What kind of personal data do we 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.
CLIENT DATA: The data we collect about Clients is 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 may also hold extra information that someone in your organisation has chosen to tell us. If we need any additional personal data for any reason, we will let you know. If you are a direct customer of ours, we will need your name, telephone number, email address and postal address, to ensure we can deliver your order.
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, so that we can communicate with you. We’ll also collect bank details, so that we can pay you (if this is part of the contractual arrangements between us). We may also hold extra information that someone in your organisation has chosen to tell us.
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 Candidates or prospective member of Staff, so that we can secure their suitability for a role. 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, we will collect any information that you provide to us, for example your name and contact details.
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 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.
How do we collect your personal data?
CLIENT DATA: We collect Clients personal data in three ways:
- Personal data that we receive directly from you:
– Where you contact us proactively, usually by phone or email; and/or
– Where we contact you, either by phone or email,
- Personal data that 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 that we collect automatically 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.
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.
We collect your data automatically via cookies, in line with cookie settings in your browser. If you are also a Client of Delicious Alchemy, we may use data from your use of our websites to enhance other aspects of our communications with or service to you.
How do we use your personal data?
Having obtained data about you, we then use it in a number of ways.
CLIENT DATA: We use Client information for:
– Legitimate Business Activities: We’ve listed below the various ways in which we use your data in order to facilitate this:
– 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.
– 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 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.
– 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; and
– 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.
We will not, as a matter of course, seek your consent when sending marketing messages to a corporate postal or email address.
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.
WEBSITE USERS: We use your data to help us to improve your experience of using our website.
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 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 Delicious Alchemy 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 can you access, amend or take back the personal data that you have given to us?
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), 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.
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.
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. To allow you to do so, we will provide you with your data in a commonly used machine-readable format so that you can transfer the data to the other data controller. 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.
If you would like to exercise any of these rights, please note that we may keep a record of your communications to help us resolve any issues which you raise.
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.
Our legal bases for processing your data – legitimate interests
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 and meetings. 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.
Our legal bases for processing your data – 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 services we provide as long as you do not actively opt-out from these communications.
Our legal bases for processing your data – 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.
How to contact us
How you can get in touch with us:
- 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);
- You can write to us at the following address:
- 4 Atlas Way, Sheffield, United Kingdom, S4 7QQ
- Alternatively, you can send an email to: firstname.lastname@example.org
How you can get in touch with us to update your marketing preferences
You can do this by emailing us at: email@example.com or by clicking the unsubscribe link in any marketing e-mail we send to you.
How to contact your local supervisory authority
Details of your local supervisory authority: The Information Commissioner’s Office. You can contact them in the following ways:
Candidates – includes applicants for all roles advertised or promoted by Delicious Alchemy, including permanent, part-time and temporary positions and freelance roles; as well as people who have supplied a speculative CV to Delicious Alchemy not in relation to a specific job.
Clients – while it speaks for itself, this category covers our customers, clients, and others to whom Delicious Alchemy 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 Delicious Alchemy may contact – these may include Candidates’ and Delicious Alchemy’s Staff emergency contacts and referees. We will only contact them in appropriate circumstances.
Website Users – any individual who accesses any of the Delicious Alchemy websites.