Devonshire Appointments Limited (Recruitment Agency) are committed in protecting the privacy of our candidates, clients and users of our website. This policy explains what personal data we hold on you and how we process and protect that data when you use our website or services. We will only use your personal data in accordance with the terms of this statement.
Any usage below of ‘we’, ‘us’ or ‘our’ is a reference to Devonshire Appointments Limited; registered address – 3rd Floor, 88 Wood Street, London EC2V 7QT.
The General Data Protection Regulation (GDPR) law came into effect in the UK on the 25th of May 2018. Your rights in accordance with GDPR are included in this policy.
Personal information from you
As a recruitment company we must process personal data (including sensitive personal data) in order to provide services to our clients and candidates. In doing so, we act as a recruitment data controller.
You may give your personal details to us directly, such as on a CV, an application or registration form, via our website or by corresponding with us by phone, email or otherwise. Personal data that we may collect includes:
- Full name
- Identification and proof of right to work in the UK
- Contact details including; email address, phone number(s), home address
- Salary details and NI number
- Employment history (up to 10 years)
- Education Certificates
- Referee contact details
- Limited company details
Please note however, that this list is not exhaustive.
Depending on the client and the role that you have applied to work for, or that we have offered you, we may need to collect personal sensitive data. Under the General Data Protection Regulation this includes information about your health (for example details of any sick leave you may have taken during previous roles), information about any disability and details of any offences you may have committed or are alleged to have committed and adverse financial history (for example if you hold any CCJs or have been declared bankrupt).
Personal information from other sources
We offer a recommendation scheme, use LinkedIn, job boards and social media platforms and may also collect your personal information from another source. We will always advise you where we found your personal information.
Purpose of processing your personal data
We collect and hold your personal data (which may include sensitive personal data) and process that data for the following purposes:
- To provide you with employment searching services to facilitate the recruitment process;
- To assess your eligibility and suitability for any roles that we represent you for;
- To maintain our business relationship, where you are a candidate, client or a user of our website;
- To perform operational and administration functions.
Do you have to provide us with personal data?
You have the right to refuse to give us permission to hold your personal and sensitive personal data on our CRM. You also have the right to ask us to delete, change or stop processing your data that we already have. However, if you do not provide us with personal or sensitive personal data, it may restrict our ability to provide you with recruitment services.
Legal basis for holding personal data
Devonshire Appointments Limited must have a legal basis for processing your personal data. The legal bases we rely upon to pursue our processing purposes are:
- Our legitimate interest in providing you with our recruiting services, however such interests can be overridden by your privacy interests;
- Our legal obligation in some cases, for us to meet our legal or regulatory responsibilities;
- Our contractual obligations to which you are subject. This includes where we have entered into a placement agreement with you or any other contract to provide services to you both;
- Your consent to data processing for activities which we will obtain from you from time to time, for example of a situation where we would rely on consent to introduce you to a client or sign an NDA (non-disclosure agreement) asked by our client.
Where Devonshire Appointment Limited has relied on a legitimate interest to process your personal data our legitimate interests is as follows:
- To offer you the tailored and efficient recruitment service you expect of us.
As a recruitment business, we will introduce candidates to clients for permanent and temporary employment as well as offering clients’ vacancies to candidates. In order to do so, the exchange of personal data of our clients and candidates is essential to our operation.
In order to support our candidates and to assist our clients with their recruitment needs, we are required to keep a database of client and candidate personal data. Furthermore, to maintain, expand and develop our business we need to record the data of prospective candidates and client data.
We offer you a tailored service that is customised based on the information that you provide us with. We also want to offer an efficient service, which means that we need to use your data for payroll and other administrative activities.
As a recruitment business we may disclose your information to third parties where appropriate. Devonshire Appointments Limited may share your information with the following third parties:
- Our clients, your prospective employers;
- re-employment screening companies;
- Our payroll system InTime to process payroll services to candidates and clients for temporary recruitment services;
- Payment intermediaries such as an Umbrella and Limited companies;
- Government and law enforcement authorities;
- Outsourced IT and document storage providers, for example servers and cloud-based data storage services;
- Third party service providers, such as lawyers, accountants and technical support.
Any third party that we may share your data with must ensure the security of that data. Third parties are also obliged to only use your information for the purposes we have outlined. We will not pass on sensitive data to third parties without your consent, unless we are legally required to do so.
Devonshire Appointments Limited work with clients and candidates in the UK, EU, US and APAC, therefore we may transfer the information you provide to us to countries outside the European Economic Area (‘EEA’) for the purposes of providing you with work-finding services. We will take steps to ensure adequate protections are in place to ensure the security of your information and will ask for your consent before doing so.
How long we will store your information
Devonshire Appointments Limited will retain your personal data only for as long as is necessary. Different laws require us to keep different data for different periods of time.
The Conduct of Employment Agencies and Employment Businesses Regulations 2003, require us to keep work-seeker records for at least one year from (a) the date of their creation or (b) after the date on which we last provide you with work-finding services.
We must also keep your payroll records, including holiday pay, sick pay and pension auto-enrolment records for as long as is legally required by HMRC and associated national minimum wage, social security and tax legislation.
Where we have obtained your consent to process your personal and sensitive personal data, we will keep your data for 6 years after the last meaningful contact with you. Upon expiry of that period we will seek further consent from you. If consent is not granted, we will delete the personal data that we hold on you.
Please be aware that you have the following data protection rights:
- The right to be informed about the personal data we process on you;
- The right of access to the personal data we process on you;
- The right to erasure of your personal data in certain circumstances;
- The right to restrict processing of your personal data;
- The right to data portability in certain circumstances;
- The right to object to the processing of your personal data that was based on a public or legitimate interest;
- The right not to be subjected to automated decision making and profiling; and
- The right to withdraw consent at any time.
Where you have consented to us processing your personal and sensitive data you have the right to withdraw that consent at any time by contacting our data protection officer (see below).
Queries or data request
If you wish to speak about the personal or sensitive data we hold on you or if you wish to erase your data, please contact our GDPR team on GDPR@devonshire.co.uk
You also have the right to raise concerns with Information Commissioner’s Office on 0303 123 1113 or at https://ico.org.uk/concerns/, or any other relevant supervisory authority should your personal data be processed outside of the UK, if you believe that your data protection rights have not been adhered to.
Amendments made to the policy will not jeopardise the protection and privacy of your personal data.