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 – Lower Ground Floor Park House, 16-18 Finsbury Circus, London, EC2M 7EB.
In line with the General Data Protection Regulation (GDPR), 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, candidates and suppliers. In doing so, we act as a recruitment data controller.
Candidates
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
- Nationality
- 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).
Clients
You may give your company details to us directly, such as on our contact via our website or by corresponding with us by phone, email or otherwise. Personal data that we may collect and hold includes:
- Company name;
- Company website;
- Company registered address;
- Company registration number;
- Company VAT number;
- Hiring manager name;
- Hiring manager job title;
- Hiring manager contact details.
We will process company data about what communications we have had with you, including telephone conversations, emails and marketing content we have sent to you. We also process feedback that you provide about our candidates who we have presented to you for recruitment processes.
If you provide information to us about a candidate (for example, you provide a reference), then we will obtain your details from the candidate and will keep a record of the personal data that you provide to us about that candidate.
We can source personal data about you from public domain sources such as LinkedIn and social networking sites or because you were a delegate at one of our events or at an event where the event organiser is permitted to share delegate details with us.
Suppliers
We typically collect your name and contact details as a business contact for your organisation.
Personal information from other sources
We 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 and how it is used
We collect and hold your personal data (which may include sensitive personal data) and process that data for the following purposes:
Active Candidates
We use your personal data to:
- Provide you with employment searching services to facilitate the recruitment process;
- Assess your eligibility and suitability for any roles that we represent you for;
- Communicate with you;
- Enable you to upload your CV and apply for jobs;
- Personalise your experience by creating a candidate profile;
- Provide you with interviewing and salary advice;
- Enable us to monitor equality and diversity;
- Send you direct marketing for the purposes of informing you about job opportunities industry reports and insights, and other content in accordance with your marketing choices.
Prospective Candidates
We use your personal data to:
- Provide you with employment searching services to facilitate the recruitment process;
- Assess your eligibility and suitability for any roles that we represent you for;
- Provide you with interviewing and salary advice;
- Contact you and find out if you are interested in our services;
- Send you direct marketing for the purposes of informing you about job opportunities, industry reports and insights, and other content in accordance with your marketing choices.
Clients
We may use your personal data to:
- Provide recruitment services to you;
- Communicate with you;
- Get feedback from you on our services through client satisfaction surveys, salary guide information and polls;
- Maintain our business relationship with you;
- Answer your enquiries when you contact us;
- Fulfil contractual obligations to you;
- Establish, exercise or defend legal claims;
- Use for direct marketing purposes.
Suppliers
We use your personal data to:
- Communicate with you;
- Maintain our business relationship with you;
- Answer your enquiries when you contact us;
- Fulfil contractual obligations to you;
- Establish, exercise or defend legal claims; and
- Use for direct marketing purposes.
You can unsubscribe from receiving marketing communications from us, by emailing “unsubscribe” to [email protected].
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.
Legitimate interest
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.
Third Parties
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;
- 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.
We also share your personal data with third party service providers who perform services and functions on our behalf, such as:
- Conducting employment reference checks;
- Conducting qualification checks;
- Carrying out criminal convictions checks (as required);
- Carrying out other screening checks (as required)
- Verifying details you have provided from third party sources;
- Conducting psychometric evaluations or skills tests;
- Providing data analytics to us;
- Administering surveys or competitions on our behalf;
- Assisting us to communicate with you; and providing research, mailing or other direct marketing services.
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.
Overseas Transfers
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.
Where we process your personal data for direct marketing purposes, we will do so until you ask us to stop, and for a short period after this (to allow us to implement your request). We also keep a record of the fact that you have asked us not to send you direct marketing or to process your data indefinitely, so that we can respect your request.
Your rights
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 GDPR team (see below).
How to contact us
If you wish learn more about this privacy policy or any of the procedures set out in it please contact our contracts team who can help on [email protected]
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 [email protected]
If you wish you withdraw from receiving marketing communications from us or make a complaint regarding this policy or the data we hold on you, please contact our administration team on [email protected]
If you believe that your data protection rights have not been adhered to, 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.
Changes to our GDPR Privacy Policy
We may update this policy when necessary and if we make any changes we will post the updated policy on our website. We therefore encourage you to visit the privacy policy from time to time in order to keep up to date with the terms of the policy and any potential changes.
Amendments made to the policy will not jeopardise the protection and privacy of your personal data.
This Privacy Policy was last updated on 2nd August 2021.
Devonshire Appointments Limited is owned by Paragon Customer Communications. This website was created and is managed by Under2Agency.