Privacy Notice and GDPR Policy

Introduction
Context
Who we are and what we do
How we obtain your Personal Data
Why we hold your Personal Data and how we use it
The legal basis for processing your Personal Data
Who do we share your Personal Data with
Where do we store your Personal Data
How long will we store your Personal Data for
Your Rights
Subject Access to Information
Cookies
Changes to our Privacy Notice
Contact

1. Introduction

This Privacy Notice applies to The Drury Partnership Limited and 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 person responsible for data protection can be contacted by emailing dataprotection@thedrurypartnership.com.

2. Context

The General Data Protection Regulation (Regulation (EU) 2016/679), known as the GDPR, is a new regulation which replaces the Data Protection Regulation (Directive 95/46/EC). The GDPR 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.

Please read the following carefully to understand our views and practices regarding your personal information and how we will treat it. If you have any questions about this Privacy Notice or the use of your information by The Drury Partnership, please contact us at dataprotection@thedrurypartnership.com.

3. Who are we and what we do

We are a specialist headhunting business.

Head office – Crossways, West Stoughton, Wedmore BS28 4PW

We collect the personal data of the following types of people to allow us to undertake our business;

• Prospective and placed candidates for permanent and temporary roles

• Prospective and live client contacts

• Supplier contacts to support our services, including agency contacts

• Employees, consultants, temporary workers and locoms

We collect information about you to carry out our core business and ancillary activities.

4. How we obtain your Personal Data

A) Information you give us or we may collect from you

We may collect information about you when you fill in forms or by corresponding with us by phone, e-mail or otherwise.

The information you give us or we collect about you may include:

Information contained in your CV or job application such as your name, address, private and corporate e-mail address and phone number
Information contained in any documents that you send to any of us for identity verification purposes such as your passport or driving licence
Financial information, compliance documentation and references verifying your qualifications and experience and your right to work in the United Kingdom
Links to your professional profiles available in the public domain e.g. LinkedIn, Twitter, business Facebook or corporate website
Information that you provide about yourself when negotiating or entering into a contract with us.

B) Information we collect about you when you visit our websites

With regard to each of your visits to our website, we will automatically collect the following information:

Information that you provide by filling in forms. This includes information provided to us at the time of registering to use any of our websites (where applicable), subscribing to any of our services (where applicable).
Technical information relating to your visits including, but not limited to, traffic data, location data, weblogs, other communication data and the resources that you access;
Information when you respond to a survey and/or when you report a problem with one any of our websites.

C) Information we obtain from other sources

This is information that we obtained about you from other sources such as LinkedIn, corporate websites, job boards, online CV libraries, your business card and personal recommendations.

5. Why we hold your Personal Data and how we use it

Our core service to both candidates and clients is to introduce suitably qualified and experienced candidates to our clients for the purpose of temporary or permanent engagement.

If you are a candidate, we may use information held about you:

To process your application to register with us;
For matching you with any of our clients and placing you with any of our clients for work assignments;
To engage you or your company for temporary assignment(s);
To contact you for future work-finding services.

In addition, or if you are a client or other third party, we may use information held about you in the following ways:

To carry out our obligations arising from any contracts entered into between you and us;
To notify you about changes to any of our services;
For client service, customer satisfaction, product analysis and market research purposes;
To ensure that content from our websites is presented in the most effective manner for you and for your computer;
To provide you with information or services that you expressly request from any of us or which any us feels may interest you, where you have consented to be contacted for such purposes;
To meet any of our obligations under any applicable laws or regulations;
To carry out any obligations or provide you with any other services, functionality or content which you specifically agree to on any of our websites;
To help us establish, exercise or defend legal claims.

Except for the mailing list activities we will not use your personal information collected from our websites to carry out unsolicited marketing activities. You may change your marketing preferences at any time by contacting us at dataprotection@thedurypartnership.com

We do not use your personal information to make automated decisions. All our recruitment activities and ancillary services involve human decision making in the process.

6. The legal basis for processing your Personal Data

Depending on the purpose that we hold and process your data for, we will rely on one or more of the following legal grounds to process your data:

(a) Legitimate Interests

We will rely on legitimate business interests to process your personal data to carry out work-finding services for you, to introduce candidates to our 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.

Legitimate Interests means the interests of The Drury Partnership in conducting and managing our recruitment business. For example, we have an interest in ensuring that the information provided in your CV and/or job application is correct and that you have the necessary skills and experience to meet our client’s requirements.

Legitimate Interests can also apply to the processing of data that is in your interests. For example, we only wish to put you forward for roles that you want to perform and that you have the right skills to deliver so that you have the best chance of your application succeeding.

When we process your personal information, we make sure we consider and balance any potential impact on you (both positive and negative), and your rights under data protection laws. We will not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).

(b) Necessary for the performance of a contract

We will rely on contract if you are appointed to undertake an assignment at a client (whether as a contractor or temporary worker). Your personal data will be processed as necessary throughout the assignment in order to perform the contract. We will also rely on contract if we are negotiating or have entered into a 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 you to fulfil our legal obligations.

(d) Consent

We will ask for your explicit consent to pass your personal data to a client for consideration for permanent employment or temporary assignment. We will request your consent orally, by email or by an online process. Should we want or need to rely on consent for other processing activities, we will request consent orally, by email or by an online process for the specific activity we require consent for. Your responses will be recorded on our system.

Where consent is the lawful basis for our processing you have the right to withdraw your consent to this particular activity at any time by emailing dataprotection@thedrurypartnership.com

7. Who do we share your Personal Data with?

We may share your personal data with:

Clients and/ or their appointed agents in relation to roles you wish to be considered for or assignments you are engaged to perform. We will only ever provide your details to a client / their agent in relation to a potential role if you have consented to us doing so;

Third parties to enable the completion of pre-engagement screening checks, for example current, past or prospective employers. We will notify you in advance of the pre-engagement checks we will undertake and seek your permission to us carrying them out;

We may disclose your personal data to third parties:

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 our website terms of use and other agreements, or to protect the rights, property or safety of The Drury Partnership Ltd, our customers, and others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
In the event that any of us sell or buy any business or assets, in which case each of us may disclose your personal information to the prospective seller or buyer of such business or assets.
In the event that any of us outsource any of our business functions under which we collect or store your information in which case we will ensure that any such service provider adheres to at least the same obligations of security with regard to your information as undertaken by us.
Where any of us use your information to carry out credit assessments we will need to share your information with credit reference agencies to assess your eligibility to register with us as a candidate and to verify your identity;

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 data controller;
For the purpose of a contract in place or in contemplation;
To fulfil legal obligations.

8. Where do we store your Personal Data?

We will take all steps reasonably necessary to ensure that your information is treated securely and in accordance with this Privacy Notice.

All information that you provide to us in physical form such as documents will be stored securely at our officesl.

All information you provide to us electronically is stored on our secure servers located in the United Kingdom.

9. How long will we store your Personal Data for?

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.

As a general rule, if you are a candidate, your information will be held for as long as you are actively engaging with us in order to receive work finding services.

If you cease to actively engage with us:

If you are a candidate seeking a permanent or fixed term engagement we will retain your personal data for a two (2) years after the date we last had meaningful contact with you;
If you are a candidate seeking a temporary assignment or a contracting role we will retain your personal data for two (2) years after date we last had meaningful contact with you (or, where appropriate the company you are working for or with);

10. Your Rights

You have the right to ask us not to process your personal information for marketing purposes. We will usually inform you (before collecting your information) if we wish to use your information for such purposes or if we intend to disclose your information to any third party for such purposes and we will collect your 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 information. You can also exercise the right at any time by contacting dataprotection@thedrurypartnership.com

The GDPR provides you with the following rights. To:

Request correction of 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 removed 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 restrictions 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 at: https://ico.org.uk/concerns/

If you want to contact us to exercise any of your rights, you can write to The Drury Partnership, Crossways, West Stoughton, Wedmore, BS28 4PW.

11. Subject Access to information

The Data Protection Act 1998 (the “Act”), which is the current UK data protection law until 25th May 2018, and the GDPR, which comes into effect on 25th May 2018, give you the right to access information held about you.

Your right of access can be exercised in accordance with the Act (until 25th May 2018) and the GDPR (on and after 25th May 2018). Any access request under the Act may be subject to a fee to meet any of our costs in providing you with details of the information any of us holds about you. No fee will apply once the GDPR comes into force.

A subject access request should be sent to dataprotection@thedurypartnership.com

12. Cookies

A cookie is a bite-sized piece of data that is stored on your computer’s hard drive. Almost all websites use them and they do not harm your system. We use them to track your activity on our websites and to distinguish you from other users. This helps us to provide you with a good experience when you browse our websites and also allows us to improve functionality, analyse traffic and for advertising purposes. For more information about how and why we use cookies, see our Cookie Policy on our websites.

13. Changes to our Privacy Notice

Any changes we may make to our Privacy Notice in the future will be publicised on this page.

14. Contact

Questions, comments and requests regarding this Privacy Notice are welcomed and should be addressed to dataprotection@thedrurypartnership.com