PRIVACY POLICY

At Davenport Oxley Limited we take the privacy of our clients, candidates and visitors seriously.

 

Davenport Oxley is committed to protecting and respecting your privacy. This policy 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.

 

For the purposes of this Privacy Notice, our commercial activities and services for individuals and businesses are referred to as ‘Recruitment Services’, and our actual or potential hiring customers are referred to as ‘Clients’.

 

Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

 

SECTION 1

 

Our Legitimate Business Interests

 

Our legitimate interests in collecting, retaining and processing your personal data is 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 and candidate information.

 

To maintain, expand and develop our business we need to record the personal data of prospective candidates and client contacts.

 

This section applies to individuals wishing to use or using our Recruitment Services or looking for a role to work with us (‘a Candidate’).

 

The personal data we collect or receive includes the following as applicable:

 

  • Name.
  • Address.
  • Email and other contact details.
  • Date of birth.
  • Remuneration details.
  • Work history (including information relating to placements through Davenport Oxley Limited).
  • Educational history, qualifications & skills.
  • Visa and other right to work or identity information.
  • Passport.
  • National insurance details.
  • Contact details of referees.
  • Information contained in references and pre-employment checks from third parties
  • References and links to your professional profiles available in the public domain such as LinkedIn, Twitter or corporate website.
  • Other sensitive personal information such as health records or criminal record checks (see ‘Sensitive Personal Data’ section below).
  • Your marketing preferences.

 

We may obtain your personal data from the following sources (please note that this list is not exhaustive):

 

  • Directly from you (e.g. a Curriculum Vitae, application or registering an interest in job seeking, response to a survey, information provided at events).
  • By reference or word or mouth, for instance you may have been recommended by a friend, former employer or colleague.
  • Job boards that you have registered your details on.
  • Online Curriculum vitae libraries.
  • The public domain e.g. corporate websites.
  • Social Media.
  • Conversations on the telephone or video conferencing (We do not record telephone or video conference conversations).
  • Notes following a conversation or meeting.
  • Our website contact forms and software applications.

 

Where you are a Candidate and we have obtained your personal data from a third party such as an online job board, it is our policy to advise you of the source when we first communicate with you.

 

How do we use your personal data?

 

We use your personal data so that we can provide our Recruitment Services to you, including:

 

  • Managing and maintaining our relationship with you to perform administration of operational functions.
  • Provide you with recruitment services, which may include career guidance and notifying you of potential roles or opportunities.
  • Assessing and reviewing your suitability for job roles.
  • Introducing and/or supplying you to actual or potential Clients.
  • Managing and maintaining our relationship with you to perform administration of operational functions.
  • Engaging you for a role with us or with our Clients.
  • Conduct market research and satisfaction surveys.
  • Collating market or sector specific information and providing the same to our Clients
  • Responding to your queries.
  • Sending information to third parties with whom we have or intend to enter into arrangements which are related to our Recruitment Services.
  • Providing information to regulatory authorities or statutory bodies, and our legal or other professional advisers including insurers.
  • Advise you of news, reports, industry updates, events, services, promotions and any other information that we feel may be of interest to you
  • Retaining a record of our dealings.
  • Establishing quality, training and compliance with our obligations and best practice.
  • For the purposes of backing up information on our computer systems.
  • Notify you of any changes to our Recruitment Services or this Privacy Policy.

 

What if we obtain your personal data from a third party?

 

Part of our business activity involves researching information relating to individuals for the purposes of filling job roles. This may include obtaining personal data from online sources, for example we may obtain information from social media sites such as LinkedIn and job boards, some information being publicly available but others being from sites or providers to which we subscribe. From time to time we may also receive personal information about you from hiring organisations, colleagues and former employers, or from persons for whom you have provided services or been otherwise engaged.

 

Where information from third party sources is of no use to us, or where you have notified us that you do not want us to provide you with services, we shall discard it, however we may maintain a limited record in order to avoid the duplication of process. Where we consider that information may be of use to us in pursuance of the provision of our Recruitment Services, any processing will be in accordance with this Privacy Policy. You do have the right to object to processing, please see Section 4 ‘Your rights’.

 

Automated decisions

 

Our processing of data as detailed above will always be subject to human review and involvement.

 

SECTION 2

 

This section applies where you are an individual working for a third party with whom we have dealings. For example, a Client.

 

We may collect your personal data in the course of our dealings and this may include the following:

 

  • Your contact information, which may include your full name, job role, contact telephone number and email
  • Your statements and opinions about candidates and/or other personnel e.g. a reference
  • Information relating to our relationship with you or the party for whom you work including records of any meetings or discussions
  • Your marketing preferences

 

We may obtain your personal data from the following sources (please note that this list is not exhaustive):

 

  • Directly from you, including where you have provided us with your contact details or other information for the purposes of using our Recruitment Services.
  • Colleagues or other representatives of the organisation you represent.
  • Candidates.
  • Marketing databases
  • Social media.
  • The public domain
  • Conversations, with you or others, on the telephone or video conferencing (which may be recorded) or in meetings.
  • Notes following a conversation, with you or others, or meetings you attend.

 

How we will use your personal data:

 

We will process your personal data in the context of our dealings with the third party for whom you work and as part of our Recruitment Services. Processing may include:

 

  • Manage and maintain our business relationship.
  • Using the data to communicate with you.
  • Sending information to third parties with whom we have or intend to enter into arrangements which are related to our Recruitment Services.
  • Actions necessary to further any obligation on us pursuant to a contract between ourselves and the third party you work for.
  • Collating market or sector specific information.
  • Carrying out market research, marketing analysis and satisfaction surveys.
  • Advising you of new, industry updates, events and services.
  • Providing information to regulatory authorities or statutory bodies and our legal or other professional advisers including insurers.
  • Retaining records of our dealings with you and the organisation whom you represent.
  • Establishing quality, training and compliance with our obligations and best practice.

 

SECTION 3

 

This section applies to all personal data.

 

Sensitive Personal Data

 

Sensitive personal data is information which is intensely personal to you and is usually irrelevant to our consideration of your suitability for a job role. Examples of SPD include information which reveals your political, religious or philosophical beliefs, sexual orientation, race or ethnic origin, criminal record or information relating to your health.

 

We request that you do not provide us with any sensitive personal data unless absolutely necessary. However, to the extent that you do provide us with any sensitive personal data, such as data which you choose to share with us in conversation, we shall only use that data for the purposes of our relationship with you or for the provision of our Recruitment Services. This will be for one or more of the following reasons:

 

  • You have explicitly consented to the processing
  • For the purpose of our assessment of your suitability for job roles or working capacity
  • Where processing is necessary for the purpose of obligations or rights under employment, social security or social protection law
  • To maintain records of our dealings to address any later dispute, including but not limited to the establishment, exercise or defence of any legal claims

 

Who your data is shared with

 

Your personal data may be shared with certain third parties who will be subject to contractual obligations of confidentiality and compliance with relevant laws. Those with whom we share your personal data with may include:

 

  • Our employees.
  • Individuals, hirers and other third parties necessary for the provision of our Recruitment Services.
  • Any regulatory authority or statutory body pursuant to a request for information or any legal obligation which applies to us.
  • Parties who process data on our behalf, which may include
    • outsourced administration providers
    • IT software and service companies
    • storage service providers including cloud background screening providers
    • legal and professional advisers
    • insurers
    • event organisers and coordinators

 

Why we process your personal data

 

To provide Recruitment Services, the exchange of personal data of our candidates and clients is fundamental to how our business operates. The exchange of personal data is required to be able to find potential candidates, assess a candidate’s suitability for roles and to contact clients in order to fulfil their hiring requirements. In order to support these functions, we require a database of both candidate and client personal data containing historical information as well as current resourcing needs. To maintain and develop our business we also need to record the personal data of prospective candidates and client contacts.

 

1. Legitimate interests
In providing our Recruitment Services, we will carry out some processing of personal data which is necessary for the purpose of our legitimate interests, which include using your personal data:

 

  • To contact you regarding our Recruitment Services
  • To assess suitability of Candidates and roles, for example, referencing or other feedback
  • To collate market information or trends including providing analysis to potential or actual Clients
  • As otherwise necessary to provide our Recruitment Services and/or to meet our obligations towards either the party whom you represent, or other Clients or suppliers
  • To personalise your experience and our offering, whether via our website or otherwise
  • Retaining records of our dealings and transactions and where applicable, use such records for the purposes of:
    • establishing compliance with contractual obligations with Clients or suppliers
    • addressing any query or dispute that may arise including establishing, exercising or defending any legal claims protecting our reputation
    • maintaining a back-up of our systems, solely for the purpose of being able to restore the system to a particular point in the event of a system failure or security breach
    • evaluating quality and compliance including compliance with this Privacy Policy determining staff training and system requirements
    • For our commercial viability and to pursue these legitimate interests, we may continue to process your personal information for as long as we consider reasonably appropriate for these purposes.

 

2. Consent
We may process your personal and sensitive personal data on the basis that you have consented to us doing so for a specific purpose or reason. Where we seek consent, this may be done orally, by email or by an online process. Where consent is not granted the Company will cease to process your personal data and sensitive personal data.

 

You may withdraw your consent to our processing of your personal information for a particular purpose at any time. However, we may continue to retain, or otherwise use your personal information thereafter where we have a legitimate interest or a legal or contractual obligation to do so. Our processing in that respect will be limited to what is necessary in furtherance of those interests or obligations.

 

3. Performance of a Contract
In order to provide our recruitment services we may enter into a contract with you and/or a third party. A contract will contain obligations on both your part and our part and we shall process your data as is necessary for the purpose of those obligations.

 

4. Compliance with legal obligations (regulatory and statutory)
We must comply with a number of statutory provisions when providing our Recruitment Services, which necessitate the processing of personal data. These include the Conduct of Employment Agencies and Employment Businesses Regulations 2003, which amongst other things requires us to:

 

  • Verify your identity
  • Assess your suitability for an external job role
  • Maintain records for specific periods

 

We are also required to comply with statutory and regulatory obligations relating to business generally, for example complying with tax, bribery, fraud/crime prevention and data protection legislation, and co-operating with regulatory authorities such as Information Commissioner’s Office or HMRC.

 

If you do not wish to provide us with necessary data

 

There may be circumstances where we require you to provide data which is necessary in order for us to meet statutory or contractual obligations, or perform our Recruitment Services. If you do not wish to provide us with information we request then please notify us. However, please be aware that as a result we may be unable to provide you or the party who you represent with a Recruitment Service, and in some cases, may result in a breach of the contract we have with you or a third party you represent.

 

Transfer of Data outside the UK and the EEA

 

Where permitted by applicable law, we may transfer your personal data to other jurisdictions outside the European Economic Area (‘EEA’) for the purposes set out in this privacy policy. We will seek your consent before transferring your personal data to jurisdictions outside the UK and the EEA. We shall ensure that any such transfers outside of the United Kingdom and the EEA are lawful and with an adequate level of protection and that your personal data is kept secure in accordance with the DPA 1998 (up to and including 24 May 2018) and the GDPR (from and including 25 May 2018).

 

Data Security and Confidentiality

 

We have implemented appropriate technical and organisational security measures designed to protect your Personal Data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure, unauthorised access, and other unlawful or unauthorised forms of Processing, in accordance with applicable law.

 

Because the internet is an open system, the transmission of information via the internet is not completely secure. Although we will implement all reasonable measures to protect your personal data, we cannot guarantee the security of your data transmitted to us using the internet – any such transmission is at your own risk and you are responsible for ensuring that any Personal Data that you send to us are sent securely.

 

Retention of your Data

 

We only retain your information for as long as necessary for us to use your information as described above or to comply with our legal obligations. When your personal data is deleted it is erased securely.

 

However please be advised that we may retain some of your information after you cease to use our services, for instance:

 

  • if it is necessary for us to comply with legal or contractual obligations.
  • it is required to defend Davenport Oxley in the event of a potential dispute.
  • for legitimate business interests.

 

If, however you have made a request for your information to be deleted, this will be processed in line with your request and not by our standard retention period. Please see Section 4 ‘Your Rights’ below.

 

Links to other Internet sites

 

Our website may provide links to other third-party internet sites. Despite these linkages, or any references to Davenport Oxley at those Internet sites, this Privacy Policy applies to this Website only. Please note when the URL indicates you are no longer on this Website, and read the privacy policy of each Internet site that you visit. Davenport Oxley is not responsible for the privacy practices of such Internet sites.

 

SECTION 4

 

Your Rights

 

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 recruitment/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 Davenport Oxley, 71 – 73 Shelton Street, London WC2 H 9JQ or email gdpr@davenportoxley.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.
  • Right to withdraw consent at any time

 

If you wish to exercise any of these rights you should, in the first instance email to gdpr@davenportoxley.com

 

Complaints

 

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/

 

Changes to our Privacy Policy

 

We reserve the right to update this privacy policy at any time, and any changes we make to our privacy policy will be posted on this page. We will notify you if there are any changes to this policy that materially affect how we collect, store or process your personal data. If we would like to use your previously collected personal data for different purposes than those we notified you about at the time of collection, we will provide you with notice and, where required by law, seek your consent, before using your personal data for a new or unrelated purpose. We may process your personal without your knowledge or consent where required by applicable law or regulation.

 

How to Contact Us

 

If you have questions, comments and requests regarding this privacy policy or if you would like to exercise your rights, please write to: Data Officer, Davenport Oxley Limited, 71 – 73 Shelton Street, London WC2H 9JQ, or email at gdpr@davenportoxley.com