Updated: May 2018
Deltra Recruitment Ltd, 30 City Road, London, EC1Y 2AB and its subsidiaries (“Deltra Group Ltd”, “Group”, ”We”, “Us”, “Our”) 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.
This notice sets out the basis on which any personal data we collect from you or retain about you will be used by us.
The General Data Protection Regulation (“GDPR”) (Regulation (EU) 2016/679) is a new regulation that replaces the Data Protection Regulation (Directive 95/46/EC). GDPR aims to unify data protection legislation across EU member states, enhancing privacy rights for individuals and providing a strict framework within which commercial organisations can legally collect, retain and use personal information.
For the purposes of GDPR, the data controller is Deltra Recruitment Ltd, 30 City Road, London, EC1Y 2AB, with registration number 7394054.
What information do we collect?
We will be the Data Controller of the personal data you provide to us. We'll only collect basic personal data about you, we do this so we can provide our services to you. We do not collect any special types of information or location based information. This does however include personal data such as name, address, email, phone number, work history, and where relevant a copy of you CV or Profile.
You could be:
- A client we engage with for supplying recruitment services
- A candidate we represent for new opportunities
- An employee on a permanent, temporary or contract basis.
Why do we need your information?
We need to know your basic personal data in order to provide you with recruitment services. We will not collect any personal data from you that we do not need to provide this service to you.A fundamental process of our business is to introduce candidates to clients for permanent employment, temporary assignments or professional contracts. Using your information in this way is called our Legitimate Business Interest.
In addition to Legitimate Interest, we may also rely on contractual and legal obligation and consent, for various different business processes. When we enter into a contract with you we need this data to provide the service to you. We also need to retain this data to fulfil our legal obligation to authorities.If we require consent to perform a particular function, we will request this from you.
How do we collect your information?
We collect personal information about you from a range of sources, including our website when you apply for a job or when you complete an online form. We may also collect your data from third parties we work with such as subscribed or publicly available sources such as directories, job boards, online CV libraries, corporate websites and social media sites, such as LinkedIn.
If we collect information from a public source we will establish contact with you within 5 days, otherwise your information will be deleted. We will tell you what information we hold, where it was sourced and the purposes for which we intend to store and process your information.
What do we do with your information?
All the personal data we collect is processed by our employees in the UK, however for the purposes of IT hosting and maintenance this information is located on servers within the European Union.
In the process of providing recruitment services, we will need to share your data with some third parties, such as introducing a candidate to a client, arranging interviews between candidates and clients, reference agencies and any compliance obligations. We also use third party suppliers in supporting our services to you.
There are situations where third parties need to process your information, such as lawfully fulfilling their contractual obligation as our data processor or to fulfil their legal obligation.
We may also share your information with third parties if we sell or buy any business or asset, as we will need to disclose your information to a potential buyer or seller of services.If we are acquired then your information would be shared as part of our transferred assets.
We do not utilise automated decision-making or profiling in our systems. We do use our 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.
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 website, 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 to us is not completely secure. Although we will do our best to protect your personal information, we cannot guarantee the security of information transmitted to us directly and any transmission is at your own risk. Once we have received your information, we use strict security procedures and features to minimise and prevent unauthorised access.
All of the data we capture is stored on a secure server and encrypted. It is only accessible by authorised users and we deploy many security systems to ensure unauthorised access it not permitted. Access to your information is only granted to approved and authorised users. Data transmitted between the internal user and the server is encrypted to ensure it is protected in transit.
How long do we keep it?
We understand our legal duty to retain accurate information and only retain personal information for as long as we need to for our legitimate business interests and that you are happy for us to do so. Accordingly, we have a data retention notice and routinely run reports to identify and remove data that we no longer have a legitimate business interest in maintaining.
Your information will be held under our legitimate interest for 4 years, unless we receive instruction to remove it. If you are submitted to any position with our clients, we are required by The Conduct of Employment Agencies and Employment Businesses (Amendment) Regulations 2016 to retain your data for at least 12 months following the activity. We are also required under UK tax law to keep your basic personal data (name, address, contact details) for a minimum of 6 years for any contractual arrangement made as a result of a placement, after which time it will be deleted. Your information we use for marketing purposes will be kept with us until you Opt Out to receive this information, or 4 years if we receive no further instruction.
We try to ensure the information we hold about you is accurate by:
- Enabling you to manage your information by logging onto our portal at https://candidate.deltragroup.com/mercury.candidateportal/app/#/mercury.candidateportal/app/login and to review whether the details we hold about you are accurate
- Enabling you to keep in touch with us so you can let us know of changes to your personal information.
- 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).This will be subject to any legal obligations to retain records, in which case your data will be pseudonomised.
- 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 your personal information. This enables you to ask us to suspend the processing of your personal information, 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.
The criteria we use to determine whether we should retain your personal information includes:
- Our legal obligations.
- Whether an interview or placement has been arranged.
- Our recruitment expertise and knowledge of the industry by country, sector and job role.
- Whether you have told us you want to be contacted about future job opportunities.
Due to legal obligations, we may archive part or all of your personal information or retain it on our financial systems only, deleting all or part of it from our main Customer Relationship Manager (CRM) system. We may pseudonomise parts of your information, particularly following a request for suppression or erasure of your information.If your information is deleted we will have no record of you remaining, so may re-engage with you if your information is available in a public location.
What are your rights?
Our website and communications may, from time to time, contain links to or from the websites of our partner networks 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.
You have various rights under the GDPR which include:
Make a complaint. In the first instance we would ask to you to contact our Consultants and register the issue, allowing us to respond within 14 days.If you are not satisfied with the response, we suggest you contact 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/.
If at any point you would like us to stop processing your data, then you can do so by emailing one of our Consultants, who will action that request.
If at any point you believe the information we process on you is incorrect, you can request to see this information and even have it corrected or delete it via the Portal.