Drake's Privacy Commitment
How we collect personal information
We will collect and store your personal information when you interact with our website or, as a client or applicant, request our services. We collect personal information in writing, by telephone, by e-mail, application forms, resumes, through interviews (in person/ telephone), by contacting individuals that applicants have nominated as referees, from clients to whom services are supplied as part of our temporary staffing business, and through the administration and assessment of the results of aptitude tests and the interpretation of the results of such tests.
Drake collects personal information directly from the individual to whom it relates, except where that individual has consented to Drake collecting the personal information from a third party or the law otherwise permits Drake to do so.
What personal information do we hold about you?
Personal information means any information relating to a person that enables them to be identified either directly or indirectly. Personal information that we hold about you may include your:
- email address;
- phone number;
- IP address; and
- location data.
If you are an applicant, personal information that we hold about you may include the same information listed above, along with your language, gender, date of birth, social network accounts, education, work history, skills, aptitudes, CV, salary/benefit information, information derived from background checks such as criminal convictions and credit records, banking details, driver’s license number, information about your health, (including any medical condition and health and sickness records) and information about your hobbies and interests. We may also process your function/job title and your work email address and your company’s name, postal address, VAT and/or company number. It will also include any personal information we derive about you through the administration of skills, personality or aptitude testing.
We will take reasonable steps to ensure the personal information that we store is accurate, complete and up-to-date.
How we use your information
Drake provides permanent recruitment services that respond to the needs of both employers (“clients”) and applicants by helping to place the right person in the right position. We will use your personal data, and may share your personal data with other parties acting on our behalf or our clients, for one or more of the following purposes:
- to conduct research about the use of our website;
if you are an applicant, to assess your suitability for either permanent or temporary employment with Drake or one of our clients;
- for individuals who are hired by Drake (whether as permanent employees or for temporary staffing arrangements), to carry out our contract with you, including providing payroll services and relevant benefits;
- for our own administrative purposes, including training our staff, conducting internal audits or transferring assets as part of a sale, purchase or investment in the business;
- if you are a client, to carry out our contract with you;
- for market research purposes;
- to assess and respond to a complaint you might make to us;
- to conduct investigations of suspicious or harmful activity; and
- to comply with Drake’s regulatory and legal obligations.
We do not sell your personal information to others.
If we wish to use your personal information for a purpose beyond that for which it was originally provided, we will ask for your consent or seek to rely on another valid legal ground to process your personal information in accordance with the applicable law.
Information for marketing purposes
Where you have consented to us using your personal data for marketing purposes, we may use your information to conduct marketing and data analysis or to send you updates and news concerning Drake and its business partners.
If at any time after you have consented to us using your information for marketing purposes and you wish us to stop using your information for these purposes, please email us at email@example.com.
Grounds for processing
To process your data lawfully we need to rely on one or more valid legal grounds. The grounds we may rely upon include:
- your consent to particular processing activities. For example, where you have consented to us using your information for marketing purposes;
- our legitimate interests as a business (except where your interests or fundamental rights override these). For example, it is within our legitimate interests to use your data to prevent or detect fraud or abuses of our website;
- our compliance with a legal obligation to which Drake is subject. For example, we have a duty to investigate and respond to complaints made against us and may need to process your personal information as part of such investigation; or
- if you are a client, because processing your personal data is necessary for the performance of a contract.
How we use particularly sensitive personal information
“Special categories” of particularly sensitive personal information require higher levels of protection. We need to have further justification for collecting, storing and using this type of personal information. We may process special categories of personal information in the following circumstances:
- in limited circumstances, with your explicit written consent (on a case by case basis);
- where we need to carry out our legal obligations;
- where it is needed in the public interest, such as for equal opportunities monitoring; and
- where it is needed to assess your working capacity on health grounds, subject to appropriate confidentiality safeguards.
Less commonly, we may process this type of information where it is needed in relation to legal claims or where it is needed to protect your interests (or another person’s interests) and you are not capable of giving your consent, or where you have already made the information public.
We do not need your consent if we use “special categories” of your personal information in accordance with this policy to carry out our legal obligations or exercise specific rights in the field of employment law. In limited circumstances, we may approach you for your written consent to allow us to process certain particularly sensitive data. If we do so, we will provide you with full details of the information that we would like and the reason we need it, so that you can carefully consider whether you wish to consent. You should be aware that it is not a condition of your contract with us that you agree to any request for consent from us.
Information about criminal convictions
We may only use your personal information relating to criminal convictions where the law allows us to do so. This will usually be where such processing is necessary to carry out our obligations and provided we do so in line with this policy. Where appropriate, we will collect information about criminal convictions as part of the recruitment process or we may be notified of such information directly by you.
Less commonly, we may use your personal information relating to criminal convictions where it is necessary in relation to legal claims, where it is necessary to protect your interests (or another person’s interests), and you are not capable of giving your consent, or where you have already made the information public.
Automated decision making
Automated decision-making takes place when an electronic system uses personal information to make a decision without human intervention. We do not envisage that any decisions will be taken about you using automated means, however, we will notify you in writing if this position changes.
Disclosure of your personal information
There are circumstances where we may wish to disclose or are compelled to disclose your personal data to third parties. This will only take place in accordance with the applicable law and for the purposes listed above. These scenarios include disclosure:
- to our subsidiaries, branches or associated offices;
- if you are an applicant, to clients for the purposes of possible recruitment of you to specific positions that we feel you may be suited to and/or for supplying your services to clients as a temporary staff worker;
- if you are an applicant, to referees in making enquiries;
- to our outsourced service providers or suppliers to facilitate the provision of our services, for example, the disclosure to our data centre provider for the safe keeping of your personal data;
- to third party service providers and consultants in order to protect the security or integrity of our business, including our databases and systems and for business continuity reasons;
- to organisations and government agencies that provide background checks, including credit, criminal and education background checks;
- to other temporary staffing companies, where we are working on a joint staffing project;
- to another legal entity, on a temporary or permanent basis, for the purposes of a joint venture, collaboration, financing, sale, merger, reorganisation, change of legal form, dissolution or similar event. In the case of a merger or sale, your personal data will be permanently transferred to a successor company;
- to legal advisors who may need to manage or litigate a claim;
- to public authorities where we are required by law to do so; and
- to any other third party where you have provided your consent.
International transfer of personal data
We may transfer your personal data to a third party in countries outside the EU for further processing in accordance with the purposes set out in this policy. In particular, your personal data may be transferred to our outsourced service providers located abroad. In these circumstances we will, as required by applicable law, ensure that your privacy rights are adequately protected by appropriate technical, organisation, contractual or other lawful means. Please contact our Privacy Office at firstname.lastname@example.org for a copy of the safeguards which we have put in place to protect your personal data and privacy rights in these circumstances.
We may disclose your information to any person as required by law and specifically to any government agency if we believe in good faith that we must do so to comply with the law or that doing so is required to prevent, detect, investigate or remedy improper conduct potentially affecting Drake.
Retention of Personal Information
Your personal information will be retained for as long as it is necessary to carry out the purposes set out in this policy (unless longer retention is required by the applicable law). However, we will not retain any of your personal information beyond this period and the retention of your personal information will be subject to periodic review. We may keep an anonymised form of your personal information, which will no longer refer to you, for statistical purposes without time limits, to the extent that we have a legitimate and lawful interest in doing so.
Confidentiality and Security
Drake is committed to:
- seeking to safeguard all personal information that you provide to us;
- seeking to ensure that it remains confidential and secure; and
- taking all reasonable steps to ensure that personal privacy is respected.
All our data is stored in written or electronic form on our servers and computers and in various physical locations. We maintain physical, electronic and procedural safeguards to protect your personal information from misuse, unauthorised access or disclosure and loss or corruption by computer viruses and other sources of harm. We restrict access to personal information to those staff members, joint venture partners, subsidiary companies and third parties who need to know that information for the purposes set out in this policy.
Unfortunately, no data transmission over the Internet can be guaranteed as totally secure. Accordingly, although Drake strives to protect such information, Drake cannot ensure or warrant the security of any information you transmit to us or from our online services and you do so at your own risk. Once we receive your transmission, we will take reasonable steps to preserve the security of this information in our own systems. If you have a login name and/or password for use in conjunction with this website, you are entirely responsible for the maintenance of the confidentiality of that login name and/or password. Furthermore, you are entirely responsible for any and all activities that occur under your login name. You agree to immediately notify Drake of any unauthorized use of your login name and/or password or any other breach of security known to you.
Your rights with regards to your personal information
Data protection law provides individuals with certain rights, including the right to: access, rectify, withdraw consent, erase, restrict, transport, and object to the processing of, their personal information. Individuals also have the right to lodge a complaint with the relevant information protection authority if they believe that their personal information is not being processed in accordance with the law. Further information about your rights is set out below:
- Right to make subject access request (SAR). You may, where permitted by applicable law, request copies of your personal data. If you would like to make a SAR, i.e. a request for copies of the personal data we hold about you, you may do so by writing to our Privacy Office at email@example.com. The request should make clear that a SAR is being made. We will require proof of your identity before providing you with details of any personal data we may hold about you.
- Right to rectification. You may request that we rectify any inaccurate and/or complete any incomplete personal information. If we disagree and believe the information to be accurate and complete, we will advise you and include a notation on the record that you dispute the information’s accuracy. Requests for corrections or supplements to all other personal information should be made to our Privacy Office at firstname.lastname@example.org. We will respond to your request to correct or supplement your personal information within a reasonable time period and, in any event, within any time period specified in relevant laws.
- Right to withdraw consent. You may, as permitted by law, withdraw your consent to the processing of your personal information at any time. Such withdrawal will not affect the lawfulness of processing based on your previous consent. Please note that if you withdraw your consent, you may not be able to benefit from certain service features for which the processing of your personal information is essential.
- Right to object to processing. You may, as permitted by law, request that we stop processing your personal information.
- Right to erasure. You may request that we erase your personal information and we will comply, unless there is a lawful reason for not doing so.
- Your right to lodge a complaint with the supervisory authority. We suggest that you contact us about any questions or if you have a complaint in relation to how we process your personal information. However, you do have the right to contact the relevant supervisory authority in the relevant country directly.
What exactly are cookies?
A cookie is a small file that a website or its service provider transfers to your computer’s hard drive, mobile phone or other device, through your web browser (if you agree) that enables the websites or service providers systems to recognise your browser and capture and remember certain information.
You can set your browser to notify you when you receive a cookie. This enables you to decide if you want to accept it or not. Alternatively, you can choose to turn off all cookies via your browser settings. However, some of the services and features offered through our website may not function properly if your cookies are disabled.
Cookies can be first party or third party cookies.
- First party cookies - cookies that the website you are visiting places on your computer.
- Third party cookies - cookies placed on your computer through the website but by third parties, such as, Google.
What cookies are used on our website?
We may use the following cookies on our website:
- Strictly necessary cookies
These cookies are essential in order to enable you to move around our website and use its features, such as accessing secure areas of the website. Without these cookies, services you have asked for cannot be provided. These cookies are first party cookies. They are deleted when you close the browser.
- Performance cookies
These cookies collect information in an anonymous form about how visitors use our website. They allow us to recognise and count the number of visitors and to see how visitors move around the website when they are using it as well as the approximate regions that they are visiting from. These are first party cookies.
- Functionality cookies
These cookies allow the website to remember choices you make (for example, choice of language or region) and provide enhanced, more personal features when you return to our website. These are first party cookies.
- Targeting or advertising cookies
These cookies allow us and our advertisers to deliver information more relevant to you and your interests. They are also used to limit the number of times you see an advertisement as well as help measure the effectiveness of advertising campaigns. They remember that you have visited our website and may help us in compiling your profile. These are persistent cookies which will be kept on your device until their expiration or earlier manual deletion.
You block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including strictly necessary cookies) you may not be able to access all or parts of our website. For more information please visit www.allaboutcookies.org and http://www.youronlinechoices.com/uk/.
Our website provides hyperlinks to websites owned and controlled by others. Drake is not responsible for the privacy practices of any website that it does not own or otherwise control.
Where you submit information on behalf of another person, you confirm that you have made that person aware of how we may collect, use and disclose their information, the reason you have provided it, how they can contact us, the terms of this policy and that they have consented to such collection, use and disclosure.
Compliance with Privacy Laws
Drake complies with the data protection and privacy laws to which it is subject. You should satisfy yourself that you are familiar with those laws, including any exceptions which may apply under them. You should also be aware that privacy laws in various jurisdictions may change from time to time.
Except to the extent expressly stated otherwise in this policy, Drake accepts no obligations with respect to the handling of personal information other than those mandated by law in the country which has, or counties which have jurisdiction over Drake in any given circumstances.
Changes to this Policy
As we strive to improve our practices, we may review this policy from time to time. We reserve the right to change this policy at any time and to notify you of those changes by posting an updated version of this policy on our website. It is your responsibility to check our policy each time before you access our website for any changes.
How to Contact Us
We also will, upon request, make available specific information about our privacy policies, practices and procedures. You can raise concerns and initiate the steps to gain access to your personal information by writing to our Privacy Office, at:
Privacy Officer, Drake International, 429 - 433 Pinner Road, North Harrow, HA1 4HN