Privacy Policy

Introduction

Davies Resourcing Limited with its registered office at 5th Floor, 20 Gracechurch Street, London, EC3V 0BG, United Kingdom, and its entities and subsidiaries (hereinafter referred to as ‘Davies Resourcing’) is committed to being transparent about how it processes your personal data.

This Privacy Policy outlines how Davies Resourcing will collect, hold, process, and share your personal data, to assist you in making informed decisions when using our website and/or accessing our products and services.

In this Privacy Policy, the terms ‘we’, ‘our’ or ‘us’ are used to refer to Davies Resourcing, who are the data controller or processor responsible for processing your personal data.

Data Protection

Davies Group Limited and its subsidiary companies, including Davies Resourcing, are committed to protecting the privacy of our clients, candidates, contingent workers, Independent Contractors and users of our websites, and we endeavour to always provide a safe and secure user experience.

We will ensure that the information you submit to us, or which we collect via various channels (including our website, through written correspondence including e-mail, conversations, or meetings with our consultants) is only used for the purposes set out in this Privacy Policy.

Through this Privacy Policy, we aim to inform you about the types of personal data Davies Resourcing collects, the purposes for which we use the data and the ways in which the data is handled. We also aim to satisfy our obligation of transparency under applicable personal data protection and privacy laws, including the UK/EU GDPR.

The Types of Personal Data We Collect

We collect and process the following types of personal data:

  • When you browse our website, we use cookies to collect usage data, which may include, but is not limited to, your IP address, browser type/version, browsing behaviour on our site (including the pages that you visit, the time spent on those pages and the date and time of your visit) and your geolocation data. More information about the types of cookies we use and our reasons for using them can be in our Cookie Policy.
  • Personal identifiers, including but not limited to your name and contact details, date of birth, National Insurance number and characteristics, such as your country of residence, address, telephone number and email address.
  • Recruitment information, including copies of your right to work documentation, references and other information included in your CV, cover letter or application form as part of the application process.
  • Employment records, including job titles, work history, previous salary information, leave date and reason for leaving, working hours, holidays, training records and professional memberships.
  • Information about your next of kin and emergency contacts.
  • Details of periods of leave taken by you and the reasons for the leave.
  • Details of any disciplinary or grievance procedures in which you have been involved, including any warnings issued to you and related correspondence.
  • Records of your communication with us during the recruitment and selection process, including emails you send to our Recruitment Team.
  • A recording of your interview(s), if carried out remotely via Microsoft Teams, or any other online platform.
  • Records relating to any pre-employment checks we conduct for you, such as credit and/or criminal record checks, regulatory checks.
  • Psychometric testing data.

Davies Resourcing may also collect, store, and use the following ‘special categories’ of personal data about you:

  • Information about your medical, health and/or medical diagnosis information, including whether or not you have a disability or other underlying conditions for Davies Resourcing needs to make reasonable adjustments.
  • Information about your criminal convictions and / or offences.
  • Information relating to your race or ethnic origin, sexual life and orientation, or your religious / philosophical / moral beliefs, where this information is needed to facilitate equal opportunities monitoring.

Where We Obtain Your Personal Data From

The personal data we process for our candidates within Davies Resourcing is collected during the course of our working relationship with you. The data may be collected from you directly, or from a variety of sources including, but not limited to:

  • Organisations to whom you have provided your CV and who have engaged with you as part of a job application.
  • Application forms, CVs or resumes.
  • Our clients.
  • Our website cookies.
  • Your passport or other identity documents such as your driving license.
  • Forms completed by you as part of the onboarding and screening process.
  • Correspondence and conversations we have with you.
  • Information you enter into our systems as part of the recruitment process.
  • Interviews, meetings, and other assessments.
  • Fraud prevention agencies and organisations.
  • Industry regulators and ombudsmen, including but not limited to the Financial Conduct Authority (FCA), Information Commissioner’s Office (ICO) and Financial Ombudsman Service (FOS).
  • Insurance companies.
  • Insurance industry databases.
  • Law enforcement agencies.
  • Social media.
  • Third party data providers / search systems.
  • Recruitment companies.
  • Background check providers.
  • Former employers.
  • Credit reference and other agencies, as part of the background checking process.

Our Lawful Bases For Processing Your Personal Data

Under the UK/EU General Data Protection Regulation (‘GDPR’), the lawful bases we may rely on for processing your personal data are:

  • Consent – you have given clear consent for us to process your personal data for a specific purpose. Please note – for any processing we undertake which relies on your consent, you are able to remove your consent at any time by contacting us at talent@davies-group.com.
  • Contract – the processing is necessary for a contract we (or the relevant data controller, where we are acting in the capacity of data processor) have with you to perform obligations that we undertake in providing a service to you, or because you have asked us to take specific steps before entering into a contract.
  • Legal Obligation – the processing is necessary for us to comply with the law. We are subject to certain legal requirements which may require us to process your personal data. We may also be obliged by law to disclose your personal data to a regulatory body or law enforcement agency.
  • Vital Interest – the processing is necessary to protect your life.
  • Public Task – the processing is necessary for us to perform a task in the public interest or our official functions, and the task or function has a clear basis in law.
  • Legitimate Interest – the processing is necessary for our legitimate interests or the legitimate interests of a third party, unless there is a good reason to protect your personal data which overrides those legitimate interests.

How We Use Your Personal Information

We will only process your personal data where it is reasonable and necessary to accomplish the processing purposes outlined in this Privacy Policy. This may include, but is not limited to:

  • To provide our services to you.
  • To maintain our business relationship, where you are a user of our website, a client or candidate.
  • To answer your enquiries.
  • To fulfil contractual obligations to our clients.
  • To enable you to submit your CV for general applications, to apply for specific jobs or to subscribe to our job alerts or match your details with job vacancies.
  • To assist us in finding a position that is most suitable for you and to send your personal information (including sensitive personal information) to clients in order to apply for jobs.
  • To retain your details and notify you about future job opportunities other than the specific role for which you have contacted us.
  • To verify your entitlement to work when assessing your suitability for a role.
  • To conduct pre-employment screening to ensure you are permitted to undertake a role for which you have applied. We will only collect information relating to criminal convictions where we are legally permitted to do so, however if you refuse to provide any information when requested, we may be unable to offer you.
  • To comply with our duties in relation to candidates with disabilities or underlying conditions who require reasonable adjustments, and to fulfil our obligations under general health and safety law.
  • To ensure effective contingent worker and Independent Contractor relationship management and business administration.
  • To direct-market services, advise you of news and industry updates, events, promotions, reports and other information. Before we do so, you will be given an option to opt-out of such communications and an option to unsubscribe will also be provided within each communication.
  • To provide you with personalised content on our website, with more relevant communication in our emails, and with a tailored service from our consultants, we use a database to track and record your usage and interaction with our website and emails. We ensure that no personally identifiable attributes are recorded in this database, and we do not share this information with any other business or affiliate.
  • Respond to and defend ourselves against legal claims.
  • Ensure meaningful equal opportunities monitoring and reporting.

We will only share your personal data with other parties where it is reasonable and necessary to accomplish the processing purposes outlined in this Privacy Policy. This may include, but is not limited to, where we:

  • Require pre-employment references from your past employer(s).
  • Provide references on request, for current or former contingent workers and Independent Contractors.
  • Carry out pre-employment background checks, including credit and criminal record checks.
  • Require confirmation from regulators of all necessary regulatory permissions, or to otherwise make appropriate notifications to regulators, where it is a requirement of the role for which you have applied.
  • Have a legitimate business purpose to share personal data with other Davies Group entities to accomplish the processing purposes outlined in this Privacy Policy.
  • Use services of third-party service providers to carry out activities, provide services, or undertake business operations on our behalf.
  • Are required to share information with law enforcement bodies and/or fraud prevention agencies for the purpose of preventing or detecting fraud or criminal activities.

In any such cases, the data we share will be limited to that which is strictly necessary and will be subject to appropriate contractual and confidentiality arrangements being in place.

Additionally, all of our third-party service providers are required to take appropriate security measures to protect your personal data, in line with Davies Group policies, and we do not allow them to use your personal data for their own purposes under any circumstances.

Change of Purpose

We will only process your personal data in line with the purposes for which we collected it, unless we reasonably consider that we need to use it for another purpose, and that purpose is compatible with the original purpose.

Please note – we may process your personal data without your knowledge or consent in compliance with the above rules, where this is required or permitted by law. For example, where the processing relates to the detection and prevention of crime.

Automated Decision-Making and Profiling

In some circumstances, we may use automated processing and decision-making, where a decision is made by automated means without any human involvement. Our current use of automation technologies includes:

  • Robotic Process Automation (RPA) – Where virtual workers automate the copying and pasting of information from one system into another.
  • Self-Service Platforms – Allows humans to directly interact with an RPA process, enabling human-in-the-loop processing of information.
  • Artificial Intelligence (AI) and Machine Learning – To enable virtual workers to learn and understand the data presented and improve effectiveness.
  • Intelligent Automation Digital Assistant – An AI supervisor that automatically manages, tracks, and orchestrates virtual worker schedules and activities.
  • Computer Vision/Optical Character Recognition – Offers pattern matching within images and can be used to interpret complicated language-based text recognition.
  • Natural Language Processing – Translates/extracts human language into computer readable information (think “Hey Siri”) for the purpose of classifying information.
  • Conversational AI – Uses AI and Natural Language Processing to enable real-time conversations with customers via the use of chatbots.
  • API End-points – Uses virtual workers to bridge the gap between old systems and new ones by copying and pasting information across.

We do not anticipate that any of the automation technologies described above will produce legal or similarly significant effects on you, however if this was to change in the future, we would only do so where it is:

  • Necessary for the entry into or performance of a contract; and
  • Authorised under domestic laws applicable to the data controller; or
  • Based on your explicit consent.

International Transfers

We will not knowingly transfer your personal data outside of the United Kingdom (UK) and European Economic Area (EEA) without your consent, or without receiving authorisation from the relevant data controller where we are acting in the capacity of data processor.

Where such a transfer is necessary, we will only make the transfer once we can be assured that suitable protections will be maintained, and appropriate safeguards are in place. This may include:

  • Ensuring that we transfer the personal data to countries that the Information ICO has deemed to provide an adequate level of protection.
  • Putting suitable clauses in our contracts so that organisations take appropriate steps to give personal data the same protection it has in the UK and EEA.
  • Implementing suitable technical and/or organisational measures to protect the personal data.

Please note – where your personal data needs to be transferred between the UK and EEA as part of our business-as-usual operations, this will be done on the basis that the ICO has deemed these jurisdictions to provide an adequate level of protection.

If you would like to understand more about this, please send an email outlining your query to DPO@davies-group.com.

How Long We Will Hold Your Information

We will keep your personal data for as long as necessary to fulfil the purposes that we describe in this Privacy Policy, including to satisfy any applicable legal, tax-related, and other business requirements.

Davies Resourcing often support clients and candidates over many years, and potentially throughout their careers, so the purpose for which we retain data is often an ongoing concern. We conduct regular data-cleansing and updating exercises with our candidates to ensure that:

(a) the data that we hold is accurate and up to date;
(b) we are not holding data for longer than we need to.

To determine the appropriate retention period, we also consider a number of additional factors, such as:

  • The length of our relationship with you, or as long as there is a requirement to provide services to you.
  • Our legitimate interests for retaining your data.
  • Compliance with our legal and contractual obligations.
  • Your rights relating to the information we hold about you. You have certain rights in relation to personal information we hold about you. Further details can be found in the ‘Your Rights’ section below.
  • The nature and sensitivity of the personal data.
  • The potential risk of harm from unauthorised use or disclosure of the personal data.
  • Requirements of the relevant data controller, where we are acting in the capacity of data processor.

Your Rights

Davies Resourcing is committed to processing your personal data in compliance with all applicable laws and regulations. Under UK/EU GDPR, you may be able to exercise several individual rights, including:

Right of Access

You have the right to ask us for a copy of the personal data we hold about you, as well as other supplementary information.

Right to be Informed

You have the right to know how we will collect and use your personal data.

Right to Rectification

If personal information we hold about you is inaccurate, out of date or incomplete, you have a right to have the data rectified, updated or completed. You can let us know by contacting us using the details in the ‘Contact’ section below.

Right of Erasure

In certain circumstances, you have the right to request that personal data we hold about you is erased. For example, if the information is no longer necessary for the purposes for which it was collected or processed, or our processing of the information is based on your consent and there are no other legal grounds on which we may process the information. Please note – there may be certain circumstances under which we are obliged to retain your personal data.

Right to Object or Restrict Processing

In certain circumstances, you have the right to object to our processing of your personal data. For example, if we are processing your information on the basis of our legitimate interests and there are no compelling legitimate grounds for our processing which override your rights and interests. You also have the right to object to use of your personal information for direct marketing purposes.

You may also have the right to restrict our use of your personal information, such as in circumstances where you have challenged the accuracy of the information, for the period of time where we are verifying its accuracy.

Right to Data Portability

You have the right to ask that we transfer the personal information you gave us to another organisation, or to yourself, in certain circumstances.

Rights Related to Automated Decision-Making and Profiling

You have the right to request human intervention where a decision has been taken about you using fully automated decision-making or profiling, and which produces legal or similarly significant effects on you.

You can exercise any of the above rights by contacting us using the details in the ‘Contact’ section below.

Please note – most of the above rights are subject to limitations and exceptions. We will provide reasons if we are unable to comply with any request to exercise your rights.

Contact Us

If you have any questions, or if you would like to contact us about our processing of your personal data, including to exercise your rights as outlined above, please contact us by email at info.talent@davies-group.com.

To the extent that we are processing your personal data based on your consent, you have the right to withdraw your consent at any time. You can do this by contacting us using the email address above. All requests will be processed within 30 days from receipt.

How to Complain

We aim to meet the highest standards to safeguard your privacy. However, if you have any concerns about Davies Resourcing’s use of your personal data, you can make a complaint to our Data Protection Officer by emailing DPO@davies-group.com or by writing to:

Data Protection Officer
Davies Group,
3rd and 4th Floors
No.2 Smithfields
Stoke-on-Trent
ST1 3DH
UK

You also have the right to contact the data protection regulator if you feel that we have processed your personal data in a manner which contravenes privacy law. You can do this by following the link to their website: https://ico.org.uk/make-a-complaint/. Alternatively, you can contact them by:

Post: Information Commissioners Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF

Email: casework@ico.org.uk

Phone: 0303 123 1113 (Local rate) or 01625 545 745 (National rate)

Changes to Our Privacy Policy

We reserve the right to update this Privacy Policy at any time, and we will provide you with a copy of the updated Privacy Policy (displayed electronically) when we make any substantial changes. We may also notify you in other ways from time to time about changes to the processing of your personal information.

This Privacy Policy was last updated on 16/10/2023.