Deverell Smith is committed to protecting and respecting the privacy of third parties (including candidates and clients who use our services and all visitors to its website www.deverellsmith.com.
This website is not intended for children and we do not knowingly collect data relating to children.
We endeavour to ensure that all data from which you can be identified (“Personal Information”) provided to, or otherwise obtained by, us is handled in accordance with the UK Data Protection Act 1998, the retained EU law version of the EU General Data Protection Regulation and all similar or related legislation (the “Data Protection Legislation“). You can be assured that your Personal Information will only be used by Deverell Smith in accordance with this privacy policy (this “Policy“).
This Policy (together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing Personal Information about you) sets out the basis on which any Personal Information we collect about you, or that you provide to us, will be processed. Please read the following carefully to understand our views and practices regarding your Personal Information and how we will treat it.
WHO WE ARE AND OUR CONTACT DETAILS
In this Policy, “Deverell Smith”, “we”, “us” and “our” refers to Deverell Smith Limited, registered in England & Wales, registered office at 2nd Floor Cannon Green, 1 Suffolk Lane, London, EC4R 0AT. Our company registration number is 05724877 and we can be contacted on 020 7291 0900. You can email our data protection manager on info@deverellsmith.com.
For the purpose of the Data Protection Legislation, the data controller is Deverell Smith in respect of any Personal Information that you provide to us or that we otherwise obtain about you.
WHAT INFORMATION DO WE COLLECT ABOUT YOU?
We may collect, use, store and transfer different kinds of Personal Information about you which we have grouped together as follows:
· Identity Data – includes your name, address, e-mail address and phone number, financial and credit card information, personal description (including, but not limited to, age, academic information and qualifications, work history and other professional information) and photographs.
· Technical[AM1] 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, device ID and other technology on the devices you use to access this website.
· Profile Data includes your username and password, services provided to you, your interests, preferences, feedback and survey responses.
· Usage Data includes information about how you interact with and use our website, products and services.
· Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
We also collect, use and share aggregated data such as statistical or demographic data which is not personal data as it does not directly (or indirectly) reveal your identity. For example, we may aggregate individuals' Usage Data to calculate the percentage of users accessing a specific website feature in order to analyse general trends in how users are interacting with our website to help improve the website and our service offering.
HOW YOUR INFORMATION IS COLLECTED
We may collect and process the following data about you:
We collect Identity Data, Profile Data and Marketing and Communications Datathat you give us by filling in forms on our Website, or by corresponding with us by phone, e-mail or otherwise. This includes information you provide when you register to use our Website, subscribe to our services, place a posting on our Website, participate in discussion boards or other social media functions on our Website, communicate via our Website (including communicating with other users), complete surveys, update your personal or company profile and when you report a problem with our Website.
As you interact with our website, we will automatically collect Technical Data and Usage Data about your equipment, browsing actions and patterns. We collect this personal data by using cookiesand other similar technologies. Please see our cookie policy for further details.
Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources, including:
Name | Purpose of data | Type of Data transferred | Location Data is Transferred to |
Microsoft Azure | Backing up our internal infrastructure | Contact information | UK, EU & US |
Microsoft Teams | Shaing internal communications | Contact information | UK, EU & US |
Bullhorn | Storing Data, Processing of Data, Marketing & Sales | Contact information, Payment preferences | Bullhorn Group Companies have entered into Standard Contractual Clauses and Switzerland and UK Addendums (collectively, “SCC”) among them as authorized by the European Commission under the GDPR and UK GDPR for the transfer of personal data from Bullhorn Group Companies in the EEA, UK, and Switzerland to Bullhorn Group Companies outside these territories. The SCC set forth the adequate safeguards for the protection of privacy and fundamental rights and freedoms of European, British and Swiss individuals for such data transfers outside the EEA, UK and Switzerland. Please use the contact information in Sec. 15 below to obtain more information on these contractual arrangements. |
Broadbean | Storing Data & Processing of Data | Contact information | UK, EU, EEA |
Docusign | Storing Data & Processing of Data | Contact information, Right to work documents | UK, EU & US |
Cloudcall | Storing Data | Contact information | We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. |
Timesheet Portal | Storing Data & Processing of Data | Contact information, Payment rates | UK, EU & US |
Processing of Data | Contact information | LinkedIn's services require data to flow from the European Union (EU), the European Economic Area (EEA), United Kingdom (UK) and Switzerland to the United States (U.S.) and back | |
Reed | Processing of Data | Contact information | Your personal data is stored on servers in the European Economic Area |
Total Jobs | Processing of Data | Contact information | UK, EU, EEA |
Indeed | Processing of Data | Contact information | UK, EU, EEA |
CV Library | Processing of Data | Contact information | UK, EU, EEA |
Glenigans | Processing of Data | Contact information | UK |
LEGAL BASES 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 and to carry out pre-engagement and pre-employment screening services (except where we are required to obtain explicit consent to carry out a check).
(b) Necessary for the performance of a contract
We will rely on contract if you are a client or if you are appointed to undertake an assignment at a client (whether as a contractor or temporary worker).
(c) Necessary for compliance with a legal obligation
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 for a temporary assignment. 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 info@deverellsmith.com.
USES MADE OF THE INFORMATION
We will only use Personal Information we hold about you (including information we receive from other sources) in the following ways, depending on the types of information:
to consider your application for a role we are seeking to fill;
to carry out our obligations arising from any contract entered into between you
to provide you with the information, products and services that you request from us, as well as support in respect of those services;
to improve our Website (e.g. to ensure that content is presented in the most effective manner for you and for your computer) and services;
to allow you to participate in interactive features of our service, when you choose to do so;
as part of our efforts to keep our website safe and secure; and
for our internal business processes.
COOKIES
Our Website uses cookies to distinguish you from other users of our Website. This helps us to provide you with a good experience when you browse our Website and also allows us to improve our Website. For detailed information on the cookies we use and the purposes for which we use them see our Cookies Policy here: https://www.deverellsmith.com/legal_documents/cookies
DIRECT MARKETING
You will receive marketing communications from us if you have registered for our services and have not opted out of receiving the marketing.
We may also analyse your Identity, Technical, Usage and Profile Data to form a view as to which products, services and offers may be of interest to you so that we can then send you relevant marketing communications.[AM2]
From time to time, we may also use your Personal Information to contact you for market research purposes. This will only happen where you have consented to receiving such communications.
If you do not want us to use your Personal Information in the ways described in this Policy, please let us know by contacting us at info@deverellsmith.com. You may also opt out of receiving marketing emails from us at any time by clicking on the unsubscribe link in any marketing email.
If you opt out of receiving marketing communications, you will still receive service-related communications that are essential for administrative or customer service purposes e.g. to enable us to deliver our recruitment services to you.
HOW WE SHARE YOUR PERSONAL INFORMATION
Where it is necessary for the performance of our contract with you or for our internal business processes, we may share your Personal Information with our suppliers, contractors, third party partners (including any investors we may work with), prospective candidates/clients, and any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006.
In addition, it may be necessary to disclose your Personal Information if we are under a legal obligation, or in order to enforce or apply our Website Terms of Use or other agreements; or to protect the rights, property, or safety of Deverell Smith, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
If Deverell Smith enters into a joint venture with, purchases or is sold to or merges with another business entity, or in the event that we sell or buy any business or assets, or substantially all of our assets are acquired by a third party, your Personal Information may be disclosed or transferred to the purchaser, our new business partners or owners or their advisors.
[AM3] We may make use of the Personal Information we have collected from you to enable us to comply with our advertisers’ wishes by displaying their advertisement to that target audience.[U4]
We require all third parties to respect the security of your Personal Information and to treat it in accordance with the law. We do not allow our third-party service providers to use your Personal Information for their own purposes and only permit them to process your Personal Information for specified purposes and in accordance with our instructions.
OUR SECURITY AND DATA RETENTION MEASURES
All Personal Information you provide to us is stored on our secure servers in the European Economic Area, and we take steps to protect your Personal Information from unauthorised access and against unlawful processing, accidental loss, destruction and damage. To the extent that we take any payments from you, these will be encrypted. 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.
In addition, we limit access to your Personal Information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your Personal Information on our instructions and they are subject to a duty of confidentiality.
We will only keep your Personal Information for as long as is reasonably necessary to fulfil the purposes we collected it for, including for the purposes any legal, regulatory, tax, accounting or reporting requirements. We may retain your Personal Information for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
In some circumstances you can ask us to delete your data: see below section called Your Rights below for further information.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your Personal Information, we cannot guarantee the security of your data transmitted to our Website; any transmission is at your own risk.
TRANSFERS OF PERSONAL INORMATION OVERSEAS
In processing your Personal Information, it may be necessary for us to transfer your Personal Information outside the European Economic Area (“EEA“)to staff operating outside the EEA who work for us or for one of our suppliers. This includes staff engaged in, among other things, the provision of support services[U5] .
We will take all steps reasonably necessary to ensure that your Personal Information is treated securely and in accordance with this Policy and the Data Protection Legislation when it is processed in, or other accessed from, a location outside the EEA. This means that we will only transfer your Personal Information to third parties outside the EEA if that third party (a) is situated in a country that has been confirmed by the European Commission as providing an adequate level of protection to Personal Information, or (b) has agreed (by way of a written contract in a standard template as provided by the data protection regulator) to provide all protections to your Personal Information as required by the Data Protection Legislation.
YOUR RIGHTS
You have a number of rights under data protection laws in relation to your Personal Information.
You have the right to:
· Request access to your Personal Information (commonly known as a "subject access request"). This enables you to receive a copy of the Personal Information we hold about you and to check that we are lawfully processing it. Please click here to make a subject access reques.
· Request correction of the Personal Information that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
· Request of 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. Please click here to request the erasure of your data.
· Object to processing of your Personal Information where we are relying on a legitimate interest (or those of a third party) as the legal basis for that particular use of your data (including carrying out profiling based on our legitimate interests). In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your right to object.
· Object any time to the processing of your Personal Information for direct marketing purposes by contacting us at info@deverellsmith.comor by clicking on the unsubscribe link in any marketing email.
· Request the transfer of your Personal Information to you or to a third party. We will provide to you, or a third party you have chosen, your Personal Information in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
· Withdraw consent at any time where we are relying on consent to process your Personal Information. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
· Request restriction of processing of your Personal Information. This enables you to ask us to suspend the processing of your Personal Information in one of the following scenarios:
o If you want us to establish the data's accuracy;
o Where our use of the data is unlawful but you do not want us to erase it;
o Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
o You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
If you wish to exercise any of the rights set out above please contact us at info@deverellsmith.com.
You will not have to pay a fee to access your Personal Information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your Personal Information (or to exercise any of your other rights). This is a security measure to ensure that Personal Information is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
COMPLAINTS
Should you have any queries or complaints in relation to how we use your Personal Information, please contact us using the details set out below. Should you wish to take any complaints or queries further, you have the right to contact the Information Commissioner’s Office (ICO), the UK regulator for data protection issues (www.ico.org.uk).
THIRD PARTY LINKS
Our Website 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.
CHANGES TO OUR PRIVACY POLICY
We keep our privacy policy under regular review. This version was last updated in January 2024.
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, for example a new address or email address.
CONTACTQuestions, comments and requests regarding this Policy are welcomed and should be addressed to info@deverellsmith.com