Thank you for choosing to be part of our community at DURLSTON PARTNERS. We are committed to protecting your personal information and your right to privacy. If you have any questions or concerns about our policy or our practices with regards to your personal information, please contact us at [email protected].
DURLSTON PARTNERS is made up of different legal entities, currently Durlston Partners London Limited and Durlston Partners USA, LLC. This privacy policy is issued on behalf of the Durlston Partners so when we mention “we”, “us” or “our” in this privacy policy, we are referring to the relevant Durlston Partners’ company responsible for processing your data. DURLSTON PARTNERS LONDON LIMITED is the controller and responsible for this website.
1) Data we collect
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
- Client Data. This is personal data that we hold if you are a client of ours. It may include names and contact details of your relevant employees with whom we are liaising, details about services we provide to you, your hiring requirements and correspondence between us.
- Candidate Data. This is personal data that we hold if you are a candidate. It may include your name, contact details, gender, your current job title, location, your curriculum vitae and information contained therein, details of your key skills and experience, details on recruitment processes that you are involved in, details on your contracts of employment, employment status, compensation information and other information, such as restrictive covenants, visa requirements and benefits, relating to the terms of your employment and details on the type of role you are looking for. We also collect correspondence between you and us, together with correspondence between us and our clients which may refer to you.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.
2) How we collect your data
We collect information when communicating with you in person, on a telephone, text messaging services and via email. We also collect information from documentation that you provide us with, chiefly (if you are a candidate) your curriculum vitae but also contracts of employment. We may also collect information about you from publicly available websites.
We collect information from your CV, on-line profiles and relating to previous recruitment processes you have been involved in to enable us to accurately match relevant opportunities to your profile and then reach out to alert you to these opportunities. We operate a specialised search service and as such we need to be able to proactively approach potential candidates with whom we have had communications in the past to alert them to the existence of a relevant opportunity.
3) How we use your data
If you are a client we will use your data to provide services to you, communicate with you regarding candidates and to manage our relationship with you.
If you are a candidate we use your data:
- to accurately match your profile to relevant opportunities
- to effectively market you as a candidate to the opportunities that you decide to go forwards with
- to contact you about new relevant opportunities and on-going recruitment processes
We will only use your personal data when the law allows us to. To process your personal data, we will most commonly rely on the following legal bases:
- For the performance of a contract, we have with you (such as if you request that we represent you to a client as part of a recruitment process).
- For compliance with a legal obligation to which we are subject (such as tax obligations and when we are obliged to comply with lawful requests from competent authorities such as law enforcement).
- For the purposes of our legitimate interests (such as being able to match you and then contact you with relevant opportunities and for fraud detection), provided that such processing does not outweigh your rights and freedoms.
- Your consent, if you expressly ask us to put you forward to a client for a specific opportunity.
Note that we may process your personal data for more than one legal basis depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific lawful basis we are relying on to process your personal data.
4) How we share your data
We may share your personal information with other companies in the Durlston Partners Group based outside of the UK in order that they can match candidates with suitable opportunities.
If you are a candidate we will share your data with clients in relation to a relevant opportunity, but only where you have given us express permission to do so, and we will not share it beyond these parties. Express permission may come in the form of an email, text message, telephone call or in-person but we will always seek it overtly before sharing your personal information.
We may also share your data with:
- Service providers who provide IT and system administration services to us.
- Professional advisers including lawyers, bankers, auditors and insurers who provide banking, legal, insurance and accounting services.
- HM Revenue & Customs, regulators and other authorities who require reporting of processing activities in certain circumstances.
- Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.
We may, at our discretion, share completely anonymised or aggregated sets of data with third parties without gaining consent of individuals.
If we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- We only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data;
- We use specific contracts approved for use in the UK which give personal data the same protection it has in the UK.
- A specific exception applies under the law which allows us to make the transfer. For example if you give us your explicit consent to transfer your personal information to a particular client or other third party.
5) How long we hold your data
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
We hold personal information on candidates for 15 years. Beyond this we may anonymise the data and continue to hold it for research or statistical purposes.
The reason that we hold data for that long is that the areas we cater to are highly specialised and people generally do not move roles frequently. To continue to be able to match passive candidates with relevant opportunities we have determined that this is an appropriate and proportionate length of time to hold your data.
6) Your choices
You can let us know if you would like us not to market any further opportunities to you. You can also put a temporary or permanent hold on this. To do so please let us know by emailing [email protected]
If you are a resident of the European Union (“EU”) or the United Kingdom (“UK”), you may have certain additional rights, as detailed below.
Your rights
To the extent a specific element of our processing of your personal data relies upon your consent, you may withdraw such consent at any time with future effect. Such a withdrawal will not affect the lawfulness of the processing prior to the consent withdrawal. You may let us know this on the [email protected] part of our website.
If you wish to object to the processing of your personal data on the basis of legitimate interest and no opt-out mechanism is available to you directly, please contact us at [email protected]
Please note If you do not provide us with certain of your personal data, we may not be able to fulfil the requested purpose of collection, such as to respond to your queries. However, unless otherwise specified, not providing your personal data will not result in legal consequences for you.
Additional data privacy rights:
Below please find information on additional rights you may have under applicable law:
- Access: You may request that we confirm whether or not we are processing your personal data. If we are, you may request a copy of your personal data, which we will provide free of charge, together with information about such processing, such as the purposes of the processing and the categories of personal data concerned. However, this is not an absolute right and the interests of other individuals and organisations (such as clients that hold us to non-disclosure agreements) may restrict your right of access. For further copies, we may charge a reasonable fee based on administrative costs. We may decline requests which are excessive, particularly if repetitive. We may ask for legal proof of your identity before providing you with access to any data.
- Rectification: You may also ask us to change, update or fix your personal data in certain cases, particularly if it’s inaccurate. You may also ask us to update your data by providing us with an up to date copy of your CV. In some circumstances we may need to verify the accuracy of the new data you provide to us.
- Erasure: You may request the erasure of your personal data. We may ask for legal proof of your identity to perform this task. Note that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
- Restrict Processing: You may ask us to restrict the processing of your personal data under certain circumstances, such as if your Personal Data is inaccurate or unlawfully held
- Data portability: You may ask for a copy of the personal data you provided to us in a structured, commonly used and machine-readable format and you may have the right to transmit this data to another entity.
- Object: You may object to the processing of your personal data on grounds relating to your particular situation under certain circumstances, for example for direct marketing. If you have a right to object and you exercise this right, your personal data will no longer be processed for such purposes by us, unless there are overriding compelling legitimate grounds for the processing or as otherwise provided under applicable law. You may let us know this by emailing [email protected]
Please note that these rights may be limited under applicable laws. Please note that we may need to retain certain information for record keeping purposes, to complete any transactions that you began prior to your request, or for other purposes as required or permitted by applicable law.
7) Security of your data
We have put in place 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 personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
8) Changes
We keep our privacy policy under regular review. This version was last updated on 4th April 2023. 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 your relationship with us.