers, an explanation will not confirm an unknown or unauthorized shift or disclose another worker's data.

Employers see privacy-preserving reach information: zero may be exact; 1-4 is suppressed; larger groups are shown only as 5-9, 10-24, 25-49, or 50+. Employer small-cell results do not include worker names, rows, or contact details.

Shift allocation is not within Articles 22A to 22D. The first-valid-wins allocation model resolves a race condition between workers who have each chosen to accept the same shift; it is a worker-initiated contract acceptance, not a platform decision about you. The employer-approval allocation model is reviewed by a human (the employer) and is therefore also outside Article 22.

Candidate Scoring: The reliability score and placement score values in your candidate profile are calculated by a published deterministic formula, not AI or machine learning. The formula considers: completed shifts, no-shows, late cancellations, compliance RAG status, months of experience, and skill count. These scores inform how your profile is ranked in internal search results but do not produce any legal effect and are always subject to human review. The full formula is documented in our internal governance document available on request.

Timesheet Deemed-Approval & Worker Reliability Monitoring

Prisma Staffing operates two rules-based (non-AI, non-machine-learning) monitoring mechanisms that can affect your pay or how your profile is ranked:

1. 48-hour deemed-approval on timesheets. Under your assignment confirmation (Clause 4.3), if an employer does not approve or dispute your finalised timesheet within 48 hours of your shift ending, Prisma Staffing may approve it on your behalf using objective platform evidence (GPS clock-in/out records). This only ever happens for a timesheet that is finalised, has no unresolved anomaly flags or open corrections, and passes the same automated pay-safety checks (including the National Minimum Wage check) applied to every approval, never for a timesheet under dispute or with an unresolved issue, which is instead routed to a human reviewer so you are still paid the objectively-evidenced amount by the next pay day.
2. Reliability/no-show scoring. The reliability score described under "Candidate Scoring" above also reflects deemed-approval evidence (i.e., whether your attendance history required employer intervention) as one of its published inputs.

Because deemed-approval can affect when and how you are paid, and reliability scoring can affect how your profile is ranked, we treat both as falling within our UK GDPR Articles 22A to 22D transparency obligations even though neither is a solely-automated decision with a significant, unreviewable effect: a support ticket is automatically raised for human review whenever a timesheet is NOT safe for deemed-approval, and reliability scoring never triggers suspension or account action by itself. Your safeguards:

• Right to human review: email support@prismastaffing.co.uk with the timesheet ID, or use Profile → Challenge an AI Decision (select "Timesheet Approval") to have a human recheck a deemed approval.
• Right to contest: a deemed approval based on evidence that you dispute (e.g., a clock-in/out discrepancy) can be corrected via the standard timesheet correction process; a resulting pay adjustment is applied retroactively.
• Right to an explanation of the logic: the deemed-approval criteria are: 48 hours elapsed, timesheet finalised and payable, no unresolved anomaly or open correction, and a pass of the same guard battery (including NMW) every manual approval uses.
• Records retained: every deemed approval is recorded with a system-actor attribution and an audit event, consistent with our data retention schedule (§7).

A Data Protection Impact Assessment for this processing is maintained (internal; available on request via support@prismastaffing.co.uk).

CV Analytics and Headhunting

CV-driven candidate matching operates in three distinct layers, each with different processing characteristics and safeguards:

1. Affinda, ML CV parser (third-party processor). Your uploaded CV is sent to Affinda's EU endpoint solely to extract structured fields (job titles, durations, skills, education). Affinda is contracted to delete the source document after parsing (deleteAfterParse=true).
2. Prisma Staffing deterministic scoring. From the extracted fields, Prisma Staffing calculates reliability score and placement score using a published, rules-based formula. No AI or machine learning is used at this layer.
3. Recruiter-approved approach (dry-run and confirmation step). A human Prisma Staffing recruiter reviews the shortlisted profiles before any outbound approach is made; an automated approach without recruiter confirmation is not possible by design.

Under the EU AI Act, CV analytics used in employment matching are classified as high-risk per Annex III §4 (employment, workers' management, and access to self-employment). Safeguards in place:

• A human recruiter is in the loop on every outbound approach (Articles 22A to 22D safeguard).
• You have the right to an explanation of the scoring formula on request.
• You have the right to contest your score and request human review of any decision that affected your profile's visibility to employers, via Profile → Challenge an AI Decision in the app or by email (reviewed by a human; we aim to respond within 5 business days and will tell you if we need longer).
• You may withdraw headhunting consent at any time (see "Right to Withdraw Consent" below).

Fraud / Duplicate-Profile Detection

Prisma Staffing runs a deterministic, rule-based fraud-detection layer that flags potential duplicate registrations and impersonation attempts. The detector uses:

• National Insurance (NI) number matches across accounts
• Fuzzy name and date-of-birth matches
• Bank-account-fragment matches across accounts

When a multi-signal flag fires, an alert is surfaced to admin operators. A flagged account can lead to admin-confirmed suspension via a high-risk administrator suspension action (which requires an explicit dry-run and confirmation step, see §4.5 Tier 2 governance). Because suspension has a significant effect on you, this falls within UK GDPR Articles 22A to 22D and you have:

• Right to human review: admin confirmation is already mandatory before any suspension takes effect.
• Right to contest: you can challenge the suspension; the admin team will re-examine the multi-signal evidence.
• Right to an explanation of the logic: the rules above are the full set of signals; we will tell you which signals fired.

Coverage Assurance Agent (Shift-Offer Routing)

Prisma Staffing operates an autonomous Coverage Assurance Agent that monitors published shifts for fill risk (for example, a shift close to its start time with unfilled slots) and identifies eligible workers who could be invited or offered the opportunity. The agent only ever considers workers who already meet the deterministic compliance and eligibility gates described above (RAG status, Right to Work, student-visa hours cap, etc.); it does not itself decide who is eligible.

This is not a solely automated decision under UK GDPR Articles 22A to 22D. Before any shift offer or invitation actually reaches you, a human Prisma Staffing operator must review and approve the agent's proposal (human-on-the-loop), the agent cannot broadcast a shift or send you a direct invitation on its own. Nonetheless, because an AI system is involved in identifying which workers are surfaced as candidates, we disclose this under our Article 13/14 transparency obligations:

• Right to human review: a human operator already approves every offer/invitation action before it is sent to you; you may additionally request review of a specific instance by emailing support@prismastaffing.co.uk with the shift ID or date.
• Right to contest: submit a contest through Profile → Challenge an AI Decision in the app (select "Shift Offer Routing"), or by email as above. In-app appeals are logged, tracked with a reference ID, and reviewed by a human. We aim to respond within 5 business days and will tell you if we need longer.
• Right to an explanation of the logic: the agent surfaces candidates using the same deterministic eligibility criteria described elsewhere in this section (RAG, Right to Work, hours caps); it does not use profiling beyond those documented rules.
• Records retained: the agent's run history and proposed actions are logged internally for audit and safety-review purposes, consistent with our data retention schedule (§7).

AI-Assisted Actions: Where AI proposes actions that may affect your employment (e.g., shift recommendations, compliance suggestions), high-impact proposals are routed to human operators for approval before execution (see §4.5). A Data Protection Impact Assessment (DPIA) is maintained for our AI processing activities in accordance with UK GDPR Article 35 and ICO guidance on AI and data protection.

Your right to human review: You may request human review of any decision in which AI was involved, including any scoring that affects how your profile is presented to employers, by contacting support@prismastaffing.co.uk.

Right to Withdraw Consent

Where we process your data based on consent (e.g., biometric verification, analytics cookies, headhunting matching), you may withdraw consent at any time without affecting the lawfulness of processing before withdrawal. Withdraw via Account Settings → Privacy, or email support@prismastaffing.co.uk.

Talent pool (shift matching) participation is processed on the basis of legitimate interests, not consent. You may object/opt out at any time via Account Settings → Privacy. Opting out immediately removes you from active talent-pool digests and revokes talent-pool-derived live invitation/offer entitlement; retained history becomes non-actionable. It does not hide all or worked before shifts and does not affect an existing assignment or pending pay.

Headhunting consent is separate from talent pool participation. Withdrawing headhunting consent removes your profile from all active Prisma Staffing headhunting mandates immediately and does not affect your ability to find and book shifts through Prisma Staffing.

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9. Security Measures

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10. Cookies

We use four categories of cookies (necessary, functional, analytics and marketing) and similar storage technologies. Your consent is required for analytics and marketing cookies; you can grant, refuse, or change consent at any time from Account Settings → Privacy or via the in-app cookie banner. See our full Cookie Policy for the full list with names, durations, and providers.

• Essential cookies / storage: authentication and consent state. These do not require consent (PECR reg 6 essential exemption) and the platform does not function without them.
• Analytics (consent-gated): Google Analytics 4 loads only after you grant analytics consent. We send anonymous usage events (anonymize_ip: true); cookies set include _ga and _ga_<container> with Google's default 2-year retention. Data is processed in the US under the Google DPF / SCCs (see §6).
• Marketing (consent-gated): Apollo.io visitor tracking loads only after you grant marketing consent and is used for outbound marketing measurement. Data is processed in the US under SCCs.

Manage preferences anytime in Account Settings → Privacy.

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11. Children's Privacy

Our services are for individuals 18+ (UK minimum working age for most roles). We do not knowingly collect data from children. If discovered, it will be deleted immediately.

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12. Policy Changes

We may update this policy to reflect legal or service changes. For material changes:

• We update the version number and date
• We notify you via email for significant changes
• We request renewed consent if legally required

Continued use after changes constitutes acceptance. Check back periodically for updates.

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13. Contact & Complaints

Contact Prisma Staffing

• Email: support@prismastaffing.co.uk
• Address: Suite RA01, 195-197 Wood Street, London, E17 3NU

Complain to ICO

Information Commissioner's Office

• Wycliffe House, Water Lane, Wilmslow, SK9 5AF
• Phone: 0303 123 1113
• ico.org.uk/make-a-complaint

How we handle complaints

If you are unhappy with how we have used your personal data, email support@prismastaffing.co.uk or write to the address above.

• Acknowledgement: we acknowledge your complaint within 5 working days.
• Response: we investigate and send you our outcome within 30 days of receiving it. If we need longer, we will tell you why and when to expect it.
• Escalation: if you remain unhappy, or we do not reply within these times, you may complain to the ICO as above.

We encourage you to contact us first so we can resolve your concern directly.

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UK GDPR Compliant: This policy fulfills Articles 12, 13, and 14 transparency requirements.