Privacy Notice for Candidates
Walker Dendle (”We”) are committed to protecting and respecting your privacy.
Our Group means our subsidiaries, our ultimate holding company and its subsidiaries, our associated companies as defined in section 1159 of the UK Companies Act 2006 (our Group).
This notice sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us.
The General Data Protection Regulation (GDPR) (Regulation (EU) 2016/679) is a new regulation which replaces the Data Protection Regulation (Directive 95/46/EC) The Regulation aims to harmonise data protection legislation across EU member states, enhancing privacy rights for individuals and providing a strict framework within which commercial organisations can legally operate.
Even though the UK has expressed its intention to leave the EU in March 2019, the GDPR will be applicable in the UK from 25th May 2018. The Government intends for the GDPR to continue in UK law post Brexit and has also introduced a Data Protection Bill to replace the current Data Protection Act in due course.
Your new rights under the GDPR are set out in this notice but will only apply once the GDPR becomes law on 25th May 2018.
Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.
For the purposes of data protection legislation in force from time to time the data controller is Walker Dendle of Cell 3, KOPSHOP, 6 Old London Road, Kingston upon Thames, KT2 6QF.
Our nominated representative is Lisa Dendle.
Who we are and what we do
We are a recruitment agency and recruitment business as defined in the Employment Agencies and Employment Businesses Regulations 2003 (our business). We collect the personal data of the following types of people to allow us to undertake our business;
- Prospective and placed candidates for permanent or temporary roles;
- Prospective and live client contacts;
- Supplier contacts to support our services;
- Employees, consultants, temporary workers;
We collect information about you to carry out our core business and ancillary activities.
- PERSONAL INFORMATION
The information that we collect about you may include your name, address, private and corporate e-mail address and phone number, financial information, compliance documentation and references verifying your qualifications and experience and your right to work in the United Kingdom, curriculum vitae and photograph, links to your professional profiles available in the public domain e.g. LinkedIn, Twitter, business Facebook or corporate website.
We may collect the following information when you visit our website:
- Any login ID and password you created on www.walkerdendle.co.uk (our site).
- Technical information when you visit our site, including the Internet protocol (IP) address.
- Information about your visit to our site, including the full Uniform Resource Locators (URL).
2. WHERE WE COLLECT YOUR INFORMATION
We collect information about you that you give us by filling in forms on our site or by corresponding with us by phone, e-mail or otherwise. It includes information you provide when you register to use our site, to enter our database, subscribe to our services, attend our events, participate in discussion boards or other social media functions on our site, enter a competition, promotion or survey, apply for positions advertised on our site, and when you report a problem with our site.
With regard to each of your visits to our site we will automatically collect the following information:
- technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information if applicable, browser type and version.
- information about your visit, including the full Uniform Resource Locators (URL), clickstream to, through and from our site (including date and time), page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, and any phone number used to call our customer service number.
We obtain information about you from other sources such as LinkedIn, corporate websites, job board websites, online CV libraries, your business card and personal recommendations. In this case we will inform you, by sending you this privacy notice, within a maximum of 30 days of collecting the data of the fact we hold personal data about you, the source the personal data originates from and whether it came from publicly accessible sources, and for what purpose we intend to retain and process your personal data.
We are working closely with third parties including business partners, sub-contractors in technical, professional, payment and other services, advertising networks, analytics providers, search information providers, credit reference agencies and professional advisors. We may receive information about you from them for the purposes of our recruitment services and ancillary support services.
- USES MADE OF THE INFORMATION
- We will use your personal information in the following ways:
- to perform or take preparatory steps to perform the contract we have entered/shall enter into with you;
- to provide you with the information, products and services that you request from us or we think will be of interest to you because it is relevant to your career;
- to provide you with information about other goods and services we offer that are similar to those that you have already been provided with or enquired about
- to comply with a legal obligation; and
- where it is necessary, for our legitimate interests (or those of a third party) and your interest and fundamental rights do not override those interests.
The core service we offer to our candidates and clients is the introduction of candidates to our clients for the purpose of temporary or permanent engagement. However, our service expands to supporting individuals throughout their career and to supporting businesses’ resourcing needs and strategies.
Our legal basis for the processing of personal data is our legitimate business interests, described in more detail below, although we will also rely on contract, legal obligation and consent for specific uses of data.
We will rely on contract if we are negotiating or have entered into a placement agreement with you or your organisation or any other contract to provide services to you or receive services from you or your organisation.
We will rely on legal obligation if we are legally required to hold information on to you to fulfil our legal obligations.
We will in some circumstances rely on consent for particular uses of your data and you will be asked for your express consent, if legally required. Examples of when consent may be the lawful basis for processing include permission to introduce you to a client. Should we want or need to rely on consent to lawfully process your data we will request your consent orally, by email or by an online process for the specific activity we require consent for and record your response on our system. Where consent is the lawful basis for our processing you have the right to withdraw your consent to this particular processing at any time.
We process your personal information as follows:
- We process your ID and any visas you may have in order to comply with our legal obligation to confirm your identity and your right to work in the UK. If these documents are not provided by you, we will unfortunately be unable to seek work on your behalf.
- We process your CV, employment history, employment references, current and expected salary, interview notes and proof of your qualifications, to enable us to ensure that we are seeking positions for you that are suited to your education and your experience, thereby fulfilling our contracts with you and with our clients. If these documents are not provided by you, we may unfortunately be unable to seek work on your behalf due to being unable to provide evidence to our client that you meet their requirements for the vacant position.
- We process your contact details and any communication between us in order to enable us to contact you regarding suitable roles, thereby fulfilling our work seeking contract with you. If this information is not provided by you, we will unfortunately be unable to seek work on your behalf due to not being able to communicate with you.
- We send your CV to our clients to fulfil our contract with you to seek work on your behalf and to fulfil our contract with our clients to fill their vacant job roles. If we are unable to send your CV to our clients we may be unable to seek work on your behalf due to being unable to provide evidence to our client that you meet their requirements for the vacant position.
- We process all data you provide us with in order to ensure we have an efficient method of working and fulfil our contracts with you and with our clients to find you positions which are relevant to your skills and your financial expectations. If this information is not provided by you, we may unfortunately be unable to seek work on your behalf due to being unable to provide evidence to our clients that you meet their requirements for their vacant position.
- In the event that Walker Dendle places you in to a contract or temporary position with our client, we will process your contract and financial information (such as bank details) in order to ensure you receive payment. If this information is not provided by you we may be unable to perform the contract we have entered in to with you and our client as we may be unable to pay you.
- We process any data you provide us regarding third parties (such as referees) on the assumption that the third party in question has given you permission to do so, and permission to Walker Dendle to collect, process and transfer their personal information to the same extent as yours.
- With your consent, we process your data in order to introduce you to a client. If we do not receive your consent we may be unable to introduce you and therefore unable to perform our contract with you and the client.
- With your consent, we process your contact details to also keep you updated with job market information, e.g. relevant jobs you can apply for and relevant market insight. If we do not receive your consent we may not be able to provide you timely and relevant information about positions and job market insight.
Other Uses we will make of your data:
- Use of our website;
- to notify you about changes to our service;
- to ensure that content from our site is presented in the most effective manner for you and for your computer.
We will use this information:
- to administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
- to improve our site to ensure that content is presented in the most effective manner for you and for your computer;
- to allow you to participate in interactive features of our service, when you choose to do so;
- as part of our efforts to keep our site safe and secure;
- to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you;
- to make suggestions and recommendations to you and other users of our site about goods or services that may interest you or them.
We may also use your personal information in the following situations, which are likely to be rare:
- Where we need to protect your interests (or someone else’s interests); and
- Where it is needed in the public interest
Our Legitimate Business Interests
Our legitimate interests in collecting and retaining your personal data are described below:
As a recruitment business and recruitment agency we introduce candidates to clients for permanent employment, temporary worker placements or independent professional contracts. The exchange of personal data of our candidates and our client contacts is a fundamental, essential part of this process.
In order to support our candidates’ career aspirations and our clients’ resourcing needs we require a database of candidate and client personal data containing historical information as well as current resourcing requirements.
To maintain, expand and develop our business we need to record the personal data of prospective candidates and client contacts.
Automated decision making
We do not undertake automated decision making or profiling. We do use our computer systems to search and identify personal data in accordance with parameters set by a person. A person will always be involved in the decision making process.
Special category personal information
We may collect from you:
- Information about race or ethnicity, religious beliefs and sexual orientation
- Information about health, including any medical condition; or
- Any criminal convictions and offences.
We process this data on the following lawful bases:
- With your explicit written consent when you sign our registration form
- Where it is needed to establish, bring or defend legal claims
- Where needed to carry out our legal obligations relating to employment law, social security law or social protection law; and
- Where it is needed to assess working capacity on health grounds, subject to appropriate confidentiality safeguards.
The situations in which we will process your personal information are listed below:
- We process anonymised data equal opportunities data to ensure that we are committed to our diversity policy.
- We only process health and medical data, and criminal convictions and offences data if it is relevant to any registration you may make, to enable us to fulfil our contract with you and our clients. This information will be processed in accordance with the restrictions imposed by law.
Right to withdraw consent
Should we want or need to rely on consent to lawfully process your data we will request your consent orally, by email or by an online process for the specific activity we require consent for and record your response on our system. Where consent is the lawful basis for our processing you have the right to withdraw your consent to this particular processing at any time by contacting us at firstname.lastname@example.org.
- clients for the purpose of introducing you to them
- clients, business partners, suppliers and sub-contractors for the performance and compliance obligations of any contract we enter into with them or you, for example any Umbrella Company you may instruct upon securing work through Walker Dendle
- subcontractors including email marketing specialists, event organisers, payment and other financial service providers
- advertisers and advertising networks that require the data to select and serve relevant adverts to you and others. We do not disclose information about identifiable individuals to our advertisers, but we will provide them with aggregate information about our users (for example, we may inform them that 500 men aged under 30 have clicked on their advertisement on any given day). We may also use such aggregate information to help advertisers reach the kind of audience they want to target (for example, women in SW1). We may make use of the personal data we have collected from you to enable us to comply with our advertisers’ wishes by displaying their advertisement to that target audience]
- analytics and search engine providers that assist us in the improvement and optimisation of our site
- credit reference agencies, our insurance broker, compliance partners and other sub-contractors for the purpose of assessing your suitability for a role where this is a condition of us entering into a contract with you.
We will disclose your personal information to third parties:
- In the event that we sell or buy any business or assets, in which case we will disclose your personal data to the prospective seller or buyer of such business or assets.
- If Walker Dendle or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
- If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms and conditions of supply of services and other agreements; or to protect the rights, property, or safety of Walker Dendle, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
The lawful basis for the third party processing will include:
- Their own legitimate business interests in processing your personal data, in most cases to fulfil their internal resourcing needs
- satisfaction of their contractual obligations to us as our data processor
- for the purpose of a contract in place or in contemplation
- to fulfil their legal obligations.
Where we store and process your personal data
The data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (”EEA”). It may be transferred to third parties outside of the EEA for the purpose of our recruitment services. It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers. This includes staff engaged in, among other things, our recruitment services and the provision of support services. By submitting your personal data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy notice.
All information you provide to us is stored on our secure servers. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
- DATA SECURITY
Security measures and procedures have been put in place to prevent the accidental loss, destruction or unauthorised disclosure of personal information, including:
- Password protection on all computer software and hardware
- Antivirus firewall protection and regular network back ups
- Hard copy data is stored securely by our third party data management provider, and is regularly shredded at our on-site premises
- The physical premises is secured at all times
- Staff training to keep personal data secure
- Service agreements with our suppliers and third party service providers.
- RIGHTS AND RETENTION, UPDATING AND REMOVAL OF PERSONAL INFORMATION
Your data will be deleted 5 years after the date of last contact from either party, or as otherwise allowed or required by law.
You have the right to ask us not to process your personal data for marketing purposes. We will usually inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes and we will collect express consent from you if legally required prior to using your personal data for marketing purposes.
You can exercise your right to accept or prevent such processing by checking certain boxes on the forms we use to collect your data. You can also exercise the right at any time by contacting us at email@example.com.
Our site may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
The GDPR provides you with the following rights. To:
- Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
- Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
- Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.
- Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
- Request the transfer of your personal information to another party in certain formats, if practicable.
- Make a complaint to a supervisory body which in the United Kingdom is the Information Commissioner’s Office. The ICO can be contacted through this link: https://ico.org.uk/concerns/
Access to information
The Data Protection Act 1998 and the GDPR give you the right to access information held about you. We also encourage you to contact us to ensure your data is accurate and complete.
Your right of access can be exercised in accordance with the Act (and the GDPR once it is in force). Prior to 25th May 2018 any access request under the Data Protection Act will be subject to a fee of £10 to meet our costs in providing you with details of the information we hold about you.
A subject access request should be submitted to firstname.lastname@example.org. No fee will apply once the GDPR comes into force.
Retention of your data
We understand our legal duty to retain accurate data and only retain personal data for as long as we need it for our legitimate business interests and that you are happy for us to do so. Accordingly, we have a data retention notice and run data routines to remove data that we no longer have a legitimate business interest in maintaining.
We do the following to try to ensure our data is accurate:
- ·our site enables you to access, review and change your personal data through the ‘Edit Account Details’ feature
- prior to making an introduction we check that we have accurate information about you
- we keep in touch with you so you can let us know of changes to your personal data
We segregate our data so that we keep different types of data for different time periods. The criteria we use to determine whether we should retain your personal data includes:
- the nature of the personal data
- its perceived accuracy
- our legal obligations
- whether an interview or placement has been arranged; and
- our recruitment expertise and knowledge of the industry by country, sector and job role.
We may archive part or all of your personal data or retain it on our financial systems only, deleting all or part of it from our main Customer Relationship Manager (CRM) system. We may pseudonymise parts of your data, particularly following a request for suppression or deletion of your data, to ensure that we do not re-enter your personal data on to our database, unless requested to do so.
For your information, Pseudonymised Data is created by taking identifying fields within a database and replacing them with artificial identifiers, or pseudonyms.
Our current retention notice is available upon request.
- ENQUIRIES, ISSUES AND COMPLAINTS
If you have any queries or concerns please contact our Data Compliance Officer, Lisa Dendle at email@example.com
You have the right to make a complaint to the supervisory authority, which in the UK would be the ICO https://ico.org.uk/
- CHANGES TO THIS PRIVACY NOTICE
Any changes we make to our privacy notice in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our privacy notice.
- CONTACTING US
Lisa Dendle is our Data Compliance Officer and is your point of contact for data protection matters.
Questions, comments and requests regarding this privacy notice are welcomed and should be addressed to firstname.lastname@example.org.