https://www.dcmoperations.com (our website) is provided by Wix Web Hosting. Derwent Capital Management (‘we’, ‘our’ or ‘us’). We are the controller of personal data obtained via our website, meaning we are the organisation legally responsible for deciding how and for what purposes it is used.
When we do so we are subject to the UK General Data Protection Regulation (UK GDPR). We are also subject to the EU General Data Protection Regulation (EU GDPR) in relation to goods and services we offer to individuals in the European Economic Area (EEA).
What this policy applies to This policy relates to how we collect personal data from you - in person, by telephone, text or email and/or via our Website.
Personal data we collect about you The personal data we collect about you depends on the particular activities carried out. We will collect and use the following personal data about you: - your name and contact information, including email address and telephone number and company details if applicable, along with any other information including on your CV - information to check and verify your identity, eg your date of birth - your gender, if you choose to give this to us - your billing information, transaction and payment card information - your personal or professional interests - your professional online presence, eg LinkedIn profile - Information about how you use our website, IT, communication and other systems
We collect and use this personal data for the purposes described in the section ‘How and why we use your personal data’ below.
Personal data provided by you As part of the recruitment process, we may ask you for further personal information in order to perform our services. We may request the following from you: - Name - Address - CV (including employment history) - References - Details of education - Next of Kin - Anything specific requested by a potential employer The legal basis for us collecting and holding this data is legitimate business interest and we will hold this data in line with our retention policy.
Third Parties We may also collect data from third parties including but not limited to: - Linkedin - References - Referrals - Recruitment agencies
The legal basis for us collecting and holding this data is a legitimate business interest and we will hold this data in line with our retention policy. Once we have received your personal data from a third party source, we will always request your consent in order to keep the data. If consent is not given by you, we will immediately erase the data. Should you consent to our holding your data on file, our legal basis will be legitimate business interest. We will not send any information to any third party (unless required by law or as part of our internal processes) prior to gaining your consent.Prior to sending your CV to a potential client, we will send your CV to an outsourced CV formatting service which may be outside of the EEA.
Should we find a role for you, we may also request the following information: - Bank details - DBS - Credit Check - Passport check The legal basis for us collecting and holding this data is contractual in order to carry out our services under a contract for service or contract of service or for legal purposes.
We collect personal data from you: - directly, when you enter or send us information, such as when you, and - indirectly, such as your browsing activity while on our website; we will collect information indirectly using the technologies explain in the section on ‘Cookies below.
How and why we use your personal data We collect basic personal information relating to our recruitment services. We ask for more detailed information as part of the recruitment process to assess your eligibility for a role, including previous work experience and geographic location.
Under data protection law, we can only use your personal data if we have a valid reason, eg: - where you have given consent - to comply with our legal and regulatory obligations - for the performance of a contract with you or to take steps at your request before entering into a contract, or - for our legitimate interests or those of a third party
A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests. We will carry out an assessment when relying on legitimate interests, to balance our interests against your own. You can obtain details of this assessment by contacting us (see ‘How to contact us’ below).
The table below explains what we use your personal data for and why.
What we use your personal data for Providing services to you
Our reasons To perform our contract with you or to take steps at your request before entering into a contract
What we use your personal data for Conducting checks to identify you and verify your identity or to help prevent and detect fraud against you or us
Our reasons To comply with our legal and regulatory obligations and for our legitimate interests or those of a third party, ie to minimise fraud that could be damaging for you and/or us
What we use your personal data for Customise our website and its content to your particular preferences based on a record of your selected preferences or on your use of our website
Our reasons Where we are not required to obtain your consent and do not do so, for our legitimate interests or those of a third party, ie to be as efficient as we can so we can deliver the best service to you at the best price
What we use your personal data for Communications with you not related to marketing, including about changes to our terms or policies or changes to the services or other important notices
Our reasons Depending on the circumstances: - to comply with our legal and regulatory obligations - in other cases, for our legitimate interests or those of a third party, ie to be as efficient as we can so we can deliver the best service to you at the best price
What we use your personal data for Protecting the security of systems and data
Our reasons To comply with our legal and regulatory obligations
We may also use your personal data to ensure the security of systems and data to a standard that goes beyond our legal obligations, and in those cases our reasons are for our legitimate interests or those of a third party, ie to protect systems and data and to prevent and detect criminal activity that could be damaging for you and/or us
What we use your personal data for Disclosures and other activities necessary to comply with legal and regulatory obligations that apply to our business, eg to record and demonstrate evidence of your consents where relevant
Our reasons To comply with our legal and regulatory obligations
What we use your personal data for Marketing our services to existing and former customers
Our reasons For our legitimate interests or those of a third party, ie to promote our business to existing and former customers
See ‘Marketing’ below for further information
What we use your personal data for External audits and quality checks, eg for the audit of our accounts
Our reasons For our legitimate interests or a those of a third party, ie to maintain our accreditations so we can demonstrate we operate at the highest standards
What we use your personal data for To share your personal data with members of our group and third parties in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of our insolvency
In such cases information will be anonymised where possible and only shared where necessary
Our reasons Depending on the circumstances: - to comply with our legal and regulatory obligations - in other cases, for our legitimate interests or those of a third party, ie to protect, realise or grow the value in our business and assets
See ‘Who we share your personal data with’ for further information on the steps we will take to protect your personal data where we need to share it with others.
Marketing We may use your personal data to send you updates (by email, text message, telephone or post) about our services, including exclusive offers, promotions or new services.
We have a legitimate interest in using your personal data for marketing purposes (see above ‘How and why we use your personal data’). This means we do not usually need your consent to send you marketing information. However, where consent is needed, we will ask for this separately and clearly.You have the right to opt out of receiving marketing communications at any time by contacting us at email@example.com
We may ask you to confirm or update your marketing preferences if you ask us to provide further services in the future, or if there are changes in the law, regulation, or the structure of our business.
We will always treat your personal data with the utmost respect and never sell it with other organisations for marketing purposes.
For more information on your right to object at any time to your personal data being used for marketing purposes, see ‘Your rights’ below.
Who we share your personal data with As a recruitment agency our role is to share candidate information with prospective employers with your consent. Outside of this, we will only share personal information with others when we are legally permitted to do so. We do not sell your data to any third parties.
Collection of data alone does not permit us to send information third parties. In order to perform our recruitment services, we will ask for your permission in order to share information to third parties as part of the recruitment process, including passing candidate details to prospective employers. We may also share your details with our accounts, governmental bodies and HMRC and any other professional body if so required.
We routinely share personal data with: - third parties we use to help deliver our services to you, eg payment service providers; and - other third parties we use to help us run our business, eg website hosts and website analytics providers.
We or the third parties mentioned above may occasionally also need to share personal data with: - external auditors, eg in relation to the audit of our accounts, in which case the recipient of the information will be bound by confidentiality obligations - professional advisors (such as lawyers and other advisors), in which case the recipient of the information will be bound by confidentiality obligations - law enforcement agencies, courts, tribunals and regulatory bodies to comply with our legal and regulatory obligations - other parties in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of our insolvency—usually, information will be anonymised but this may not always be possible, however, the recipient of the information will be bound by confidentiality obligations
If you would like more information about who we share our data with and why, please contact us (see ‘How to contact us’ below).
How long your personal data will be kept We will not keep your personal data for longer than we need it for the purpose for which it is used.
We have a legitimate business interest to keep your personal information securely stored for as long as we need it to provide you with the services you want from us.
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. Our standard retention period for potential candidate data is 7 years.
When deciding what the correct time is to keep the data, we look at its amount, nature and sensitivity, potential risk of harm from unauthorised use or disclosure, the processing purposes, if these can be achieved by other means and legal requirements.
For tax purposes the law requires us to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they stop being customers.
In some circumstances we may anonymise your personal data for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
Transferring your personal data out of the UK The EEA, UK and other countries outside the EEA and the UK have differing data protection laws, some of which may provide lower levels of protection of privacy.
It is sometimes necessary for us to share your personal data to countries outside the UK and EEA. In those cases we will comply with applicable UK and EEA laws designed to ensure the privacy of your personal data.
Under data protection laws, we can only transfer your personal data to a country outside the UK/EEA where: - in the case of transfers subject to UK data protection law, the UK government has decided the particular country ensures an adequate level of protection of personal data (known as an ‘adequacy regulation’) further to Article 45 of the UK GDPR - in the case of transfers subject to EEA data protection laws, the European Commission has decided that the particular country ensures an adequate level of protection of personal data (known as an ‘adequacy decision’) further to Article 45 of the EU GDPR - there are appropriate safeguards in place, together with enforceable rights and effective legal remedies for you, ora specific exception applies under relevant data protection law
Where we transfer your personal data outside the UK we do so on the basis of an adequacy regulation or (where such is not available). In the event we cannot or choose not to continue to rely on either of those mechanisms at any time we will not transfer your personal data outside the UK unless we can do so on the basis of an alternative mechanism or exception provided by UK data protection law.
Your rights You generally have the following rights, which you can usually exercise free of charge:
Your right Access to a copy of your personal data
Description The right to be provided with a copy of your personal data
Your right Correction (also known as rectification)
D The right to require us to correct any mistakes in your personal data
Your right Erasure (also known as the right to be forgotten)
Description The right to require us to delete your personal data—in certain situations
Your right Restriction of use
Description The right to require us to restrict use of your personal data in certain circumstances, eg if you contest the accuracy of the data
Your right Data portability
Description The right to receive the personal data you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations
Your right To object to use
Description The right to object: - at any time to your personal data being used for direct marketing (including profiling) - in certain other situations to our continued use of your personal data, eg where we use your personal data for our legitimate interests.
Your right Not to be subject to decisions without human involvement
Description The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you
We do not make any such decisions based on data collected by our website.
For further information on each of those rights, including the circumstances in which they do and do not apply, please contact us (see ‘How to contact us’ below). You may also find it helpful to refer to the guidance from the UK’s Information Commissioner on your rights under the UK GDPR.
If you would like to exercise any of those rights, please email, call or write to us—see below: ‘How to contact us’. When contacting us please: - provide enough information to identify yourself and any additional identity information we may reasonably request from you, and - let us know which right(s) you want to exercise and the information to which your request relates.
Keeping your personal data secure We have appropriate security measures to prevent personal data from being accidentally lost, or used or accessed unlawfully. We limit access to your personal data to those who have a genuine business need to access it.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
How to complain Please contact us if you have any queries or concerns about our use of your information (see below ‘How to contact us’). We hope we will be able to resolve any issues you may have.
You also have the right to lodge a complaint with the Information Commissioner.
The Information Commissioner may be contacted at https://ico.org.uk/make-a-complaint or by telephone: 0303 123 1113.