"We take your privacy and your rights seriously. So, we look after any information we hold as if it was our own.
Our approach is to treat everyone ethically, equally and with respect.
We’re proud that we never take a shortcut, and instead do our due diligence every step of the way ensuring our candidates always know where their data has been sent.
This covers everything from a legal perspective. Which means some of the language can be a little dry.
We’ve got to make sure that everyone knows their rights whatever happens in the future."
This section explains who our company is, the regulations that cover how we look after your data and who our data controller is...
Denholm Associates 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 (our Group)
This notice sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us.
The General Data Protection Regulation (GDPR) (Regulation (EU) 2016/679) is a new regulation which replaces the Data Protection Regulation (Directive 95/46/EC) The Regulation aims to harmonise data protection legislation across EU member states, enhancing privacy rights for individuals and providing a strict framework within which commercial organisations can legally operate.
Even though the UK has expressed its intention to leave the EU in March 2019, the GDPR will be applicable in the UK from 25th May 2018. The Government intends for the GDPR to continue in UK law post-Brexit and has also introduced a Data Protection Bill to replace the current Data Protection Act in due course.
Your new rights under the GDPR are set out in this notice but will only apply once the GDPR becomes law on 25th May 2018. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. For the purposes of data protection legislation in force from time to time, the data controller is Denholm Associates, Head Office 37 Constitution Street, Leith, Edinburgh.
Our nominated representatives are Marisa Carroll COO and Keren Van Den Broek Finance Director.
This is an outline of our business and how we can help you...
Denholm Associates (company number SC205 833) is a Recruitment, Executive Search & Employer Branding consultancy specialising in Marketing & Sales as defined in the Employment Agencies & Employment Businesses Regulation 2003. Established since 2002, we have offices in Edinburgh and Glasgow.
As your Data Controller, we collect the personal data of the following types of people to allow us to undertake our business;
- Prospective and placed candidates for permanent, interim or temporary roles;
- Prospective and live client contacts;
- Supplier contacts to support our services;
- Employees, consultants, temporary workers;
We collect information and data about you to enable us to carry out our core business and ancillary services.
This section talks about why we need to keep information about you and the sort of things we store. Plus, the information we collect about you when you visit our website to help build up a better picture of what you’re looking for. Information is also obtained from other sources and we cover how we use information, like LinkedIn profiles to match people and jobs...
In order to allow us to provide our services across Recruitment, Executive Search and Employer Branding, you give us, or we collect the following data, which can be collected across a number of channels. When you apply through an advert on our website (www.denholmassociates.com), through telephoning us directly, via email or otherwise. It includes information you provide when you register to use our site, to enter our CRM, subscribe to our services, attend our events, or other social media functions on our site, enter a competition, promotion or survey and when you report a problem with our site.
The personal data you give us or we collect about you may include your name, address, private and corporate e-mail address and phone number, financial information, compliance documentation, such as your passport or driving license to verify your right to work in the UK, and references verifying your qualifications and experience, your curriculum vitae and photograph, links to your professional profiles available in the public domain e.g. LinkedIn, Twitter, business Facebook or corporate website. In addition, we also may collect sensitive data on race and ethnic origin for the purposes of reporting on diversity.
a) Information we collect about you when you visit our website.
With regard to each of your visits to our site we will automatically collect the following information:
- technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information if applicable, browser type and version, browser plug-in types and versions, operating system and platform.
- information about your visit, including the full Uniform Resource Locators (URL), clickstream to, through and from our site including date and time, products you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information such as scrolling, clicks, and mouse-overs, methods used to browse away from the page and any phone number used to call our customer service number.
b) Information we obtain from other sources.
This is information we obtain about you from other sources such as LinkedIn, corporate websites, job board websites such as S1, online CV libraries, your business card, personal recommendations, and events. In this case we will inform you, by sending you this privacy notice, within a maximum of 30 days of collecting the data of the fact we hold personal data about you, the source the personal data originates from and whether it came from publicly accessible sources, and for what purpose we intend to retain and process your personal data.
This is how we use the information to help you find a job and our legal obligations to store that information. This bit also covers our legitimate business interests (to help provide a better service) and how we’ll ask for your permission and your right to change your mind.
It’s important to us that we’re able to provide a highly personalised service to both our candidates and clients.
As such, we use information held about you in the following ways:
To carry out our obligations arising from any contracts we intend to enter into or have entered into between you and us and to provide you with the information, products and services that you request from us or we think will be of interest to you because it is relevant to your career or to your organisation.
To provide you with information about other goods and services we offer that are similar to those that you have already purchased, been provided with or enquired about.
The core service we offer to our candidates and clients is the introduction of candidates to our clients for the purpose of temporary or permanent engagement. However, our service expands to supporting individuals throughout their career and to supporting businesses’ resourcing needs and strategies.
Our legal basis for the processing of personal data is our legitimate business interests, described in more detail below, although we have segmented our activities and will also rely on contract, legal obligation and consent for specific uses of data.
Specifically, we will rely on:
- We will rely on contract if we are negotiating or have entered into a placement agreement with you or your organisation or any other contract to provide services to you or receive services from you or your organisation
- We will rely on legal if we are legally required to hold information on you to fulfil our legal obligations. An example would be asking for a copy of your passport or driving license in order to prove your right to work in the United Kingdom. We may work in partnership with Amiqus ID to process and handle such personal data.
- We will in rely on consent for particular uses of your data including marketing through an email list or seeking permission before we introduce you to a client. We will also request 'just in time' consent before your details are submitted for a vacancy
a) Our Legitimate Business Interests
Our legitimate interests in collecting and retaining your personal data is described below:
As a business specialising in Recruitment, Executive Search & Employer Branding, we introduce candidates to clients for permanent employment, temporary worker placements or independent professional contracts, as well as providing vital insight to companies on their employer brand. The exchange of personal data of our candidates and our client contacts is a fundamental, essential part of this process.
In order to support our candidates’ career aspirations and our clients’ resourcing needs we require a database of candidate and client personal data containing historical information as well as current resourcing requirements. This is essential in allowing us to talent map for assignments we work on, particularly for senior roles or where there are skill shortages. Many of our candidates and contacts are people we have worked with over many, many years often placing candidates several times throughout their career. Such historic data is essential in helping nurture our relationships and to ensure we are best placed to support all our customers.
Holding historic data is also essential for the purposes of developing and growing our business. Such information is utilised when it comes to Denholm providing intelligence for new business tenders.
Our newly launched employer brand service also replies on drawing insight from our CRM utilising historic data developed over the years.
Should we want or need to rely on consent to lawfully process your data we will request your consent orally, by email or by an online process for the specific activity we require consent for and record your response on our system. Where consent is the lawful basis for our processing you have the right to withdraw your consent to this particular processing at any time. We would seek consent for marketing purposes and 'just in time' consent before your details are submitted for a vacancy.
How we use your data to improve your experience of our website...
Use of our website;
- to notify you about changes to our service;
- to ensure that content from our site is presented in the most effective manner for you and for your computer
We will use this information:
- to administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
- to improve our site to ensure that content is presented in the most effective manner for you and for your computer;
- 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 site safe and secure;
- to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you;
- to make suggestions and recommendations to you and other users of our site about goods or services that may interest you or them
We do not undertake automated decision making or profiling. We do use our computer 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.
How these work and how they help us make the website helpful to you...
- A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server
- Cookies may be either "persistent" cookies or "session" cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed
- Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies
Cookies that we use
Cookies used by our service providers
Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:
- https://support.google.com/chrome/answer/95647?hl=en (Chrome);
- https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences (Firefox);
- http://www.opera.com/help/tutorials/security/cookies/ (Opera);
- https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);
- https://support.apple.com/kb/PH21411 (Safari); and
- https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy (Edge)
This website is owned and operated by Denholm Associates. We are registered in England and Wales under registration number VAT 801 7695 28, and our registered office is at 37 Constitution Street, Edinburgh EH6 7BG.
You can contact us on firstname.lastname@example.org.
(This document was created using a template from SEQ Legal (https://seqlegal.com)
We sometimes have to share your information with third-party companies. And sometimes these companies are based outside the European Economic Area (EEA). This lets you know when and how we’ll do that...
We will share your personal information with:
Any member of our group both in the EEA and outside of the EEA.
Selected third parties including:
- our clients for the purpose of introducing candidates to them;
- our candidates for the purpose of arranging interviews and engagements;
- clients, business partners, suppliers and sub-contractors for the performance and compliance obligations of any contract we enter into with them or you;
- subcontractors including email marketing specialists, event organisers, payment and other financial service providers
- advertisers and advertising networks that require the data to select and serve relevant adverts to you and others. We do not disclose information about identifiable individuals to our advertisers, but we will provide them with aggregate information about our users (for example, we may inform them that 500 men aged under 30 have clicked on their advertisement on any given day). We may also use such aggregate information to help advertisers reach the kind of audience they want to target (for example, women in SW1). We may make use of the personal data we have collected from you to enable us to comply with our advertisers’ wishes by displaying their advertisement to that target audience
- analytics and search engine providers that assist us in the improvement and optimisation of our site;
- credit reference agencies, our insurance broker, compliance partners and other sub-contractors for the purpose of assessing your suitability for a role where this is a condition of us entering into a contract with you.
We will disclose your personal information to third parties:
- In the event that we sell or buy any business or assets, in which case we will disclose your personal data to the prospective seller or buyer of such business or assets.
- If Denholm Associates or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
The lawful basis for the third party processing will include:
- Their own legitimate business interests in processing your personal data, in most cases to fulfil their internal resourcing needs;
- satisfaction of their contractual obligations to us as our data processor;
- for the purpose of a contract in place or in contemplation;
- to fulfil their legal obligations
The security we have in place to store and protect your data...
The data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (”EEA”). It may be transferred to third parties outside of the EEA for the purpose of our recruitment services. It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers. This includes staff engaged in, among other things, our recruitment services and the provision of support services. By submitting your personal data, you agree to this transfer, storing or processing. Denholm Associates will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy notice.
We have recently invested in a new state of the art CRM, which has the distinction of being one of the first applicant tracking systems (ATS) to be SOC 1 audited, and one of the first non-Financial industry based software-as-a-service (SaaS) companies to utilise the SSAE 16/18 framework to provide security review. Our CRM undertakes an independent third party annual SOC 1, Type 2 audit that reviews certain of its internal controls and processes. The audit covers internal governance, production operations, change management, data backups, and software development processes. It evaluates that they have the appropriate controls and processes in place and that they are actively functioning appropriately in accordance with related standards. The SOC program offers independent verification that their security practices offer a recognised standard of security measures.
All information you provide to us is stored on our secure server with appropriate firewalls in place. Offsite backup is encrypted and only stored with Datacentres in the UK, the main one being Glasgow and backup being Manchester & London.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
Why we have to store your data and your rights to access it...
We understand our legal duty to retain accurate data and only retain personal data for as long as we need it for our legitimate business interests and that you are happy for us to do so. Accordingly, we have a data retention notice and run data routines to remove data that we no longer have a legitimate business interest in maintaining.
We do the following to try to ensure our data is accurate:
- Prior to making an introduction, we check that we have accurate information about you
- We keep in touch with you so you can let us know of changes to your personal data
- We also encourage you to inform us of any changes to your personal data
We segregate our data so that we keep different types of data for different time periods. The criteria we use to determine whether we should retain your personal data include:
- the nature of the personal data;
- its perceived accuracy;
- our legal obligations;
- whether an interview or placement has been arranged; and
- our recruitment expertise and knowledge of the industry by country, sector and job role
We may archive part or all of your personal data or retain it on our financial systems only, deleting all or part of it from our main Customer Relationship Manager (CRM) system. We may pseudonymise parts of your data, particularly following a request for suppression or deletion of your data, to ensure that we do not re-enter your personal data on to our database, unless requested to do so.
For your information, Pseudonymised Data is created by taking identifying fields within a database and replacing them with artificial identifiers, or pseudonyms.
Our current retention notice is available upon request.
How you can make sure the data we hold is accurate and relevant
You have the right to ask us not to process your personal data for marketing purposes. We will usually inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes and we will collect express consent from you if legally required prior to using your personal data for marketing purposes.
You can exercise your right to accept or prevent such processing by checking certain boxes on the forms we use to collect your data. You can also exercise the right at any time by contacting us at email@example.com.
Our site 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.
The GDPR provides you with the following rights. To:
- 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).
- 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 of your personal information. This enables you to ask us to suspend the processing of personal information about you, 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.
- Make a complaint to 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/
Access to information
The Data Protection Act 1998 and the GDPR give you the right to access information held about you. We also encourage you to contact us to ensure your data is accurate and complete.
Your right of access can be exercised in accordance with the Act (and the GDPR once it is in force). Prior to 25th May 2018 any access request under the Data Protection Act will be subject to a fee of £10 to meet our costs in providing you with details of the information we hold about you.
A subject access request should be submitted to firstname.lastname@example.org. No fee will apply once the GDPR comes into force.
Changes to our privacy notice
Any changes we make to our privacy notice in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our privacy notice.
How to contact us
If you have any questions, here’s how to get them answered. Questions, comments and requests regarding this privacy notice are welcomed and should be addressed to email@example.com