Definitions and Interpretation In this Policy the following terms shall have the following meanings: “Account” means an account required to access and/or use certain areas and features of Our Site; “Cookie” means a small text file placed on your computer or device by Our Site when you visit certain parts of Our Site and/or when you use certain features of Our Site. Details of the Cookies used by Our Site are set out in Part 14, below; and “Cookie Law” means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003;
Information About Us Our Site is owned and operated by Digital Business Development Limited, a Limited Company registered in England under company number 05095762. Registered address: 78 Chamber Street, London, United Kingdom, Post code: E1 8BL. Main trading address: 78 Chamber Street, London, United Kingdom, Post code: E1 8BL. VAT number: 752152256. Data Protection Officer: Nil Bhatt. Email address: firstname.lastname@example.org. Telephone number: +44 (0) 20 8977 2994. Postal address: 78 Chamber Street, London, United Kingdom, Post code: E1 8BL. Representative: Nil Bhatt. Email address: email@example.com. Telephone number: +44 (0) 20 8977 2994. Postal address: 78 Chamber Street, London, United Kingdom, Post code: E1 8BL.
We are regulated by Information Commissioner’s Office. We are a member of Information Commissioner’s Office
What Is Personal Data? Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) and the Data Protection Act 2018 (collectively, “the Data Protection Legislation”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’. Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.
3 i) Rights relating to automated decision-making and profiling. We do not use your personal data in this way. For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Part 15. It is important that your personal data is kept accurate and up-to-date. If any of the personal data we hold about you changes, please keep us informed as long as we have that data. Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau. If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office. We would welcome the opportunity to resolve your concerns ourselves, however, so please contact us first, using the details in Part 15.
4 • Employment screening information including sensitive personal data collected by us or on our behalf; • Samples of work you provide us (please ensure any personal data contained has been collected legitimately according to the General Data Protection Regulation as Digital Business Development Limited is not responsible for its contents) Contact information including Email, name, phone number Registration box
5 Protection Legislation and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out. We will always obtain your express opt-in consent before sharing your personal data with third parties for marketing purposes and you will be able to opt-out at any time. Third Parties whose content appears on Our Site may use third-party Cookies, as detailed below in Part 14. Please refer to Part 14 for more information on controlling cookies. Please note that we do not control the activities of such third parties, nor the data that they collect and use themselves, and we advise you to check the privacy policies of any such third parties. We use the following automated systems for carrying out certain kinds of decisionmaking and profiling. If at any point you wish to query any action that we take on the basis of this or wish to request ‘human intervention’ (i.e. have someone review the action themselves, rather than relying only on the automated method), the Data Protection Legislation gives you the right to do so. Please contact us to find out more using the details in Part 15. When you apply for a position Digital Business Development Limited may use an automated process as part of our decision making. However, our decision on whether to recruit a candidate will never be made solely as a result of this automated processing. We will only use your personal data for the purpose(s) for which it was originally collected unless we reasonably believe that another purpose is compatible with that or those original purpose(s) and need to use your personal data for that purpose. If we do use your personal data in this way and you wish us to explain how the new purpose is compatible with the original, please contact us using the details in Part 15. If we need to use your personal data for a purpose that is unrelated to, or incompatible with, the purpose(s) for which it was originally collected, we will inform you and explain the legal basis which allows us to do so. In some circumstances, where permitted or required by law, we may process your personal data without your knowledge or consent. This will only be done within the bounds of the Data Protection Legislation and your legal rights.
How Long Will You Keep My Personal Data? We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Your personal data will therefore be kept for the following periods (or, where there is no fixed period, the following factors will be used to determine how long it is kept): Type of Data How Long We Keep It • Personal data contained within your CV; • Identity verification data and proof of address you provide to us; • Proof of employment and academic history; • Personal data provided to us by your designated referees (please ensure Following the conclusion of the recruitment process, we retain your personal data in compliance with our retention and deletion policies. If your application was and is unlikely to remain unsuccessful we will delete your data automatically after 90 days. If your application was unsuccessful, and we believe that you may be suitable for future opportunities we will retain your data for 24 months from the date on which 6 they have consented to your use of this data; • Social media comments you have made; • Employment screening information including sensitive personal data collected by us or on our behalf; • Samples of work you provide us (please ensure any personal data contained has been collected legitimately according to the General Data Protection Regulation as Digital Business Development Limited is not responsible for its contents) you are notified that your application has been unsuccessful unless you object to our continued processing of your personal data using the procedure outlined below. We will delete any sensitive data (as described above) provided to us by you automatically after 30 days. . Contact information including Name, Email, Phone number, 2 years .
How and Where Do You Store or Transfer My Personal Data? We share your data within the group of companies of which we are a part. Where this involves the transfer of personal data outside the EEA, our group ensures that personal data is protected by requiring all companies within the group to follow the same rules with respect to personal data usage. These are known as “binding corporate rules”. More information on binding corporate rules is available from the European Commission. AND We use specific contracts with external third parties that are approved by the European Commission for the transfer of personal data to third countries. These contracts require the same levels of personal data protection that would apply under the Data Protection Legislation. More information is available from the European Commission. Please contact us using the details below in Part 15 for further information about the particular data protection mechanisms used by us when transferring your personal data to a third country. The security of your personal data is essential to us, and to protect your data, we take a number of important measures, including the following: • limiting access to your personal data to those employees, agents, contractors, and other third parties with a legitimate need to know and ensuring that they are subject to duties of confidentiality; • procedures for dealing with data breaches (the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, your personal data) including notifying you and/or the Information Commissioner’s Office where we are legally required to do so; 7
How Can I Control My Personal Data? 11.1 In addition to your rights under the Data Protection Legislation, set out in Part 5, when you submit personal data via Our Site, you may be given options to restrict our use of your personal data. In particular, we aim to give you strong controls on our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from us which you may do by unsubscribing using the links provided in our emails or, at the point of providing your details and by managing your Account). 11.2 You may also wish to sign up to one or more of the preference services operating in the UK: The Telephone Preference Service (“the TPS”), the Corporate Telephone Preference Service (“the CTPS”), and the Mailing Preference Service (“the MPS”). These may help to prevent you receiving unsolicited marketing. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receiving.
How Can I Access My Personal Data? If you want to know what personal data we have about you, you can ask us for details 8 of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”. All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 15. To make this as easy as possible for you, a Subject Access Request Form is available for you to use. You do not have to use this form, but it is the easiest way to tell us everything we need to know to respond to your request as quickly as possible. There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding. We will respond to your subject access request within 30 days and, in any case, not more than one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.
- Our Site may place and access certain first-party Cookies on your computer or device.
- First-party Cookies are those placed directly by us and are used only by us. We use
- Cookies to facilitate and improve your experience of Our Site and to provide and
- improve our products and services. We have carefully chosen these Cookies and have
- taken steps to ensure that your privacy and personal data is protected and respected
- at all times.
- By using Our Site, you may also receive certain third-party Cookies on your computer
- or device. Third-party Cookies are those placed by websites, services, and/or parties
- other than us. Third-party Cookies are used on Our Site to help us and our advertisers
- see which advertisements you click on and interact with. Each individual advertiser
- uses its own tracking cookies and the data taken is not confidential or interchangeable..
- For more details, please refer to the table below. These Cookies are not integral to the
- functioning of Our Site and your use and experience of Our Site will not be impaired by
- refusing consent to them.
- All Cookies used by and on Our Site are used in accordance with current Cookie Law.
- Before Cookies are placed on your computer or device, you will be shown a pop up
- requesting your consent to set those Cookies. By giving your consent to the placing of
- Cookies you are enabling us to provide the best possible experience and service to
- you. You may, if you wish, deny consent to the placing of Cookies; however certain
- features of Our Site may not function fully or as intended. You will be given the
- opportunity to allow only first-party Cookies and block third-party Cookies.
- Certain features of Our Site depend on Cookies to function. Cookie Law deems these
- Cookies to be “strictly necessary”. These Cookies are shown in the table below. Your
- consent will not be sought to place these Cookies, but it is still important that you are
- aware of them. You may still block these Cookies by changing your internet browser’s
- settings as detailed below, but please be aware that Our Site may not work properly if
- you do so. We have taken great care to ensure that your privacy is not at risk by allowing
- The following first-party Cookies may be placed on your computer or device:
- Name of Cookie Purpose Strictly Necessary
- _ga, _gid, _gat These cookies are dropped by our partner Google Analytics for traffic and user behaviour analytics. no Our Site uses analytics services provided by Google Analytics and Hotjar. Website analytics refers to a set of tools used to collect and analyse anonymous usage information, enabling us to better understand how Our Site is used. This, in turn, enables us to improve Our Site and the products and services offered through it. The analytics service(s) used by Our Site use(s) Cookies to gather the required information. You do not have to allow us to use these Cookies, however whilst our use of them does not pose any risk to your privacy or your safe use of Our Site, it does enable us to continually improve Our Site, making it a better and more useful experience for you. In addition to the controls that we provide, you can choose to enable or disable Cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all Cookies or only third-party Cookies. By default, most internet browsers accept Cookies, but this can be changed. For further details, please consult the help menu in your internet browser or the documentation that came with your device. You can choose to delete Cookies on your computer or device at any time, however you may lose any information that enables you to access Our Site more quickly and efficiently including, but not limited to, login and personalisation settings. It is recommended that you keep your internet browser and operating system up-todate and that you consult the help and guidance provided by the developer of your internet browser and manufacturer of your computer or device if you are unsure about adjusting your privacy settings.
- How Do I Contact You? To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the following details [(for the attention of Nil Bhatt): Email address: firstname.lastname@example.org. Telephone number: +44 (0) 20 8977 2994. Postal Address: 78 Chamber Street, London, United Kingdom, Post code: E1 8BL.