1. PURPOSE OF THIS NOTICE
This notice describes how we collect and use personal data about you, in accordance with the General Data Protection Regulation (GDPR), the Data Protection Act 2018 and any other national implementing laws, regulations and secondary legislation, as amended or updated from time to time, in the UK (‘Data Protection Legislation’). Personal data is any information relating to an identified or identifiable living person.
Please read the following carefully to understand our practices regarding your personal data and how we will treat it.
2. ABOUT US
Dixon Wilson (“we”, “us”, or “our”) is committed to ensuring the protection of the privacy and security of any personal data which we process.
For the purpose of the Data Protection Legislation and this notice, we are the ‘data controller’. This means that we are responsible for deciding how we hold and use personal data about you. We are required under the Data Protection Legislation to notify you of the information contained in this privacy notice.
We have appointed a Head of Data Privacy. Our Head of Data Privacy is our Data Protection Point of Contact and is responsible for assisting with enquiries in relation to this privacy notice or our treatment of your personal data. Should you wish to contact our Data Protection Point of Contact you can do so using the contact details noted below.
3. HOW WE MAY COLLECT YOUR PERSONAL DATA
We obtain personal data about you, for example, when:
- you request a proposal from us in respect of the services we provide;
- you or your employer or our clients engage us to provide our services and also during the provision of those services;
- you contact us by email, telephone, post or social media (for example when you have a query about our services); or
- from third parties and/or publicly available resources (for example, from your employer or from Companies House).
4. THE KIND OF INFORMATION WE HOLD ABOUT YOU
The information we hold about you may include the following:
- your personal details (such as your name and/or address);
- details of contact we have had with you in relation to the provision, or the proposed provision, of our services;
- details of any services you have received from us;
- our correspondence and communications with you;
- information about any complaints and enquiries you make to us;
- information from research, surveys, and marketing activities; and
- information we receive from other sources, such as publicly available information, information provided by your employer or our clients.
5. HOW WE USE PERSONAL DATA WE HOLD ABOUT YOU
We may process your personal data for purposes necessary for the performance of our contract with you or your employer or our clients and to comply with our legal obligations.
We may process your personal data for the purposes necessary for the performance of our contract with our clients. This may include processing your personal data where you are an employee, subcontractor, supplier or customer of our client.
We may process your personal data for the purposes of our own legitimate interests provided that those interests do not override any of your own interests, rights and freedoms which require the protection of personal data. This includes processing for marketing, business development, statistical and management purposes.
We may process your personal data for certain additional purposes with your consent, and in these limited circumstances where your consent is required for the processing of your personal data then you have the right to withdraw your consent to processing for such specific purposes.
Please note that we may process your personal data for more than one lawful basis depending on the specific purpose for which we are using your data.
Situations in which we will use your personal data
We may use your personal data in order to:
- carry out our obligations arising from any agreements entered into between you or your employer or our clients and us (which will most usually be for the provision of our services);
- carry out our obligations arising from any agreements entered into between our clients and us (which will most usually be for the provision of our services) where you may be a subcontractor, supplier or customer of our client;
- provide you with information related to our services and our events and activities that you request from us or which we feel may interest you;
- seek your thoughts and opinions on the services we provide; and
- notify you about any changes to our services.
In some circumstances we may anonymise or pseudonymise the personal data so that it can no longer be associated with you, in which case we may use it without further notice to you.
If you refuse to provide us with certain information when requested, we may not be able to perform the contract we have entered into with you. Alternatively, we may be unable to comply with our legal or regulatory obligations.
We may also process your personal data without your knowledge or consent, in accordance with this notice, where we are legally required or permitted to do so.
We will only retain your personal data for as long as is necessary to fulfil the purposes for which it is collected.
When assessing what retention period is appropriate for your personal data, we take into consideration:
- the requirements of our business and the services provided;
- any statutory or legal obligations;
- the purposes for which we originally collected the personal data;
- the lawful grounds on which we based our processing;
- the types of personal data we have collected;
- the amount and categories of your personal data; and
- whether the purpose of the processing could reasonably be fulfilled by other means.
Change of purpose
Where we need to use your personal data for another reason, other than for the purpose for which we collected it, we will only use your personal data where that reason is compatible with the original purpose.
Should it be necessary to use your personal data for a new purpose, we will notify you and communicate the legal basis which allows us to do so before starting any new processing.
6. DATA SHARING
Why might you share my personal data with third parties?
We will share your personal data with third parties where we are required by law, where it is necessary to administer the relationship between us or where we have another legitimate interest in doing so.
Which third-party service providers process my personal data?
“Third parties” includes third-party service providers. The following activities are carried out by third-party service providers: IT and cloud services, professional advisory services, administration services, marketing services and banking services.
All of our third-party service providers are required to take commercially reasonable and appropriate security measures to protect your personal data. We only permit our third-party service providers to process your personal data for specified purposes and in accordance with our instructions.
What about other third parties?
We may share your personal data with other third parties. We may also need to share your personal data with a regulator or to otherwise comply with the law.
7. TRANSFERRING PERSONAL DATA OUTSIDE THE EUROPEAN ECONOMIC AREA (EEA)
We may transfer the personal data we collect about you to countries outside of the EEA in order to perform our contract with you. This may include countries where there is not an adequacy decision by the European Commission and hence will not be deemed to provide an adequate level of protection for your personal information for the purpose of the Data Protection Legislation.
In these circumstances, the transfers will be under an agreement which covers the EU requirements for the transfer of personal data outside the EU, such as the European Commission approved standard contractual clauses. Should you require further information about these protective measures, please contact us using the contact details outlined below.
8. DATA SECURITY
We have put in place commercially reasonable and appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.
9. RIGHTS OF ACCESS, CORRECTION, ERASURE, AND RESTRICTION
Your duty to inform us of changes
It is important that the personal data we hold about you is accurate and current. Should your personal information change, please notify us of any changes of which we need to be made aware by contacting us, using the contact details below.
Your rights in connection with personal data
Under certain circumstances, by law you have the right to:
- request access to your personal data. This enables you to receive details of the personal data we hold about you and to check that we are processing it lawfully;
- request correction of the personal data that we hold about you;
- request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have exercised your right to object to processing (see below);
- object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this basis. You also have the right to object where we are processing your personal information for direct marketing purposes;
- request the restriction of processing of your personal data. This enables you to ask us to suspend the processing of personal data about you, for example if you want us to establish its accuracy or the reason for processing it; and
- request the transfer of your personal data to you or another data controller if the processing is based on consent, carried out by automated means and this is technically feasible.
If you want to exercise any of the above rights, please email our data protection point of contact (see below).
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.
10. RIGHT TO WITHDRAW CONSENT
In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal data for a specific purpose (for example, in relation to direct marketing that you have indicated you would like to receive from us), you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please email our data protection point of contact (see below).
Once we have received notification that you have withdrawn your consent, we will no longer process your personal information (personal data) for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.
11. CONTACT US
If you have any questions regarding this notice or if you would like to speak to us about the manner in which we process your personal data, please email our Data Protection Point of Contact at firstname.lastname@example.org or write to us at:
Data Protection Point of Contact
22 Chancery Lane
You also have the right to make a complaint to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues, at any time. The ICO’s contact details are as follows:
Information Commissioner's Office
Telephone - 0303 123 1113 (local rate) or 01625 545 745
Website - https://ico.org.uk/concerns
12. CHANGES TO THIS PRIVACY NOTICE
We will keep this privacy notice under regular review. This privacy notice was last updated on 15 May 2018.
As part of Dixon Wilson’s recruitment process, personal data is collected and processed. This notice is addressed to all applicants who are applying to work with us or who are enquiring about vacancies.
Dixon Wilson is a controller of personal data. As controller, the use or processing of personal data we hold is in accordance with this notice. Dixon Wilson takes its data protection responsibilities seriously and this notice reflects the obligations set out in the General Data Protection Regulations which apply to Dixon Wilson. This is regardless of how we receive your application, to the extent permitted under any applicable local laws.
DATA PROTECTION PRINCIPLES
Personal data is information that relates to an identified or identifiable individual.
Personal data belongs to you and it is your choice whether you provide us with your personal data. However, because we require certain personal data to consider your application for example, evidence of qualifications or work history, we may not be able to consider your application further if you do not provide all of the personal data that we request. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during the course of the recruitment process.
If you are successful in your application and commence work with us, a separate internal privacy notice will apply to the use of your personal data during your employment.
We sometimes provide recruitment agencies with the criteria for a role and they provide us with your application, if you meet the criteria. Having received your application we will then process that information.
We will then decide whether your application is strong enough to invite you for an interview or to attend assessments. If we decide to call you for an interview or to attend assessments, we will use the information you provide at the interview(s), and during any assessments, to decide whether to offer you the role.
You are under no obligation to provide personal data to us during the recruitment process.
We may collect, store and use personal data about you, in connection with your application to work with us or in respect of an enquiry about vacancies, including but not limited to the following:
- Personal details: title, name(s);
- Contact details: addresses, telephone numbers and email addresses;
- Information included in references;
- Any other information included on CVs, application forms and covering letters including qualifications, education history, details of previous employment, salary and benefits information and professional memberships;
- Immigration status details including copies of your passport, biometric residence permit and other immigration documents, driving licence;
- Other recruitment data: submissions for and information obtained from any assessment or at interview stage and notes/results thereof, special arrangements required for interview, interview notes, notes from shortlisting exercises, assessment exercises and tests, post interview feedback; and photographs.
SOURCES OF PERSONAL DATA
We may obtain your personal data from various sources including the following:
- Recruitment agencies;
- Statutory or other official bodies such as government immigration departments, including UK Visas and Immigration;
- Past employers;
- Public sources including social media.
We may also create personal data about you, such as interview documentation.
We may seek information from third parties only once a job offer has been made and we will inform you that we are doing so.
LEGAL BASIS FOR PROCESSING
To process personal data in connection with recruitment, we will rely most commonly on one or more of the following legal bases:
We have a legitimate interest in carrying out the processing, which is not overridden by your interests, fundamental rights, or freedoms. When we rely on this legal basis our legitimate interests may include the following:
(a) the management of the recruitment process and employment of staff, in particular making decisions about who to offer employment or engagement to and on what terms;
(b) the efficient running of our business;
(c) meeting external and internal governance and regulatory obligations;
(d) to enable the business to share information internally; and
(e) to enable us to take legal advice and to defend claims.
In rare circumstances we may rely on the following legal basis:
- the processing is necessary for compliance with a legal obligation;
- the processing is necessary for the performance of a contract with us or in order to take steps at your request prior to entering into a contract; or
- the processing is necessary to protect your vital interests or the interests of someone else, or the processing is necessary for the performance of a task carried out in the public interest.
We do not need your consent if we process your data under one or more of the other legal basis set out above. In some circumstances we may approach you for your written consent to allow us to process certain data.
PURPOSES OF PROCESSING
We will use your personal data for a variety of different purposes including the following:
- Making a decision about your recruitment or appointment;
- Determining the terms on which you will work for us, if you are offered employment;
- Checking you are legally entitled to work in the country in which you have applied to be employed;
- Requesting references;
- Communicating with you about your application and the recruitment process;
- Assessing your skills, qualifications and suitability for a particular position;
- Retaining details about you in case there are future employment opportunities for which you may be suited;
- Assessing education, training and development requirements;
- Complying with our legal or regulatory requirements;
- Equal opportunities monitoring;
- Using your personal data in life or death situations (e.g. in the event of an accident and we have to give your personal details to medical personnel).
SPECIAL CATEGORIES OF DATA
Special Categories of Data require higher levels of protection. We need to have further justification for collecting, storing and using this type of data however, Dixon Wilson may lawfully process Special Categories of Data in certain ways, including for the following purposes:
- We will use data about your physical or mental health or disability status to consider if we need to provide any adjustments for the recruitment process, to determine whether you are suitable for the role or to consider if we need to make any adjustments to the role you are applying for. We may use some Special Categories of Data when bringing or defending a legal claim.
- We will use data about your date of birth, nationality, race or national or ethnic origin to ensure meaningful equal opportunity monitoring and reporting.
RECIPIENTS OF PERSONAL DATA
Your information will be shared internally for the purposes of the recruitment exercise. Once we have made an offer we may then share your personal data with third parties, including:
- Your named referees when requesting a reference;
- Government immigration departments (including UK Visas and Immigration).
In addition, we may disclose the personal data that you provide to us to our third party data processers who may process data on our behalf to enable us to carry out our usual business practices. Any such disclosure will only be so that we can process your personal data for the purposes set out in this notice.
All our third party service providers are required to take appropriate security measures to protect your personal information in line with our policies. We only permit them to process your personal data for specified purposes and in accordance with our instructions.
RETENTION AND SECURITY OF PERSONAL DATA
Personal data will be stored in a range of different places, including on application records, in HR information systems and on other IT systems (including email).
Personal data gathered during the recruitment process will be transferred to a personnel file and retained during employment or engagement.
We take the security of personal data seriously. We have internal policies and controls in place to ensure that personal data is not lost, accidentally destroyed, misused or disclosed, and is not accessed except by designated members of staff in the proper performance of their duties.
We will retain personal data (including applications/CVs and interview notes) of all employees for a period of seven years after their final leaving date. For unsuccessful applicants, CVs, application forms and interview notes will be kept for one year.
After this period, our policy is in most circumstances to delete personal data from our system. This is subject to any legal or regulatory obligation to keep personal data for a longer period of time. We will also hold personal data for a longer period if it is required in connection with legal proceedings.
RIGHTS IN RELATION TO YOUR PERSONAL DATA
There are a number of rights in connection with the processing of personal data, subject to certain conditions set out in the General Data Protection Regulations these include the following:
- The request to access personal data (commonly known as a “data subject access request”). This enables individuals to receive a copy of the personal data held and to check that we are holding it lawfully.
- The request to correct personal data that is held. This enables individuals to have incomplete or inaccurate data corrected.
- The request to erase personal data. This enables individuals to ask the Firm to delete or remove personal data where there is no good reason for us holding it.
- The request to ask the Firm to stop processing personal data where we are relying on a legitimate interest and there is something about your particular situation which makes you want to object to processing on this particular ground.
- The request to restrict processing of personal data. This enables an individual to ask the Firm to suspend the processing of personal data, for example if an individual wanted to establish its accuracy or the reason for processing it.
- The request to the transfer of personal data to another party.
If an individual wants to review, verify, correct or request erasure of personal data, or object to the processing of your personal data, or request that we transfer a copy of your personal data to another party, they should email email@example.com.
If an individual wants to make a complaint regarding the processing of personal data to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues, the ICO’s contact details are as follows:
Information Commissioner’s Office
Telephone – 0303 123 1113 (local rate) or 01625 545 745
Website - https://ico.org.uk/concerns
This notice may be amended or updated from time to time.
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Other Legal Matters
This website and its contents are for information only. It is not a substitute for taking professional advice. In no event will Dixon Wilson accept liability to any person for any decision made or action taken in reliance on information contained in this website or from any linked website.
Dixon Wilson is not authorised under the Financial Services and Markets Act 2000 but we are able in certain circumstances to offer a limited range of investment services to clients because we are members of the Institute of Chartered Accountants in England and Wales. We can provide these investment services if they are an incidental part of the professional services we have been engaged to provide.
Dixon Wilson is a partnership and is registered to carry on audit work in the UK and Ireland by the Institute of Chartered Accountants in England and Wales. Details about our audit registration can be viewed at www.auditregister.org.uk for the UK and www.cro.ie/auditors for Ireland, under reference number C005318798. The professional rules applicable to audit work and the Institute’s Code of Ethics can be found at www.icaew.com/regulations. Additionally, further ethical standards for Auditors can be found at www.frc.org.uk.
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