Privacy & Cookies Policy

Introduction

Welcome to the D&A Recruitment Limited’s privacy notice.

D&A Recruitment Limited respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and provide it, to us, by different means, as well as informing you about your privacy rights and how the law protects you.

Please also use the Glossary at section 10 below to understand the meaning of some of the terms used in this privacy notice.

1. IMPORTANT INFORMATION AND WHO WE ARE

Purpose of this privacy notice

This privacy notice aims to give you information on how D&A Recruitment Limited collects and processes your personal data. For candidates, this will include any data you may provide to us when you provide us with a copy of your CV, submit an enquiry with us or when you share this information to us by email, telephone, mail, in person, online or otherwise. This will also cover information we receive from third party platforms and ‘job-boards’ when you have shown an interest in a work role. For clients, this will include any data you may provide to us when enquiring about our recruitment services or when you share this information to us by email, telephone, mail, in person or otherwise, including employee contact details for the purpose of providing our services to you.

This website is not intended for children and we do not knowingly collect data relating to children.

It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.

Controller

D&A Recruitment Limited (‘we’, ‘us’ or ‘our) is the controller and responsible for your personal data.

We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights (please see section 9 and 10 below), please contact the data privacy manager using the details set out below.

Contact details

Full name of legal entity: D&A Recruitment Limited (Company number: 07986314)

Name or title of data privacy manager: Daniel Davis

Email address: [email protected]

Postal address: Moorfield Road, Duxford, Cambridge, CB22 4PS

Telephone number: 01223 661 100

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO, so please contact us in the first instance.

Changes to the privacy notice and your duty to inform us of changes

This version was last updated on 25/05/18 and historic versions can be obtained by contacting us.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

2. THE DATA WE COLLECT ABOUT YOU

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

• Identity Data includes first name, last name, username or similar identifier, title, date of birth, gender
  and national insurance number.
• Contact Data includes address, email address and telephone numbers.
• Financial Data includes bank account details.
• Transaction Data includes details about payments to and from you and other details of services provided to you name, namely recruitment services.
• Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
• Profile Data includes your username and password, your interests, preferences, feedback and survey responses, employment history, salary, skills and attributes, education details, qualifications and national insurance number.
• Usage Data includes information about how you use our website and services.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
• Criminal Convictions and Offences Data includes details about your criminal convictions and offences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

Special Category Data

We only collect the following Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data).

1: Passport Photo

As part of the legal requirements placed on us, or our clients, to verify the identity of candidates and workers, as well as your right to work in the UK, we do collect and retain copies of your passports. We will obtain your separate, explicit consent to do this at the time we take the copy.

2: Information about criminal convictions

In some circumstances we will process information about criminal convictions as part of our recruitment services

We are required to carry out a criminal records check in order to satisfy ourselves that there is nothing in your criminal convictions history which makes you unsuitable for the role. In particular:

• We are legally required to obtain such checks for a role and will inform you of this in advance;
• The role of is one which is listed on the Rehabilitation of Offenders Act 1974 (Exceptions) Order 1975 (SI 1975/1023) so is eligible for a standard check from the Disclosure and Barring Service.
• The role requires a high degree of trust and integrity, and our client has asked us to seek a basic disclosure of your criminal records history (you will be informed in advance).

We have in place an appropriate policy document and safeguards which we are required by law to maintain when processing such data. We will also obtain your consent before conducting any criminal record check or processing/sharing the results.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you for the purposes of recruitment services. In this case, we may be unable to provide the recruitment services you have requested but we will notify you if this is the case at the time.

3. HOW IS YOUR PERSONAL DATA COLLECTED?

We use different methods to collect data from and about you including through:

• Direct interactions. You may give us your Identity, Contact, Profile and Financial Data by filling in forms, registering an account with us, providing us with a copy of your CV or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you
• apply for our services;
• wish to become a client;
• request marketing or information on our services to be sent to you;
• enter a competition, promotion or survey; or
• give us some feedback.
• Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy below for further details.
• Third parties or publicly available sources. We may receive personal data about you from various third parties as set out below:
• Technical Data from the following parties:

1. 1. 1. analytics providers such as Google based outside the EU;  and
      2. search information providers based inside the EU.

• Contact and Financial Data from providers of technical and payment services such as Experian.
• Identity and Contact Data from publicly available sources.
• Identity, Contact and Profile Data from your current employer, where you are employed by an umbrella/payroll company or personal service company.  Please note: In these circumstances, when you are engaged through such a company, we will be relying on your employer to ensure they have established a legal basis for processing your data with you. Our basis for the ongoing processing of your data will become subject to a contract between us and that company.
• For candidates only, the Disclosure and Barring Service in respect of criminal convictions.
• From third party platforms and job boards, including LinkedIn and [INSERT BOARDS USUALLY USE]

4. How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• On the basis of consent for us to provide our recruitment services to you.
• Where we need to perform the contract we are about to enter into or have entered into with you or your employer/prospective employer.
• Where it is necessary for our legitimate interests (including providing some of our recruitment services) and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal or regulatory obligation.
• To a purchaser (or prospective purchaser) of any business or asset that we are (or are contemplating) selling.

Please note: You have the right to withdraw consent to marketing at any time by contacting us.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Candidates:

For candidate’s, we may collect and process your personal data as follows:

Purpose/Activity	Type of data	Lawful basis for processing including basis of legitimate interest
To register you with us	(a) Identity Data (b) Contact Data (c) Special category (sometimes)	(a) Necessary for our legitimate interest to provide our recruitment services to you (b) On the basis of your explicit consent
To manage our relationship with you which will include: (a) Notifying you about changes to our terms or privacy policy (b) Asking you to leave a review or take a survey	(a) Identity Data (b) Contact Data (c) Marketing and Communications Data	(a) Necessary to comply with a legal obligation (b) Necessary for our legitimate interests (to keep our records updated and to study how candidates use our services) (c) On the basis of your explicit consent
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you	(a) Identity Data (b) Contact Data (c) Usage Data (d) Marketing and Communications Data (e) Technical Data.	Necessary for our legitimate interests (to study how candidates use our services, to develop them, to grow our business and to inform our marketing strategy)
To provide recruitment services to you and find you employment opportunities	(a) Identity Data (b) Contact Data (c) Profile Data (d) Usage Data (e) Marketing and Communications Data (f) Technical Data (g) Financial Data	(a) Necessary for our legitimate interest to provide our recruitment services to you. (b) conducted on the basis of your explicit consent
To carry out financial background checks	(a) Identity Data (b) Contact Data (c) Financial Data	(a) on the basis of your explicit consent (b) Necessary to comply with a legal obligation (c) Employment exemption (necessary in connection with employment)
To make suggestions and recommendations to you about goods or services that may be of interest to you	(a) Identity (b) Contact (c) Technical (d) Usage	Necessary for our legitimate interests (to develop our products/services and grow our business)
To contact you via third party platforms or process your responses to job adverts (on job-boards)	(a) Identity Data (b) Contact Data	Necessary for our legitimate interests to respond to your applications and keep you informed of work roles.
To carry out criminal records/DBS checks	(a) Identity Data (b) Contact Data (c) Special category	(a) Necessary in our legitimate interests to understand your suitability for a role (b) On the basis of your explicit consent

Clients:

For employer client’s/prospective employer clients, we may collect and process certain personal data about your organisation and individuals within your organisation as follows:

Purpose/Activity	Type of data	Lawful basis for processing including basis of legitimate interest
To manage our relationship with you which will include: (a) Notifying you about changes to our terms or privacy policy (b) Asking you to leave a review or take a survey	(a) Identity Data (b) Contact Data (c) Marketing and Communications Data.	(a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to study how clients use our services)
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you	(a) Identity Data (b) Contact Data (c) Usage Data (d) Marketing and Communications Data (e) Technical Data	Necessary for our legitimate interests (to study how clients use our services, to develop them, to grow our business and to inform our marketing strategy)
To provide recruitment services to you and assist you with a particular resourcing requirement	(a) Identity Data (b) Contact Data (c) Usage Data (d) Marketing and Communications Data (e) Technical Data	Performance of a contract with you
To provide you with relevant information that we think will be of interest to you, such as information relating to available candidates, industry insights, opinion pieces, surveys and event invitations.	(a) Contact Data (b) Identity Data	Necessary for our legitimate interests (to develop our services and grow our business)
To make suggestions and recommendations to you about goods or services that may be of interest to you	(a) Identity (b) Contact (c) Technical (d) Usage	Necessary for our legitimate interests (to develop our products/services and grow our business)

Website users:

For website users, we may collect and process your personal data as follows:

Purpose/Activity	Type of data	Lawful basis for processing including basis of legitimate interest
To administer and protect our business (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	Technical Data	(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) (b) Necessary to comply with a legal obligation
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you	(a) Usage Data, (b) Marketing and Communications Data; and (c) Technical Data.	Necessary for our legitimate interests (to study how individuals use our website, to develop it, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, services, marketing, customer relationships and experiences	(a) Technical (b) Usage	Necessary for our legitimate interests (to define types of customers for our services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about services that may be of interest to you	(a) Identity (b) Contact (c) Technical (d) Usage (e) Profile	Necessary for our legitimate interests (to develop our products/services and grow our business)

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

Promotional offers from us

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which services may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us or registered your details with us and, in each case, you have not opted out of receiving that marketing.

Third-party marketing

We do not share your personal data with third parties for marketing purposes.

Opting out

You can ask us to stop sending you marketing messages at any time by contacting us.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a service purchase, registering with us as a candidate for our recruitment services or service experience.

Cookies

What’s a cookie?

A “cookie” is a piece of information that is stored on your computer’s hard drive and which records your navigation of a website so that, when you revisit that website, it can present tailored options based on the information stored about your last visit. Cookies can also be used to analyse traffic and for advertising and marketing purposes. 

Cookies are used by nearly all websites and do not harm your system. If you want to check or change what types of cookies you accept, this can usually be altered within your browser settings.

How do we use cookies?

We use cookies to do two things:

• • to track your use of our websites. This enables us to understand how you use the sites and track any patterns that emerge individually or from larger groups. This helps us to develop and improve our websites and services in response to what our visitors want and need; and
  • to provide information on our services contract, hopefully means less time spent trawling pages and more time on the things that matter.

Cookies are either:

• • Session cookies: these are only stored on your computer during your web session and are automatically deleted when you close your browser – they usually store an anonymous session ID allowing you to browse a website without having to log in to each page but they do not collect any information from your computer; or
  • Persistent cookies: a persistent cookie is stored as a file on your computer and it remains there when you close your web browser. The cookie can be read by the websites that created it when you visit that website again. We use persistent cookies for Google Analytics and for personalisation (see below).

Cookies can also be categorised as follows:

• • Strictly necessary cookies: These cookies are essential to enable you to use the websites effectively, such as when registering on our websites, and therefore cannot be turned off. Without these cookies, the services available to you on our websites cannot be provided. These cookies do not gather information about you that could be used for marketing or remembering where you have been on the internet.
  • Performance cookies: These cookies enable us to monitor and improve the performance of our websites. For example, they allow us to count visits, identify traffic sources and see which parts of the site are most popular.
  • Functionality cookies: These cookies allow our websites to remember choices you make (such as your user name, language or the region you are in) and provide enhanced features. For instance, we may be able to provide you with news or updates relevant to the services you use. These cookies can also be used to remember changes you have made to text size, font and other parts of web pages that you can customise. They may also be used to provide services you have requested such as viewing a video or commenting on a blog. The information these cookies collect is usually anonymised.
  • Personalisation cookies: These cookies help us to provide our services specific to you. These cookies are persistent (for as long as you are registered with us) and mean that when you log in or return to the websites, you may see information similar to that you have previously browsed.

The following Cookies are active on our website:

Cookie	Name	Purpose	More information
Google Analytics	Google Analytics (Google Inc.)	Google Analytics is a web analysis service provided by Google Inc. (“Google”). Google utilizes the Data collected to track and examine the use of this Application, to prepare reports on its activities and share them with other Google services. Google may use the Data collected to contextualize and personalize the ads of its own advertising network. Personal Data collected: Cookies and Usage Data.	Privacy Policy Opt Out.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

5. DISCLOSURES OF YOUR PERSONAL DATA

We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.

• Internal third parties such as, our employees or officers who are based in the United Kingdom and provide IT and/or system administration services.
• External third parties such as:
  • specialist IT support, suppliers and sub-contractors for the performance of this site, including Cubic Design;
  • other outsourced service providers of [Account, HR, marketing] services, including [Microsoft Office 365, Bullhorn, Cashflow, Text-marketer, Mailchimp, Productive Payroll, Shield, Nova]
  • professional advisers including lawyers, bankers and insurers who provide consultancy, banking, legal, insurance and accounting services; and
  • HM Revenue & Customs, regulators and other authorities who require reporting or processing activities in certain circumstances.
  • Our Clients (we will let you know in advance who this will be).
• Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice. We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.