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PRIVACY POLICY



INTRODUCTION

This Privacy Policy explains what we do with your personal data, whether we are
in the process of helping you find a job, continuing our relationship with you
once we have found you a role, providing you with a service, receiving a service
from you, using your data to ask for your assistance in relation to one of our
Candidates, or you are visiting our website.

It describes how we collect, use and process your personal data, and how, in
doing so, we comply with our legal obligations to you. Your privacy is important
to us, and we are committed to protecting and safeguarding your data privacy
rights.

This Privacy Policy applies to the personal data of our Website
Users, Candidates, Clients, Suppliers, and other people whom we may contact in
order to find out more about our Candidates or whom they indicate is an
emergency contact. It also applies to the emergency contacts of our Staff. To be
clear, if you are a member of Darwin Recruitment's staff, you should refer to
the Darwin Recruitment Staff Privacy Policy which is available on from the
Darwin Recruitment HR department.

For the purpose of applicable data protection legislation (including but not
limited to the General Data Protection Regulation (Regulation (EU) 2016/679)
(the "GDPR"), the company responsible for your personal data ("Darwin
Recruitment" or "us") can be found here.

It is important to point out that we may amend this Privacy Policy from time to
time. Please just visit this page if you want to stay up to date, as we will
post any changes here.

If you are dissatisfied with any aspect of our Privacy Policy, you may have
legal rights and, where relevant, we have described these as well.

This Privacy Policy applies in relevant countries throughout our international
network. Different countries may approach data privacy in slightly different
ways and so we also have country-specific parts to this Privacy Policy. You can
find country-specific terms for your jurisdiction here. This allows us to ensure
that we're complying with all applicable data privacy protections, no matter
where you are.

 

SHORT FORM "AT A GLANCE" SECTION

What kind of personal data do we collect?

CANDIDATE DATA: In order to provide the best possible employment opportunities
that are tailored to you, we need to process certain information about you. We
only ask for details that will genuinely help us to help you, such as your name,
age, contact details, education details, employment history, emergency contacts,
immigration status, financial information (where we need to carry out financial
background checks), and social security number (and of course you may choose to
share other relevant information with us). Where appropriate and in accordance
with local laws and requirements, we may also collect information related to
your health, diversity information or details of any criminal convictions.

If you would like a more detailed description of the personal data that we
collect about you, please click here.

To the extent that you access our website we will also collect certain data from
you. If you would like more information about this, please click here.

CLIENT DATA: If you are a Darwin Recruitment customer, we need to collect and
use information about you, or individuals at your organisation, in the course of
providing you services such as: (i) finding Candidates who are the right fit for
you or your organisation; (ii) providing you with Recruitment Process
Outsourcing ("RPO") services (or assisting another organisation to do so);
and/or (iv) notifying you of content published by Darwin Recruitment which is
likely to be relevant and useful to you (for example our regional Recruitment
Market Updates).

If you would like a more detailed description of the personal data that we
collect in this way, please click here.

To the extent that you access our website we will also collect certain data from
you. If you would like more information about this, please click here.

SUPPLIER DATA: We need a small amount of information from our Suppliers to
ensure that things run smoothly. We need contact details of relevant individuals
at your organisation so that we can communicate with you. We also need other
information such as your bank details so that we can pay for the services you
provide (if this is part of the contractual arrangements between us).

If you would like a more detailed description of the personal data that we
collect about you, please click here.

To the extent that you access our website we will also collect certain data from
you. If you would like more information about this, please click here

PEOPLE WHOSE DATA WE RECEIVE FROM CANDIDATES AND STAFF, SUCH AS REFEREES AND
EMERGENCY CONTACTS: In order to provide Candidates with suitable employment
opportunities safely and securely and to provide for every eventuality for them
and our Staff, we need some basic background information. We only ask for very
basic contact details, so that we can get in touch with you either for a
reference or because you’ve been listed as an emergency contact for one of our
Candidates or Staff members.

If you would like a more detailed description of the personal data that we
collect about you, please click here.

WEBSITE USERS: We collect a limited amount of data from our Website Users which
we use to help us to improve your experience when using our website and to help
us manage the services we provide. This includes information such as how you use
our website, the frequency with which you access our website, and the times that
our website is most popular.

If you would like to find out more information about what data we collect about
you when you visit our website, please click here.

A number of elements of the personal data we collect from you are required to
enable us to fulfil our contractual duties to you or to others. Where
appropriate, some, for example Candidates' national insurance/social security
number are required by statute or other laws. Other items may simply be needed
to ensure that our relationship can run smoothly.

Depending on the type of personal data in question and the grounds on which we
may be processing it, should you decline to provide us with such data, we may
not be able to fulfil our contractual requirements or, in extreme cases, may not
be able to continue with our relationship.

For details of the legal bases that we rely on to be able to use and process
your personal data, please click here.

How do we collect your personal data?

CANDIDATE DATA: There are two main ways in which we collect your personal data:

1. Directly from you; and

2. From third parties.

If you want to know more about how we collect your personal data, please click
here.

To the extent that you access our website or read or click on an email from us,
we may also collect certain data automatically or through you providing it to
us. For more information please click here.

CLIENT DATA: There are two main ways in which we collect your personal data:

1 Directly from you; and

2 From third parties (e.g. our Candidates) and other limited sources (e.g.
online and offline media).

If you would like to know more about how we collect your personal data,
please click here.

To the extent that you access our website or read or click on an email from us,
we may also collect certain data automatically or through you providing it to
us. For more information please click here.

SUPPLIER DATA: We collect your personal data during the course of our work with
you.

To the extent that you access our website or read or click on an email from us,
we may also collect certain data automatically or through you providing it to
us. For more information please click here.

PEOPLE WHOSE DATA WE RECEIVE FROM CANDIDATES AND STAFF, SUCH AS REFEREES AND
EMERGENCY CONTACTS: We collect your contact details only where a Candidate or a
member of our Staff puts you down as their emergency contact or where a
Candidate gives them to us in order for you to serve as a referee.

WEBSITE USERS: We collect your data automatically via cookies when you visit our
website, in line with cookie settings in your browser. If you would like to find
out more about cookies, including how we use them and what choices are available
to you, please click here. We will also collect data from you when you contact
us via the website.

 

How do we use your personal data?

CANDIDATE DATA: The main reason for using your personal details is to help you
find employment or other work roles that might be suitable for you. The more
information we have about you, your skillset and your ambitions, the more
bespoke we can make our service. Where appropriate and in accordance with local
laws and requirements, we may also use your personal data for things like
marketing, profiling and diversity monitoring. Where appropriate, we will seek
your consent to undertake some of these activities.

For more details on how we use your personal data, please click here.

CLIENT DATA: The main reason for using information about Clients is to ensure
that the contractual arrangements between us can properly be implemented so that
the relationship can run smoothly. This may involve: (i) identifying Candidates
who we think will be the right fit for you or your organisation; (ii) providing
you with RPO services (or assisting another organisation to do so). The more
information we have, the more bespoke we can make our service.

For more details on how we use your personal data, please click here.

SUPPLIER DATA: The main reasons for using your personal data are to ensure that
the contractual arrangements between us can properly be implemented so that the
relationship can run smoothly, and to comply with legal requirements.

For more details on how we use your personal data, please click here.

PEOPLE WHOSE DATA WE RECEIVE FROM CANDIDATES AND STAFF, SUCH AS REFEREES AND
EMERGENCY CONTACTS: We use referees’ personal data to help our Candidates to
find employment which is suited to them. If we are able to verify their details
and qualifications, we can make sure that they are well matched with prospective
employers. We may also use referees' personal data to contact them in relation
to recruitment activities that may be of interest to them. We use the personal
details of a Candidates or Staff member's emergency contacts in the case of an
accident or emergency affecting that Candidates or member of Staff.

For more details on how we use your personal data, please click here.

WEBSITE USERS: We use your data to help us to improve your experience of using
our website, for example by analysing your recent job search criteria to help us
to present jobs to you that we think you'll be interested in. If you are also a
Candidate or Client of Darwin Recruitment, we may use data from your use of our
websites to enhance other aspects of our communications with, or service to,
you.

If you would like to find out more about cookies, including how we use them and
what choices are available to you, please click here.

Please note that communications to and from Darwin Recruitment's Staff including
emails may be reviewed as part of internal or external investigations or
litigation.

Who do we share your personal data with?

CANDIDATE DATA: We may share your personal data with various parties, in various
ways and for various reasons. Primarily we will share your information with
prospective employers to increase your chances of securing the job you want.
Unless you specify otherwise, we may also share your information with any of our
group companies and associated third parties such as our service providers where
we feel this will help us to provide you with the best possible service.

If you would like to see a list of who we may share your personal data with,
please click here.

CLIENT DATA: We will share your data: (i) primarily to ensure that we provide
you with a suitable pool of Candidates; (ii) to provide you with RPO services
(or assist another organisation to do so). Unless you specify otherwise, we may
share your information with any of our group companies and associated third
parties such as our service providers to help us meet these aims.

If you would like to see a list of who we may share your personal data with,
please click here.

SUPPLIER DATA: Unless you specify otherwise, we may share your information with
any of our group companies and associated third parties such as our service
providers and organisations to whom we provide services.

If you would like to see a list of who we may share your personal data with,
please click here.

PEOPLE WHOSE DATA WE RECEIVE FROM CANDIDATES AND STAFF, SUCH AS REFEREES AND
EMERGENCY CONTACTS: Unless you specify otherwise, we may share your information
with any of our group companies and associated third parties such as our service
providers and organisations to whom we provide services.

If you would like to see a list of who we may share your personal data with,
please click here.

WEBSITE USERS: Unless you specify otherwise, we may share your information with
providers of web analytics services, marketing automation platforms and social
media services to make sure any advertising you receive is targeted to you.

How do we safeguard your personal data?

We care about protecting your information. That's why we put in place
appropriate measures that are designed to prevent unauthorised access to, and
misuse of, your personal data.

For more information on the procedures we put in place, please click here.

How long do we keep your personal data for?

If we have not had meaningful contact with you (or, where appropriate, the
company you are working for or with) for a period of two years, we will Delete
your personal data from our systems unless we believe in good faith that the law
or other regulation requires us to preserve it (for example, because of our
obligations to tax authorities or in connection with any anticipated
litigation).

For more information on our policy for the retention of personal data,
please click here.

How can you access, amend or take back the personal data that you have given to
us?

Even if we already hold your personal data, you still have various rights in
relation to it. To get in touch about these, please contact us. We will seek to
deal with your request without undue delay, and in any event in accordance with
the requirements of any applicable laws. Please note that we may keep a record
of your communications to help us resolve any issues which you raise.

Right to object: If we are using your data because we deem it necessary for our
legitimate interests to do so, and you do not agree, you have the right to
object. We will respond to your request within 30 days (although we may be
allowed to extend this period in certain cases). Generally, we will only
disagree with you if certain limited conditions apply.

Right to withdraw consent: Where we have obtained your consent to process your
personal data for certain activities (for example, for profiling your
suitability for certain roles), or consent to market to you, you may withdraw
your consent at any time.

Data Subject Access Requests (DSAR): Just so it's clear, you have the right to
ask us to confirm what information we hold about you at any time, and you may
ask us to modify, update or Delete such information. At this point we may comply
with your request or, additionally do one of the following:

 * we may ask you to verify your identity, or ask for more information about
   your request; and
 * where we are legally permitted to do so, we may decline your request, but we
   will explain why if we do so.

Right to erasure: In certain situations (for example, where we have processed
your data unlawfully), you have the right to request us to "erase" your personal
data. We will respond to your request within 30 days (although we may be allowed
to extend this period in certain cases) and will only disagree with you if
certain limited conditions apply. If we do agree to your request, we will Delete
your data but will generally assume that you would prefer us to keep a note of
your name on our register of individuals who would prefer not to be contacted.
That way, we will minimise the chances of you being contacted in the future
where your data are collected in unconnected circumstances. If you would prefer
us not to do this, you are free to say so.

Please note some personal information has to be kept to comply with legal
obligations.

Right of data portability: If you wish, you have the right to transfer your data
from us to another data controller. We will help with this – either by directly
transferring your data for you, or by providing you with a copy in a commonly
used machine-readable format.

Right to lodge a complaint with a supervisory authority: You also have the right
to lodge a complaint with your local supervisory authority, details of which can
be found here.

If your interests or requirements change, you can unsubscribe from part or all
of our marketing content (for example job role emails or Darwin Recruitment
newsletters) by clicking the unsubscribe link in the email, or by updating your
preferences through our preference centre on the Darwin Recruitment website (by
signing into your account or entering your email address).

If you would like to know more about your rights in respect of the personal data
we hold about you, please click here.

How do we store and transfer your data internationally?

Darwin Recruitment is a global organisation – this is what enables us to offer
the level of services that we do. In order for us to continue operating in this
way, we may have to transfer or store your data internationally.

For more information on the steps we take when we transfer and store your data
internationally, please click here.

Who is responsible for processing your personal data on the Darwin Recruitment
website?

Darwin Recruitment controls the processing of personal data on its website(s).

If you've got any further questions, or want further details, please click here.

What are cookies and how do we use them?

What are cookies?

Cookies are small text files that are placed on your computer, smartphone or
other device when you access the internet.

Why are cookies essential to Darwin Recruitment's websites?

This website, along with many others, uses cookies. Cookies let users navigate
around sites and (where appropriate) let us tailor the content to fit the needs
of our site's visitors. Without cookies enabled we can't guarantee that the
website and your experience of it are as we intended it to be.

None of the cookies we use collect your personal information and they can’t be
used to identify you.

Types of cookies

The length of time a cookie stays on your device depends on its type. We use two
types of cookies on our websites.

Session cookies are temporary cookies which only exist during the time you use
the website (or more strictly, until you close the browser after using the
website). Session cookies help our websites remember what you chose on the
previous page, avoiding the need to re-enter information.

Persistent cookies stay on your device after you’ve visited our website. For
example, if you tick the 'Remember my ID' box when you log onto your online
account a persistent cookie will be used so that the site remembers your choice
the next time you use it. Persistent cookies help us identify you as a unique
visitor but don’t contain information that could be used to identify you to
another person.

At Darwin Recruitment we use cookies in the following ways:

 * In our online application forms. Without cookies enabled you won't be able to
   apply for our jobs
 * We also use web analytics services from other companies to track how visitors
   reach our site and the path they take through it. These companies use cookies
   to help us improve our service to you.

The analytics services we use are:

 * Google Analytics, which uses cookies to help us analyse how our visitors use
   the site. Find out more about how these cookies are used on the Google
   privacy site
 * Mouseflow, to analyse how our visitors use our sites. Mouseflow uses both
   session and persistent cookies.

You can find below more information about each individual cookie and how to
recognize them:

Advertising and targeting cookies are used to deliver advertisements more
relevant to you, but can also limit the number of times you see an
advertisement, and be used to chart the effectiveness of an ad campaign by
tracking users’ clicks. They can also provide security in transactions. They are
usually placed by third-party advertising networks with a website operator’s
permission, but can be placed by the operator themselves. They can remember that
you have visited a website, and this information can be shared with other
organisations, including other advertisers. They cannot determine who you are
though, as the data collected is never linked to your profile.

The two main ways we use advertising and targeting cookies are set out below:

 * Interest-based advertising (or online behavioural advertising) is where
   cookies are placed on your device by our third party service providers which
   remember your web browsing activity and group together your interests in
   order to provide you with targeted advertisements which are more relevant to
   you when you visit independent.co.uk.  Your previous web browsing activity
   can also be used to infer things about you, such as your demographics (age,
   gender etc.). This information may also be used to make the advertising on
   independent.co.uk more relevant to you.
 * ‘Retargeting’ is a form of interest-based advertising that enables our
   advertising partners to show you advertisements selected based on your online
   browsing activity away from the Website.  This allows companies to advertise
   to people who previously visited their website. These cookies will usually be
   placed on your device by third-party advertising networks and we have listed
   the main third party networks we work with below.

Without these cookies, online advertisements you encounter will be less relevant
to you and your interests. If you would like more information about
interest-based advertising, including how to opt-out of these cookies, please
visit www.youronlinechoices.com

How to control and delete cookies

If you want to restrict or block the cookies we set, you can do this through
your browser settings. The ‘help’ function within your browser should tell you
how.

Alternatively, you could visit www.aboutcookies.org, which contains
comprehensive information on cookies on a wide variety of browsers. You’ll also
find details on how to delete cookies from your computer. To learn about
controlling cookies on the browser of your mobile device please refer to your
handset manual.

Cookies in emails 

As well as the cookies we use on our websites, we use cookies and similar
technologies in some emails. These help us to understand whether you’ve opened
an email and how you’ve interacted with it. If you have enabled images, cookies
may be set on your computer or device. Cookies will also be set if you click on
any link within the email. The types of cookies we use are:

Web beacons: tiny, invisible images placed in emails to tell us whether you’ve
opened them (and if so how often), how you interacted with them (for example the
time you spent reading the email), which email software and web browser you
used, which device you used and your IP address. We also use web beacons to help
us display emails in the best format for your device.

Link tracking: our emails contain a number of hyperlinks, each of which has a
unique tag. When you click on one of these links the mailing company logs the
click so that we can understand who has clicked through from an email to our
website. We use this information to tailor future messages to you.

Cookies: our process for delivering emails may cause cookies to be set when you
download images or when you click on a link.

Making choices about cookies

If you don't want to accept cookies from our emails, simply close the email
before downloading any images or clicking on any links. You can also set your
browser to restrict or reject cookies. These settings will apply to all cookies
on websites and emails.

In some instances, depending on your email or browser settings, cookies in an
email may be automatically accepted (for example, when you've added an email
address to your address book or safe senders list). Please check your email
browser or device instructions for more information on this.

LONG FORM DETAILED SECTIONS

WHAT KIND OF PERSONAL INFORMATION DO WE COLLECT?

So you're looking for a bit more insight into what data we collect about you?
Here's a more detailed look at the information we may collect. The information
described below is, of course, in addition to any personal data we are required
by law to process in any given situation.

CANDIDATE DATA: Depending on the relevant circumstances and applicable local
laws and requirements, we may collect some or all of the information listed
below to enable us to offer you employment opportunities which are tailored to
your circumstances and your interests. In some jurisdictions, we are restricted
from processing some of the data outlined below. In such cases, we will not
process the data in those jurisdictions:

 * Name;
 * Age/date of birth;
 * Sex/gender;
 * Photograph;
 * Marital status;
 * Contact details;
 * Education details;
 * Employment history;
 * Emergency contacts and details of any dependants;
 * Referee details;
 * Immigration status (whether you need a work permit);
 * Nationality/citizenship/place of birth;
 * A copy of your driving licence and/or passport/identity card;
 * Financial information (where we need to carry out financial background
   checks);
 * National Insurance/Social security number (or equivalent in your country) and
   any other tax-related information;
 * Diversity information including racial or ethnic origin, religious or other
   similar beliefs, and physical or mental health, including disability-related
   information;
 * Details about your current remuneration, pensions and benefits arrangements;
 * Information on your interests and needs regarding future employment, both
   collected directly and inferred, for example from jobs viewed or articles
   read on our website;
 * Extra information that you choose to tell us;
 * Extra information that your referees chooses to tell us about you;
 * Extra information that our Clients may tell us about you, or that we find
   from other third party sources such as job sites;
 * IP address;
 * The dates, times and frequency with which you access our services; and
 * CCTV footage if you attend our premises.

 

Please note that the above list of categories of personal data we may collect is
not exhaustive.

To the extent that you access our website we will also collect certain data from
you. If you would like more information about this, please click here.

***

CLIENT DATA: The data we collect about Clients is actually very limited. We
generally only need to have your contact details or the details of individual
contacts at your organisation (such as their names, telephone numbers and email
addresses) to enable us to ensure that our relationship runs smoothly. We also
hold information relating to your online engagement with Candidate profiles and
other material published by Darwin Recruitment, which we use to ensure that our
marketing communications to you are relevant and timely. We may also hold extra
information that someone in your organisation has chosen to tell us. In certain
circumstances, such as when you engage with our Finance and Debt Recovery teams,
our calls with you may be recorded, depending on the applicable local laws and
requirements. If we need any additional personal data for any reason, we will
let you know.

To the extent that you access our website we will also collect certain data from
you. If you would like more information about this, please click here.

***

SUPPLIER DATA: We don't collect much data about Suppliers – we simply need to
make sure that our relationship runs smoothly. We'll collect the details for our
contacts within your organisation, such as names, telephone numbers and email
addresses. We'll also collect bank details, so that we can pay you. We may also
hold extra information that someone in your organisation has chosen to tell us.
In certain circumstances, such as when you engage with our Finance and Debt
Recovery teams, our calls with you may be recorded, depending on the applicable
local laws and requirements.

To the extent that you access our website we will also collect certain data from
you. If you would like more information about this, please click here.

***

PEOPLE WHOSE DATA WE RECEIVE FROM CANDIDATES AND STAFF, SUCH AS REFEREES AND
EMERGENCY CONTACTS: All we need from referees is confirmation of what you
already know about our Candidate or prospective member of Staff, so that they
can secure that job they really want. Emergency contact details give us somebody
to call on in an emergency. To ask for a reference, we'll obviously need the
referee's contact details (such as name, email address and telephone number).
We'll also need these details if our Candidate or a member of our Staff has put
you down as their emergency contact so that we can contact you in the event of
an accident or an emergency.

***

WEBSITE USERS We collect a limited amount of data from our Website Users which
we use to help us to improve your experience when using our website and to help
us manage the services we provide. This includes information such as how you use
our website, the frequency with which you access our website, your browser type,
the location you view our website from, the language you choose to view it in
and the times that our website is most popular. If you contact us via the
website, for example by using the chat function, we will collect any information
that you provide to us, for example your name and contact details.

If you would like to find out more information about what data we collect about
you when you visit our website, please click here.

****************************

HOW DO WE COLLECT YOUR PERSONAL DATA?

CANDIDATE DATA: We collect Candidate personal data in three primary ways:

1. Personal data that you, the Candidate, give to us;

2. Personal data that we receive from other sources; and

3. Personal data that we collect automatically.

Personal data you give to us

Darwin Recruitment needs to know certain information about you in order to
provide a tailored service. This will enable us to provide you with the best
opportunities, and should save you time in not having to trawl through
information about jobs and services that are not relevant to you.

There are numerous ways you can share your information with us. It all depends
on what suits you. These may include:

 * Entering your details on the Darwin Recruitment website or via an application
   form, as part of the registration process;
 * Leaving a hard copy CV at a Darwin Recruitment event, job fair or office;
 * Emailing your CV to a Darwin Recruitment consultant or being interviewed by
   them;
 *  Applying for jobs through a job aggregator, which then redirects you to the
   Darwin Recruitment website;
 * Entering your personal details into a Darwin Recruitment microsite; or
 * Entering a competition through a social media channel such as Facebook or
   Twitter.

Personal data we receive from other sources

We also receive personal data about Candidate from other sources. Depending on
the relevant circumstances and applicable local laws and requirements, these may
include personal data received in the following situations:

 * Your referees may disclose personal information about you;
 * Our Clients may share personal information about you with us;
 * We may obtain information about you from searching for potential Candidate
   from third party sources, such as LinkedIn and other job sites;
 * If you 'like' our page on Facebook or 'follow' us on Twitter we will receive
   your personal information from those sites; and
 * If you were referred to us through an RPO or an MSP supplier, they may share
   personal information about you with us.

Personal data we collect automatically

To the extent that you access our website or read or click on an email from us,
where appropriate and in accordance with any local laws and requirements, we may
also collect your data automatically or through you providing it to us. For more
information please click here.

***

CLIENT DATA We collect Client personal data in three ways:

1. Personal data that we receive directly from you;

2. Personal data that we receive from other sources; and

3. Personal data that we collect automatically.

Personal data that we receive directly from you

We both share the same goal – to make sure that you have the best staff for your
organisation. We will receive data directly from you in two ways:

 * Where you contact us proactively, usually by phone or email; and/or
 * Where we contact you, either by phone or email, or through our consultants'
   business development activities more generally.

Personal data we receive from other sources

Where appropriate and in accordance with any local laws and requirements, we may
seek more information about you or your colleagues from other sources generally
by way of due diligence or other market intelligence including:

 * From third party market research and by analysing online and offline media
   (which we may do ourselves, or employ other organisations to do for us);
 * From delegate lists at relevant events; and
 * From other limited sources and third parties (for example from our Candidates
   to the extent that they provide us with your details to act as a referee for
   them).

Personal data we collect via our website

To the extent that you access our website or read or click on an email from us,
where appropriate and in accordance with any local laws and requirements, we may
also collect your data automatically or through you providing it to us. For more
information please click here.

***

WEBSITE USERS: When you visit our website there is certain information that we
may automatically collect, whether or not you decide to use our services. This
includes your IP address, the date and the times and frequency with which you
access the website and the way you browse its content. We will also collect data
from you when you contact us via the website, for example by using the chat
function.

We collect your data automatically via cookies, in line with cookie settings in
your browser. If you are also a Candidate or Client of Darwin Recruitment, we
may use data from your use of our websites to enhance other aspects of our
communications with or service to you. If you would like to find out more about
cookies, including how we use them and what choices are available to you, please
click here.

*****************************

HOW DO WE USE YOUR PERSONAL DATA?

Having obtained data about you, we then use it in a number of ways.

CANDIDATE DATA: We generally use Candidate data in four ways:

 * Recruitment Activities;
 * Marketing Activities;
 * Equal Opportunities Monitoring; and
 * To help us to establish, exercise or defend legal claims.
 * In appropriate circumstances in the future, we may also use limited Candidate
   data for profiling and the production of salary surveys and market updates.

Here are some more details about each:

Recruitment Activities

Obviously, our main area of work is recruitment – connecting the right
Candidates with the right jobs. We've listed below various ways in which we may
use and process your personal data for this purpose, where appropriate and in
accordance with any local laws and requirements. Please note that this list is
not exhaustive.

 * Collecting your data from you and other sources, such as LinkedIn;
 * Storing your details (and updating them when necessary) on our database, so
   that we can contact you in relation to recruitment;
 * Providing you with our recruitment services and to facilitate the recruitment
   process;
 * Assessing data about you against vacancies which we think may be suitable for
   you;
 * Sending your information to Clients, in order to apply for jobs or to assess
   your eligibility for jobs;
 * Enabling you to submit your CV, apply online for jobs or to subscribe to
   alerts about jobs we think may be of interest to you;
 * Allowing you to participate in specialist online training;
 * Allowing you to participate in the interactive features of our services, when
   you choose to do so;
 * Carrying out our obligations arising from any contracts entered into between
   us;
 * Carrying out our obligations arising from any contracts entered into between
   Darwin Recruitment and third parties in relation to your recruitment;
 * Facilitating our payroll and invoicing processes;
 * Carrying out customer satisfaction surveys;
 * Verifying details you have provided, using third party resources (such as
   psychometric evaluations or skills tests), or to request information (such as
   references, qualifications and potentially any criminal convictions, to the
   extent that this is appropriate and in accordance with local laws);
 * Complying with our legal obligations in connection with the detection of
   crime or the collection of taxes or duties; and
 * Processing your data to enable us to send you targeted, relevant marketing
   materials or other communications which we think are likely to be of interest
   to you.

We may use your personal data for the above purposes if we deem it necessary to
do so for our legitimate interests. If you want to know more about what this
means, please click here. If you are not happy about this, in certain
circumstances you have the right to object and can find out more about how and
when to do this here.

Please note that in certain of the jurisdictions in which we operate, we comply
with additional local law requirements. For more information in relation to your
jurisdiction, please click here.

 Marketing Activities

We may periodically send you information that we think you may find interesting,
or to ask for your help with connecting other Candidates with jobs. In
particular, we may wish to use your data for the purposes listed below, where
appropriate and in accordance with any local laws and requirements. Please note
that this list is not exhaustive. To:

 * enable us to develop and market other products and services;
 * market our full range of recruitment services (permanent, temporary,
   contract, outplacement, MSP programmes and RPO services) to you;
 * send you details of reports, promotions, offers, networking and client
   events, and general information about the industry sectors which we think
   might be of interest to you;
 * display promotional excerpts from your details on Darwin Recruitment'
   website(s) as a success story (only where we have obtained your express
   consent to do so); and
 * provide you with information about certain discounts and offers that you are
   eligible for by virtue of your relationship with Darwin Recruitment.

We need your consent for some aspects of these activities which are not covered
by our legitimate interests (in particular, the collection of data via cookies,
and the delivery of direct marketing to you through digital channels) and,
depending on the situation, we'll ask for this via an opt-in or soft-opt-in
(which we explain further below). Please note that in certain of the
jurisdictions in which we operate, we comply with additional local law
requirements. For more information in relation to your jurisdiction,
please click here.

Soft opt-in consent is a specific type of consent which applies where you have
previously engaged with us (for example by submitting a job application or CV,
or registering a vacancy to be filled), and we are marketing other
recruitment-related services. Under ‘soft opt-in’ consent, we will take your
consent as given unless or until you opt out. For most people, this is
beneficial as it allows us to suggest other jobs to you alongside the specific
one you applied for, significantly increasing the likelihood of us finding you a
new position. For other types of e-marketing, we are required to obtain your
explicit consent.

If you want to know more about how we obtain consent, please click here. If you
are not happy about our approach to marketing, you have the right to withdraw
your consent at any time and can find out more about how to do so here. Nobody's
perfect, even though we try to be. We want to let you know that even if you have
opted out from our marketing communications through our preference centre, it is
possible that your details may be recaptured through public sources in an
unconnected marketing campaign. We will try to make sure this doesn't happen,
but if it does, we're sorry. We'd just ask that in those circumstances you opt
out again.

All our marketing is based on what we think will serve our Clients and
Candidates best, but we know we won’t always get it right for everyone. We may
use your data to show you Darwin Recruitment adverts and other content on other
websites, for example Facebook. If you do not want us to use your data in this
way, please turn off the “Advertising Cookies” option (please refer to
our Cookies Policy). Even where you have turned off advertising cookies, it is
still possible that you may see a Darwin Recruitment advert, but in this case it
won’t have been targeted at you personally, but rather at an anonymous audience.

Equal opportunities monitoring and other sensitive personal data

We are committed to ensuring that our recruitment processes are aligned with our
approach to equal opportunities. Some of the data we may (in appropriate
circumstances and in accordance with local law and requirements) collect about
you comes under the umbrella of "diversity information". This could be
information about your ethnic background, gender, disability, age, sexual
orientation, religion or other similar beliefs, and/or social-economic
background. Where appropriate and in accordance with local laws and
requirements, we'll use this information on an anonymised basis to monitor our
compliance with our equal opportunities policy. We may also disclose this
(suitably anonymised where relevant) data to Clients where this is contractually
required or the Clients pecifically requests such information to enable them to
comply with their own employment processes.

This information is what is called ‘sensitive’ personal information and slightly
stricter data protection rules apply to it. We therefore need to obtain your
explicit consent before we can use it. We'll ask for your consent by offering
you an opt-in. This means that you have to explicitly and clearly tell us that
you agree to us collecting and using this information.

We may collect other sensitive personal data about you, such as health-related
information, religious affiliation, or details of any criminal convictions if
this is appropriate in accordance with local laws and is required for a role
that you are interested in applying for. We will never do this without your
explicit consent.

If you would like to find out more about consent, please click here. Please note
that in certain of the jurisdictions in which we operate, different rules apply
to this sensitive data. For more information in relation to your jurisdiction,
please click here.

If you are not happy about this, you have the right to withdraw your consent at
any time and you can find out how to do so here.

To help us to establish, exercise or defend legal claims

In more unusual circumstances, we may use your personal data to help us to
establish, exercise or defend legal claims.

 Profiling

Although at present all our recruitment activities involve human-decision making
during the process, we may in the future use fully automated technologies such
as expert systems or machine learning to complete a Candidate selection process
from end-to-end, where appropriate and in accordance with any local laws and
requirements.

Where appropriate, we will seek your consent to carry out some or all of these
activities. If you do not provide consent to profiling, your application will
continue to be reviewed manually for opportunities you apply for, but your
profile will not be automatically considered for alternative roles. This is
likely to decrease the likelihood of us successfully finding you a new job.

You have the right to withdraw that consent at any time and can find out more
about how to do so here.

***

CLIENT DATA: We use Client information for:

 * Recruitment Activities;
 * Marketing Activities; and
 * To help us to establish, exercise or defend legal claims.

Here are some more details about each:

Recruitment Activities

Obviously, our main area of work is recruitment. We've listed below the various
ways in which we use your data in order to facilitate this.

 * Storing your details (and updating them when necessary) on our database, so
   that we can contact you in relation to recruitment activities;
 * Keeping records of our conversations and meetings, so that we can provide
   targeted services to you;
 * Undertaking customer satisfaction surveys; and
 * Processing your data for the purpose of targeting appropriate marketing
   campaigns.

We may use your personal data for these purposes if we deem this to be necessary
for our legitimate interests. If you would like to know more about what this
means, please click here.

If you are not happy about this, in certain circumstances you have the right to
object and can find out more about how and when to do this here.

Marketing Activities

Subject to any applicable local laws and requirements, we will not, as a matter
of course, seek your consent when sending marketing materials such as our Global
Skills Index to a corporate postal or email address.

If you are not happy about this, you have the right to opt out of receiving
marketing materials from us and can find out more about how to do
so contactushere.

Please note that in certain of the jurisdictions in which we operate, we comply
with additional local law requirements regarding marketing activities. For more
information in relation to your jurisdiction, please click here.

To help us to establish, exercise or defend legal claims

In more unusual circumstances, we may use your personal data to help us to
establish, exercise or defend legal claims.

***

SUPPLIER DATA: We realise that you're probably busy, and don't want us to be
contacting you about all sorts of things. To find the right balance, we will
only use your information:

 * To store (and update when necessary) your details on our database, so that we
   can contact you in relation to our agreements;
 * To offer services to you or to obtain support and services from you;
 * To perform certain legal obligations;
 * To help us to target appropriate marketing campaigns; an
 * In more unusual circumstances, to help us to establish, exercise or defend
   legal claims.

We may use your personal data for these purposes if we deem this to be necessary
for our legitimate interests. If you want to know more about what this means,
please click here.

We will not, as a matter of course, seek your consent when sending marketing
messages to a corporate postal or email address.

If you are not happy about this, in certain circumstances you have the right to
object and can find out more about how to do so here.

Please note that in certain of the jurisdictions in which we operate, we comply
with additional local law requirements For more information in relation to your
jurisdiction, please click here.

***

PEOPLE WHOSE DATA WE RECEIVE FROM CANDIDATES AND STAFF, SUCH AS REFEREES AND
EMERGENCY CONTACTS: We will only use the information that our Candidate gives us
about you for the following purposes:

 * If our Candidates or Staff members put you down on our form as an emergency
   contact, we'll contact you in the case of an accident or emergency affecting
   them; or
 * If you were put down by our Candidate or a prospective member of Staff as a
   referee, we will contact you in order to take up a reference. This is an
   important part of our Candidate quality assurance process, and could be the
   difference between the individual getting a job or not.
 * If you were put down by our Candidate or a prospective member of Staff as a
   referee, we may sometimes use your details to contact you in relation to
   recruitment activities that we think may be of interest to you, in which case
   we will use your data for the same purposes for which we use the data of
   Clients. If you would like to find out more about what this means, please
   click here.

We may use your personal data for these purposes if we deem this to be necessary
for our legitimate interests. If you would like to find out more about what this
means, please click here.

If you are not happy about this, you have the right to object and can find out
more about how to do so here.

***

WEBSITE USERS: We use your data to help us to improve your experience of using
our website, for example by analysing your recent job search criteria to help us
to present jobs, content, blogs, literature and downloads to you that we think
you'll be interested in.

If you would like to find out more about cookies, including how we use them and
what choices are available to you, please click here.

******************************

 WHO DO WE SHARE YOUR PERSONAL DATA WITH?

Where appropriate and in accordance with local laws and requirements, we may
share your personal data, in various ways and for various reasons, with the
following categories of people:

 * Any of our group companies;]
 * Individuals and organisations who hold information related to your reference
   or application to work with us, such as current, past or prospective
   employers, educators and examining bodies and employment and recruitment
   agencies;
 * Tax, audit, or other authorities, when we believe in good faith that the law
   or other regulation requires us to share this data (for example, because of a
   request by a tax authority or in connection with any anticipated litigation);
 * Third party service providers who perform functions on our behalf (including
   external consultants, business associates and professional advisers such as
   lawyers, auditors and accountants, technical support functions and IT
   consultants carrying out testing and development work on our business
   technology systems);
 * Third party outsourced IT and document storage providers where we have an
   appropriate processing agreement (or similar protections) in place;
 * Marketing technology platforms and suppliers
 * In the case of Candidates: potential employers and other recruitment
   agencies/organisations to increase your chances of finding employment;
 * In the case of Candidates: third party partners, job boards and job
   aggregators where we consider this will improve the chances of finding you
   the right job;
 * In the case of Candidates: MSP suppliers as part of our clients' MSP
   programmes;
 * In the case of Candidates and our Candidates' and prospective members of
   Staff's referees: third parties who we have retained to provide services such
   as reference, qualification and criminal convictions checks, to the extent
   that these checks are appropriate and in accordance with local laws;
 * If Darwin Recruitment merges with or is acquired by another business or
   company in the future, (or is in meaningful discussions about such a
   possibility) we may share your personal data with the (prospective) new
   owners of the business or company.

 

*******************************

 HOW DO WE SAFEGUARD YOUR PERSONAL DATA?

We are committed to taking all reasonable and appropriate steps to protect the
personal information that we hold from misuse, loss, or unauthorised access. We
do this by having in place a range of appropriate technical and organisational
measures. These include measures to deal with any suspected data breach.

If you suspect any misuse or loss of or unauthorised access to your personal
information please let us know immediately. Details of how to contact us can be
found here.

********************************

HOW LONG DO WE KEEP YOUR PERSONAL DATA FOR?

We will Delete your personal data from our systems if we have not had any
meaningful contact with you (or, where appropriate, the company you are working
for or with) for two years (or for such longer period as we believe in good
faith that the law or relevant regulators require us to preserve your data).
After this period, it is likely your data will no longer be relevant for the
purposes for which it was collected.

For those Candidates whose services are provided via a third party company or
other entity, "meaningful contact" with you means meaningful contact with the
company or entity which supplies your services. Where we are notified by such
company or entity that it no longer has that relationship with you, we will
retain your data for no longer than two years from that point or, if later, for
the period of two years from the point we subsequently have meaningful contact
directly with you.

When we refer to "meaningful contact", we mean, for example, communication
between us (either verbal or written), or where you are actively engaging with
our online services. If you are a Candidate we will consider there to be
meaningful contact with you if you submit your updated CV onto our website or
take part in any of our online training. We will also consider it meaningful
contact if you communicate with us about potential roles, either by verbal or
written communication or click through from any of our marketing communications.
Your receipt, opening or reading of an email or other digital message from us
will not count as meaningful contact – this will only occur in cases where you
click-through or reply directly.

********************************

HOW CAN YOU ACCESS, AMEND OR TAKE BACK THE PERSONAL DATA THAT YOU HAVE GIVEN TO
US?

One of the GDPR's main objectives is to protect and clarify the rights of EU
citizens and individuals in the EU with regards to data privacy. This means that
you retain various rights in respect of your data, even once you have given it
to us. These are described in more detail below.

To get in touch about these rights, please contact us. We will seek to deal with
your request without undue delay, and in any event within one month (subject to
any extensions to which we are lawfully entitled). Please note that we may keep
a record of your communications to help us resolve any issues which you raise.

Right to object: this right enables you to object to us processing your personal
data where we do so for one of the following four reasons: (i) our legitimate
interests; (ii) to enable us to perform a task in the public interest or
exercise official authority; (iii) to send you direct marketing materials; and
(iv) for scientific, historical, research, or statistical purposes.

The "legitimate interests" and "direct marketing" categories above are the ones
most likely to apply to our Website Users, Candidates, Clients and Suppliers. If
your objection relates to us processing your personal data because we deem it
necessary for your legitimate interests, we must act on your objection by
ceasing the activity in question unless:

 * we can show that we have compelling legitimate grounds for processing which
   overrides your interests; or
 * we are processing your data for the establishment, exercise or defence of a
   legal claim.

If your objection relates to direct marketing, we must act on your objection by
ceasing this activity.

Right to withdraw consent: Where we have obtained your consent to process your
personal data for certain activities (for example, for our marketing
arrangements or automatic profiling), you may withdraw this consent at any time
and we will cease to carry out the particular activity that you previously
consented to unless we consider that there is an alternative reason to justify
our continued processing of your data for this purpose in which case we will
inform you of this condition.

Data Subject Access Requests (DSAR): You may ask us to confirm what information
we hold about you at any time, and request us to modify, update or Delete such
information. We may ask you to verify your identity and for more information
about your request. If we provide you with access to the information we hold
about you, we will not charge you for this unless your request is "manifestly
unfounded or excessive". If you request further copies of this information from
us, we may charge you a reasonable administrative cost where legally
permissible. Where we are legally permitted to do so, we may refuse your
request. If we refuse your request we will always tell you the reasons for doing
so.

Please note that in certain of the jurisdictions in which we operate, we comply
with additional local law requirements regarding data subject access requests
and may refuse your request in accordance with such laws. For more information
in relation to your jurisdiction, please click here.

Right to erasure: You have the right to request that we erase your personal data
in certain circumstances. Normally, the information must meet one of the
following criteria:

 * the data are no longer necessary for the purpose for which we originally
   collected and/or processed them;
 * where previously given, you have withdrawn your consent to us processing your
   data, and there is no other valid reason for us to continue processing;
 * the data has been processed unlawfully (i.e. in a manner which does not
   comply with the GDPR);
 * it is necessary for the data to be erased in order for us to comply with our
   legal obligations as a data controller; or
 *  if we process the data because we believe it necessary to do so for our
   legitimate interests, you object to the processing and we are unable to
   demonstrate overriding legitimate grounds for our continued processing.

 

Please note that in certain of the jurisdictions in which we operate, we comply
with additional local law requirements regarding data subject right to erasure
and may refuse your request in accordance with local laws. For more information
in relation to your jurisdiction, please click here.

We would only be entitled to refuse to comply with your request for one of the
following reasons:

 * to exercise the right of freedom of expression and information;
 * to comply with legal obligations or for the performance of a public interest
   task or exercise of official authority;
 * for public health reasons in the public interest;
 * for archival, research or statistical purposes; or
 * to exercise or defend a legal claim.

When complying with a valid request for the erasure of data we will take all
reasonably practicable steps to Delete the relevant data.

Right to restrict processing: You have the right to request that we restrict our
processing of your personal data in certain circumstances. This means that we
can only continue to store your data and will not be able to carry out any
further processing activities with it until either: (i) one of the circumstances
listed below is resolved; (ii) you consent; or (iii) further processing is
necessary for either the establishment, exercise or defence of legal claims, the
protection of the rights of another individual, or reasons of important EU or
Member State public interest.

The circumstances in which you are entitled to request that we restrict the
processing of your personal data are:

 * where you dispute the accuracy of the personal data that we are processing
   about you. In this case, our processing of your personal data will be
   restricted for the period during which the accuracy of the data is verified;
 * where you object to our processing of your personal data for our legitimate
   interests. Here, you can request that the data be restricted while we verify
   our grounds for processing your personal data;
 * where our processing of your data is unlawful, but you would prefer us to
   restrict our processing of it rather than erasing it; and
 * where we have no further need to process your personal data but you require
   the data to establish, exercise, or defend legal claims.

 

If we have shared your personal data with third parties, we will notify them
about the restricted processing unless this is impossible or involves
disproportionate effort. We will, of course, notify you before lifting any
restriction on processing your personal data.

Right to rectification: You also have the right to request that we rectify any
inaccurate or incomplete personal data that we hold about you. If we have shared
this personal data with third parties, we will notify them about the
rectification unless this is impossible or involves disproportionate effort.
Where appropriate, we will also tell you which third parties we have disclosed
the inaccurate or incomplete personal data to. Where we think that it is
reasonable for us not to comply with your request, we will explain our reasons
for this decision.

Right of data portability: If you wish, you have the right to transfer your
personal data between data controllers. In effect, this means that you are able
to transfer your Darwin Recruitment account details to another online platform.
To allow you to do so, we will provide you with your data in a commonly used
machine-readable format that is password-protected so that you can transfer the
data to another online platform. Alternatively, we may directly transfer the
data for you. This right of data portability applies to: (i) personal data that
we process automatically (i.e. without any human intervention); (ii) personal
data provided by you; and (iii) personal data that we process based on your
consent or in order to fulfil a contract.

Right to lodge a complaint with a supervisory authority: You also have the right
to lodge a complaint with your local supervisory authority. Details of how to
contact them can be found here.

If you would like to exercise any of these rights, or withdraw your consent to
the processing of your personal data (where consent is our legal basis for
processing your personal data), details of how to contact us can be found here.
Please note that we may keep a record of your communications to help us resolve
any issues which you raise.

You may ask to unsubscribe from job alerts at any time. Details of how to do so
can be found here.

It is important that the personal information we hold about you is accurate and
current. Please keep us informed if your personal information changes during the
period for which we hold your data.

********************************

 

WHO IS RESPONSIBLE FOR PROCESSING YOUR PERSONAL DATA ON THE DARWIN RECRUITMENT
WEBSITE?

The Marketing Team at Darwin Professional Staffing Group are responsible for
processing the personal Data that is captured via the Darwin Website. You can
contact the director of this team by emailing sarah.wall@darwinrecruitment.com.

If you have any comments or suggestions concerning this Privacy Policy please
follow this link. We take privacy seriously so we'll get back to you as soon as
possible.

********************************

 HOW DO WE STORE AND TRANSFER YOUR DATA INTERNATIONALLY?

So you want to know more about how we store and transfer your data
internationally? In order to provide you with the best service and to carry out
the purposes described in this Privacy Policy, your data may be transferred:

 * between and within Darwin Recruitment entities;
 * to third parties (such as advisers or other Suppliers to the Darwin
   Recruitment business);
 * to overseas Clients;
 * to Clients within your country who may, in turn, transfer your data
   internationally;
 * to a cloud-based storage provider; and
 * to other third parties, as referred to here.

We want to make sure that your data are stored and transferred in a way which is
secure. We will therefore only transfer data outside of the European Economic
Area or EEA (i.e. the Member States of the European Union, together with Norway,
Iceland and Liechtenstein) where it is compliant with data protection
legislation and the means of transfer provides adequate safeguards in relation
to your data, for example:

 * by way of data transfer agreement, incorporating the current standard
   contractual clauses adopted by the European Commission for the transfer of
   personal data by data controllers in the EEA to data controllers and
   processors in jurisdictions without adequate data protection laws; or
 * by signing up to the EU-U.S. Privacy Shield Framework for the transfer of
   personal data from entities in the EU to entities in the United States of
   America or any equivalent agreement in respect of other jurisdictions; or
 * transferring your data to a country where there has been a finding of
   adequacy by the European Commission in respect of that country's levels of
   data protection via its legislation; or
 * where it is necessary for the conclusion or performance of a contract between
   ourselves and a third party and the transfer is in your interests for the
   purposes of that contract (for example, if we need to transfer data outside
   the EEA in order to meet our obligations under that contract if you are a
   Clientof ours); or
 * where you have consented to the data transfer.

 

To ensure that your personal information receives an adequate level of
protection, we have put in place appropriate procedures with the third parties
we share your personal data with to ensure that your personal information is
treated by those third parties in a way that is consistent with and which
respects the law on data protection.

********************************

COOKIES POLICY

What's a cookie?

A "cookie" is a piece of information that is stored on your computer's hard
drive and which records your navigation of a website so that, when you revisit
that website, it can present tailored options based on the information stored
about your last visit. Cookies can also be used to analyse traffic and for
advertising and marketing purposes.

Cookies are used by nearly all websites and do not harm your system. If you want
to check or change what types of cookies you accept, this can usually be altered
within your browser settings. We also provide information about this in our
Marketing preferences page on the Darwin Recruitment website.

How do we use cookies?

We use cookies to do two things:

 * to track your use of our website. This enables us to understand how you use
   the site and track any patterns that emerge individually or from larger
   groups. This helps us to develop and improve our website and services in
   response to what our visitors want and need; and
 * to help us advertise jobs to you that we think you'll be interested in.
   Hopefully this means less time for you trawling through endless pages and
   will get you into the employment you want more quickly.

Cookies are either:

 * Session cookies: these are only stored on your computer during your web
   session and are automatically deleted when you close your browser – they
   usually store an anonymous session ID allowing you to browse a website
   without having to log in to each page but they do not collect any information
   from your computer; or
 * Persistent cookies: a persistent cookie is stored as a file on your computer
   and it remains there when you close your web browser. The cookie can be read
   by the website that created it when you visit that website again. We use
   persistent cookies for Google Analytics and for personalisation (see below).

Cookies can also be categorised as follows:

 * Strictly necessary cookies: These cookies are essential to enable you to use
   the website effectively, such as when applying for a job, and therefore
   cannot be turned off. Without these cookies, the services available to you on
   our website cannot be provided. These cookies do not gather information about
   you that could be used for marketing or remembering where you have been on
   the internet.
 * Performance cookies: These cookies enable us to monitor and improve the
   performance of our website. For example, they allow us to count visits,
   identify traffic sources and see which parts of the site are most popular.
 * Functionality cookies: These cookies allow our website to remember choices
   you make (such as your user name, language or the region you are in) and
   provide enhanced features. For instance, we may be able to provide you with
   news or updates relevant to the services you use. These cookies can also be
   used to remember changes you have made to text size, font and other parts of
   web pages that you can customise. They may also be used to provide services
   you have requested such as viewing a video or commenting on a blog. The
   information these cookies collect is usually anonymised.
 * Personalisation cookies: These cookies help us to advertise details of
   potential job opportunities that we think may be of interest. These cookies
   are persistent (for as long as you are registered with us) and mean that when
   you log in or return to the website, you may see advertising for jobs that
   are similar to jobs that you have previously browsed.

 

****************************

OUR LEGAL BASES FOR PROCESSING YOUR DATA

LEGITIMATE INTERESTS

Article 6(1)(f) of the GDPR is the one that is relevant here – it says that we
can process your data where it "is necessary for the purposes of the legitimate
interests pursued by [us] or by a third party, except where such interests are
overridden by the interests or fundamental rights or freedoms of [you] which
require protection of personal data."

We don't think that any of the following activities prejudice individuals in any
way – in fact, they help us to offer you a more tailored, efficient service, so
everyone's a winner! However, you do have the right to object to us processing
your personal data on this basis. If you would like to know more about how to do
so, please click here.

Please note that in certain of the jurisdictions in which we operate, a
different legal basis for data processing might apply in certain cases. For more
information in relation to your jurisdiction, please click here.

CANDIDATE DATA:

We think it's reasonable to expect that if you are looking for employment or
have posted your professional CV information on a job board or professional
networking site, you are happy for us to collect and otherwise use your personal
data to offer or provide our recruitment services to you, share that information
with prospective employers and assess your skills against our bank of vacancies.
Once it's looking like you may get the job, your prospective employer may also
want to double check any information you've given us (such as the results from
psychometric evaluations or skills tests) or to confirm your references,
qualifications and criminal record, to the extent that this is appropriate and
in accordance with local laws. We need to do these things so that we can
function as a profit-making business, and to help you and other Candidates get
the jobs you deserve.

We want to provide you with tailored job recommendations and relevant articles
to read to help you on your job hunt. We therefore think it's reasonable for us
to process your data to make sure that we send you the most appropriate content.

We also think that it might help with your job search if you take part in our
specialist online training or some of our more interactive services, if you have
the time. These are part of our service offering as a business, and help
differentiate us in a competitive marketplace, so it is in our legitimate
interests to use your data for this reason.

We have to make sure our business runs smoothly, so that we can carry on
providing services to Candidates like you. We therefore also need to use your
data for our internal administrative activities, like payroll and invoicing
where relevant.

We have our own obligations under the law, which it is a legitimate interest of
ours to insist on meeting! If we believe in good faith that it is necessary, we
may therefore share your data in connection with crime detection, tax collection
or actual or anticipated litigation.

***

CLIENT DATA:

To ensure that we provide you with the best service possible, we store your
personal data and/or the personal data of individual contacts at your
organisation as well as keeping records of our conversations, meetings,
registered jobs and placements. From time to time, we may also ask you to
undertake a customer satisfaction survey. We think this is reasonable – we deem
these uses of your data to be necessary for our legitimate interests as an
organisation providing various recruitment services to you.

***

SUPPLIER DATA:

We use and store the personal data of individuals within your organisation in
order to facilitate the receipt of services from you as one of our Suppliers. We
also hold your financial details, so that we can pay you for your services. We
deem all such activities to be necessary within the range of our legitimate
interests as a recipient of your services.

***

PEOPLE WHOSE DATA WE RECEIVE FROM CANDIDATES AND STAFF, SUCH AS REFEREES AND
EMERGENCY CONTACTS:

If you have been put down by a Candidate or a prospective member of Staff as one
of their referees, we use your personal data in order to contact you for a
reference. This is a part of our quality assurance procedure and so we deem this
to be necessary for our legitimate interests as an organisation offering
recruitment services and employing people ourselves.

If a Candidate or Staff member has given us your details as an emergency
contact, we will use these details to contact you in the case of an accident or
emergency. We are sure you will agree that this is a vital element of our
people-orientated organisation, and so is necessary for our legitimate
interests.

****************************************

 CONSENT

In certain circumstances, we are required to obtain your consent to the
processing of your personal data in relation to certain activities. Depending on
exactly what we are doing with your information, this consent will be opt-in
consent or soft opt-in consent.

Article 4(11) of the GDPR states that (opt-in) consent is "any freely given,
specific, informed and unambiguous indication of the data subject's wishes by
which he or she, by a statement or by a clear affirmative action, signifies
agreement to the processing of personal data relating to him or her." In plain
language, this means that:

 * you have to give us your consent freely, without us putting you under any
   type of pressure;
 * you have to know what you are consenting to – so we'll make sure we give you
   enough information;
 * you should have control over which processing activities you consent to and
   which you don’t. We provide these finer controls within our privacy
   preference centre; and
 * you need to take positive and affirmative action in giving us your consent –
   we're likely to provide a tick box for you to check so that this requirement
   is met in a clear and unambiguous fashion.

We will keep records of the consents that you have given in this way.

 

We have already mentioned that, in some cases, we will be able to rely on soft
opt-in consent. We are allowed to market products or services to you which are
related to the recruitment services we provide as long as you do not actively
opt-out from these communications.

Please note that in certain of the jurisdictions in which we operate, we comply
with additional local law requirements regarding consenting to receive marketing
materials. For more information in relation to your jurisdiction, please click
here.

As we have mentioned, you have the right to withdraw your consent to these
activities. You can do so at any time, and details of how to do so can be found
here.

ESTABLISHING, EXERCISING OR DEFENDING LEGAL CLAIMS

Sometimes it may be necessary for us to process personal data and, where
appropriate and in accordance with local laws and requirements, sensitive
personal data in connection with exercising or defending legal claims. Article
9(2)(f) of the GDPR allows this where the processing "is necessary for the
establishment, exercise or defence of legal claims or whenever courts are acting
in their judicial capacity".

This may arise for example where we need to take legal advice in relation to
legal proceedings or are required by law to preserve or disclose certain
information as part of the legal process.

ANNEX 1 – HOW TO CONTACT US

Country in which you use Darwin Recruitment' services or supply Darwin
Recruitment with services: UK

Darwin Recruitment entity responsible for processing the personal data of
Website Users: Darwin Recruitment Specialist Recruitment Limited

The Darwin Recruitment entity responsible for processing the personal data of
Candidates, Clients, Suppliers and the emergency contacts and referees of
Candidates and Darwin Recruitment' Staff will depend on which of the below
companies is the counterparty associated with the relevant arrangement:

Darwin Recruitment Enterprise

Darwin Recruitment B.V.

Darwin Recruitment AG

Darwin Recruitment GmbH

Darwin Recruitment USA

Darwin Professional Staffing Group

How you can get in touch with us:

FROM INSIDE GERMANY:

 * to access, amend or take back the personal data that you have given us;
 * if you suspect any misuse or loss of or unauthorised access to your personal
   information;
 * to withdraw your consent to the processing of your personal data (where
   consent is the legal basis on which we process your personal data);
 * You can contact our designated Data Protection Officers

Kontaktdaten unseres Datenschutzbeauftragten:
c/o activeMind.legal Rechtsanwaltsgesellschaft m.b.H.
Potsdamer Str. 3
80802 München
Tel.: 089-418560170

 * Alternatively you can send an email
   to: Datenschutzbeauftragter-Darwin_GmbH@darwinrecruitment.com

FROM OUTSIDE OF GERMANY:
 * to access, amend or take back the personal data that you have given to us;
 * if you suspect any misuse or loss of or unauthorised access to your personal
   information;
 * to withdraw your consent to the processing of your personal data (where
   consent is the legal basis on which we process your personal data);
 * with any comments or suggestions concerning this Privacy Policy
 * You can write to us at the following address:

Cumberland House, 129 High Street, Billericay, CM12 9AH

 * Alternatively, you can send an email to: marketing@Darwin Recruitment.com.
 * How you can get in touch with us to update your marketing preferences

You can do this by updating your profile here.

 * Alternatively you can email us at: marketing@Darwin Recruitment.com or by
   clicking the unsubscribe link in any marketing e-mail we send to you.

ANNEX 2 – HOW TO CONTACT YOUR LOCAL SUPERVISORY AUTHORITY

Country in which you use Darwin Recruitment' services or supply Darwin
Recruitment with services: UK

Details of your local supervisory authority: The Information Commissioner's
Office. You can contact them in the following ways:

 * Phone: 0303 123 1113
 * Email: casework@ico.org.uk
 * Live chat.
 * Post: Information Commissioner's Office

Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF

ANNEX 3 – COUNTRY-SPECIFIC VARIATIONS TO OUR PRIVACY POLICY

PRIVACY POLICY TOPIC: DARWIN RECRUITMENT' PROCESSING OF YOUR SENSITIVE PERSONAL
DATA

JURISDICTION: UK

COUNTRY-SPECIFIC LEGAL REQUIREMENT: Where your personal data are processed in
accordance with the fair processing condition relating to our rights and
obligations under employment and social security law, this relates to our
processing of your personal data which is necessary for compliance with legal
obligations (such as ensuring that we pay you statutory sick pay, comply with
the statutory employment protections that you enjoy, comply with health and
safety laws, and ensure that appropriate National Insurance contributions are
made).

NOTE: THIS APPENDIX WILL BE UPDATED WHEN LOCAL IMPLEMENTING LAW HAS BEEN
FINALISED

ANNEX 4 – COOKIES LIST

Cookie Name

Google Adwords User Lists

Google Analytics

GA Audiences

Google Tag Manager

Google Dynamic Remarketing

Google Adwords Conversion

Facebook Connect

Facebook Custom Audience

Mouseflow

GLOSSARY

Candidates – includes applicants for all roles advertised or promoted by Darwin
Recruitment, including permanent, part-time and temporary positions and
freelance roles with Darwin Recruitment' Clients; as well as people who have
supplied a speculative CV to Darwin Recruitment not in relation to a specific
job. Individual contractors, freelance workers and employees of suppliers or
other third parties put forward for roles with Darwin Recruitment, Clients as
part of an MSP offering or otherwise will be treated as candidates for the
purposes of this Privacy Policy.

Clients - while it speaks for itself, this category covers our customers,
clients, and others to whom Darwin Recruitment provides services in the course
of its business.

Delete – while we will endeavour to permanently erase your personal data once it
reaches the end of its retention period or where we receive a valid request from
you to do so, some of your data may still exist within our systems, for example
if it is waiting to be overwritten. For our purposes, this data has been put
beyond use, meaning that, while it still exists on an archive system, this
cannot be readily accessed by any of our operational systems, processes or
Staff.

General Data Protection Regulation (GDPR) – a European Union statutory
instrument which aims to harmonise European data protection laws. It has an
effective date of 25 May 2018, and any references to it should be construed
accordingly to include any national legislation implementing it.

Other people whom Darwin Recruitment may contact – these may include Candidates'
and Darwin Recruitment's Staff emergency contacts and referees. We will only
contact them in appropriate circumstances.

Staff – includes employees and interns engaged directly in the business of
Darwin Recruitment (or who have accepted an offer to be engaged) as well as
certain other workers engaged in the business of providing services to Darwin
Recruitment (even though they are not classed as employees). For these purposes
we also include employees of Darwin Recruitment who are engaged to work on
Clients' premises. To be clear, 'Staff' does not include individuals hired by
Darwin Recruitment for the purpose of being placed with Clients outside of an
RPO/MSP arrangement. These individuals are treated in the same way as Darwin
Recruitment' Candidates and are covered by this Privacy Policy. Likewise,
independent contractors and consultants performing services for Darwin
Recruitment fall within the definition of a 'Supplier' for the purposes of this
Privacy Policy.

Suppliers – refers to partnerships and companies (including sole traders), and
atypical workers such as independent contractors and freelance workers, who
provide services to Darwin Recruitment. In certain circumstances Darwin
Recruitment will sub-contract the services it provides to Clients to third party
suppliers who perform services on Darwin Recruitment' behalf. In this context,
suppliers that are individual contractors, freelance workers, or employees of
suppliers will be treated as Candidates for data protection purposes. Please
note that in this context, Darwin Recruitment requires Suppliers to communicate
the relevant parts of this Privacy Policy (namely the sections directed at
Candidates) to their employees.

Website Users - any individual who accesses any of the Darwin Recruitment
websites.

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