Privacy Policy


This privacy policy governs the collection, storage and use of personal information collected by Diana Duggan Associates (UK) Limited, a company incorporated in England and Wales with registered company number 08953455 and registered offices at 5 London Wall Buildings Finsbury Circus,  London, EC2M 5NS, United Kingdom ("Diana Duggan Associates", "we" or "us"):

  • via our website at  https://www.dianaduggan.com/ (the "Site"), or
  • as a result of you responding to an advertisement posted by us on a jobsite; or
  • or as a result of us matching your CV, as uploaded by you onto a jobsite, to a vacancy we are seeking to fill for one of our clients; or
  • through our provision of temporary recruitment and resourcing services to you and our clients ("Services"), as an individual candidate or consultant or as a contact at one of our clients, personal service companies or umbrella companies; or
  • as a result of a personal recommendation; or
  • from a company website; or
  • from your business card; or
  • as a result of our market research; or

where "you" are a candidate, consultant, client contact or contact at any other organisation involved in the introduction and/or supply of a candidate's or consultant's services, such as a contact at a recruitment process outsourcing company, consultancy company, personal service company or umbrella company.
References in this policy to:

  • "hirer" and "client" mean any hiring organisation to which we offer and/or provide recruitment, resourcing and/or consultancy services;
  • "client contact" means a hiring manager or procurer/recipient of consultancy services at a client;
  • "candidate" means a potential or actual candidate for a role with a client;

Specifically, this privacy policy provides you with details about the personal information we collect and hold about you, how we use your personal information, and your rights regarding the personal information we hold about you. 
It does not cover any specific use of your personal information by an actual or potential hirer. Nor does it cover any use of your personal information by an umbrella company or personal services company through which you provide your services.  That use will be governed by the relevant organisation's privacy policy.
Please read this privacy policy carefully – by accessing or browsing the Site or requesting the provision of Services from us, you confirm that you have read and understood this privacy policy in its entirety. 


Overview


We respect your right to privacy. Our overall aim is to ensure that our collection and use of personal information is appropriate to the provision of services to you and our clients, and is in accordance with applicable data protection laws.
Further details of how we do so are set out in each section of our privacy policy as follows:


Who we are and what we do


Diana Duggan Associates (UK) Limited is the data controller of the personal information that we collect from you. It is a company registered in England and Wales (registration number 08953455), whose registered office is 5 London Wall Buildings, Finsbury Circus, London, EC2M 5NS.
You can contact us in relation to this privacy policy by telephone 020 7374 2921 and email at correspondence@dianaduggan.co.uk
We provide recruitment and consultancy services to candidates and consultants to help them find roles within banking and professional services. We do this through assessing and matching people with potential opportunities.
We work with clients to provide recruitment and recruitment process outsourcing services to help them fill requirements for specialist skills and consultancy.


The personal information we collect about "you"


Candidates and placed consultants: Diana Duggan Associates aims to collect the minimum data it needs to perform its role. Typically, this is name, address, job title and contact details. In addition, if you are a candidate being considered for a role it will also include your CV as well as other details about your skills and experience. For more information please see [the next section] [the information in this link]
When:

  • you access and browse the Site (including when you submit personal information to us through data entry fields on the website)
  • we provide Services to you or an actual or a potential hirer of your services;
  • we contact you with a view to providing Services to you; or
  • we download details uploaded by you onto a jobsite in relation to a vacancy we are seeking to fill for one of our clients; or
  • we provide on boarding services to a hirer of your services; or
  • we contact you with a view to providing Services to you; or
  • we provide on-boarding services to a hirer of your services; or
  • you submit your time records

 
will usually collect the following information from or about you:

  • your name;
  • your age and sex;
  • your postal address;
  • your phone and e-mail details;
  • a copy of your passport details including your passport photograph;
  • your place of birth;
  • nationality;
  • driving licence;
  • proof of address;
  • P45/P60;
  • birth certificate;
  • your current and previous employment/work details, including job title and employer;
  • recruitment specific details such as any professional certifications, education and qualifications, skills, career history, salary range, right to work status, citizenship, referee details and any other information relevant to help us provide recruitment services;
  • any other information which you include in your CV or a completed application form;
  • any information which has been published or made available on a social media profile or job board (whether by you or a third party), or in any news media;
  • your umbrella company or personal service company;
  • the contract for services we hold with your umbrella company or personal service company relating to the work you do or will do for our client, including timesheet data and charge rates relating to the work you perform thereunder;
  • references from third parties such previous employers and nominated referees;
  • the results of pre-employment screening or vetting checks which we are asked (by our client) or required (by law) to undertake in relation to you (including the results of any Disclosure and Barring checks and any information you provide relating to current and/or spent criminal convictions carried out on behalf of the hirer during the on boarding process).  Please note that we will seek your specific consent (by way of a separate consent request) to process this information;
  • the results of right to work checks;
  • details of your referees and emergency contacts;
  • any e mail communications, including attachments, which you send to us;
  • your time worked on an assignment;

From time to time we will collect and process medical information relating to your absence from work and your attendance at medical appointment during working hours.  We will request your separate, written consent to us processing any medical information about you we receive. We will share this information with the relevant hirer. You can update your CV or personal data at any time by forwarding a copy to correspondence@dianaduggan.co.uk

  • Referees and emergency contacts: we collect basic contact details (such as name, title, address, email and telephone) so that we can contact you for a reference or as an emergency contact for one of our candidates/consultants.

Client, MSP, Umbrella Company or Personal Service Company contacts:

  • your name;
  • your postal address;
  • your phone and e-mail details;
  • details of your role, title and responsibilities within your company
  • where "you" are a client contact:
    • any opinion or feedback you share with us regarding a candidate or consultant;
    • details of any queries you raise with us regarding the Services;
    • details of any recruitment or resourcing requirements or plans you share with us.

 

How we use your personal information and our lawful bases for processing your personal data


Candidates and placed consultants: we collect, store and use your name, addresses for our legitimate interests:

  • so that we can recommend opportunities and assignments we think will be of interest to you and to help us to provide suitable candidates and consultants for our clients who engage us to assist them fulfil their recruitment and resourcing requirements;
  • so that we can contact you (via email, SMS, telephone, mobile, WhatsApp or Skype) about permanent and/or temporary opportunities and assignments that we believe you will be interested in;
  • to provide a channel through which you can submit your CV for general applications, to apply for specific jobs or to subscribe to our job alerts;
  • to match your details with vacancies, to assist us in finding a position that is most suitable for you and to send your information to clients for potential jobs. Please note that we will always obtain verbal or written consent before presenting your personal details to a client;
  • to enter into and administer contracts which are necessary in order for your services to be supplied or made available to a hirer;
  • to contact your referees and obtain references;
  • to contact your emergency contacts in the event of an emergency;
  • to make payments, in respect of any services you provide via us to our client, to you, your personal service company or umbrella company (as appropriate);
  • to provide recruitment-related support;
  • to carry out market research for our internal use;
  • to develop an industry-relevant database of candidates and clients to help meet our clients' resourcing requirements and connect candidates with work opportunities;
  • for internal record keeping purposes;
  • to carry out compliance checks to ensure that whoever is paying you is complying with tax and national insurance law;
  • to perform credit checks as part of the pre-employment/engagement screening process.
  • to carry out services that we, you or our client have requested including work-related references, qualifications and criminal references checking services, verification of the details you have provided from third party sources, psychometric evaluations or skills tests;
  • to inform you of Diana Duggan (networking and other career-development related ) events.

We do not believe that this storage and use will unduly prejudice your rights or freedoms.
We will store information that we obtain in relation to you so that we are able to contact you about future roles and opportunities. We also store such information to enable us to provide work-related references if asked to do so by future employers or hirers.
We will store and use your personal information to carry out identity verification to comply with The Conduct of Employment Agencies and Employment Businesses Regulations 2003. 
We will also carry out right to work checks to comply with immigration legislation. 
In other, relatively limited circumstances, we will carry out further relevant background checks as requested by our client.  In some cases this will involve using third party checking company such as World-Check, and/or processing medical data you share with the client because it is relevant to your work whilst on assignment. We will collect, store and use your health data with your consent.  You can withdraw your consent at any stage but this may prevent us from being able to deliver our recruitment services to you.
Where you are successful in securing temporary assignment work with one of our clients we will store and use your personal information for the purposes of completing contracts with you, your chosen personal service company or umbrella company (as appropriate) and for processing payment to you or to such company in respect of services you have performed for our client.  Such processing will be for our legitimate interests so that we can provide Services to you and our client and we do not believe that this storage and use of your personal information will unduly prejudice your rights or freedoms.
This processing will also be necessary for the performance of a contract to which you are party (i.e. your contract with us or between us and the umbrella company or your personal service company relating to the supply of assignment services) or in order to take steps prior to you entering into such contract.

  • We will collect, store and use your health data and any Disclosure and Barring Checks with your consent.  You can withdraw your consent at any stage but this may prevent us from being able to deliver our recruitment services to you.
  • Contacts at our clients and other third parties involved in the supply of resourcing services (e.g. umbrella companies and personal service companies): we collect, store and use your name and contact details for our legitimate interests so that we: can send you the details of candidates and consultants and contact you about our Services; and maintain our business relationship with you. 

This allows you to be contacted to receive and administer any Services which you or your organisation has requested. 
In the case of contacts at umbrella companies and personal service companies this allows you to be contacted to receive, on behalf of your employer, details of current and future assignments, related timesheet data and payment details.
We do not believe that this storage and use of your personal information will unduly prejudice your rights or freedoms.


All users of the Site and our Services


We collect, store and use your personal information for the following purposes:

  • to make the Site available to you; and
  • to provide any Services that you request.
  • Sometimes, our use of your personal information is for purposes which are ancillary to the provision of the Site and then Services, or which are desirable in order to make them to operate more effectively.  In those circumstances, we believe we have a legitimate interest in handling your personal information, and do not believe that this storage and use of your personal information will unduly prejudice your rights or freedoms.
  • The relevant circumstances are:
  • detecting and preventing fraud;
  • keeping our websites, apps, products and IT systems secure;
  • ensuring that our own processes, procedures and systems are as efficient as possible;
  • analysing and enhancing the information that we collect;
  • determining the effectiveness of our promotional campaigns and advertising; and
  • where you have given us your consent, contacting you (including by SMS and e-mail) with products and services which we think will interest you.

In some, relatively limited, circumstances we need to handle your personal information in a certain way to be able to comply with our legal obligations – for example: if we are requested to disclose your personal information to regulatory bodies; if we need to demonstrate our compliance with applicable law; for the purposes of compliance with: the Conduct of Employment agencies and Employment Businesses Regulations 2003, any tax and national insurance legislation relating to the payment of personal service company contractors and umbrella workers, and immigration law.


Anonymous data


We collect anonymised details about visitors to our website for the purposes of aggregate statistics or reporting purposes.  However, no single individual will be identifiable from the anonymised details we collect for these purposes.


How we share your personal information and who we share it with


We will disclose information under the following circumstances:

  • Service and Site usage information: When we share anonymous information generated by our Services with our clients.
  • Third-party service providers: When we share information with third-party service companies for them to facilitate or to provide certain services on our [or our clients'] behalf. This will include:
    • IT support service providers;
    • providers of vetting and screening services;
    • payment processors and software providers;
    • third-party service providers who track our customers' use of the Site and the Services for us;

These companies are authorised to use your personal information only as necessary to provide the relevant services to us.

  • Group companies: We provide your personal information to our subsidiaries or affiliated companies for the purpose of processing personal information on our behalf to provide the Site and the Services. These parties are required to process such information based on our instructions and in accordance with this privacy policy. They do not have any independent right to share this information.
  • Compliance with laws and legal proceedings: When we respond to court orders, or legal process, or to establish or exercise our legal rights or defend against legal claims. When we believe it is necessary to share information in order to investigate, prevent or take actions against illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of our terms of use, or as otherwise required by law.
  • Merger or acquisition: When we need to transfer information about you if we are acquired by or merged with another company.  If we are involved in a merger, acquisition, or sale of all or a portion of its assets, you will be notified by email and/or a prominent notice on our Site of any change in ownership or uses of your personal information, as well as any choices you have regarding your personal information.
  • Recruitment and resourcing services: When we are using your personal information in the context of our recruitment and resourcing services, then we will (with your permission) share your personal information with our clients or hirers where we believe that you are appropriate for a particular role or vacancy with that client or hirer. 
  • Umbrella companies and personal service companies:  When you inform us that you are supplying or intend to supply your services via Diana Duggan to a client through an umbrella company or personal service company.
  • Recruitment Process Outsourcing and Managed Service Providers:  In certain cases, there an organisation such as a managed service provider will act as a gateway for the supply of Services made via Diana Duggan to the end hirer. Where this is the case, we will share your information with such organisations to the extent that it is necessary for the purposes of the supply.
  • Where personal information is shared with clients, hirers, umbrella companies, personal services companies or managed service providers in the circumstances described above, then those organisations will handle your personal information in line with their own privacy policies.


International transfers

We may transfer personal information that we collect from you to third parties located in countries that are outside the UK or the European Economic Area in connection with the above purposes. 
Please be aware that countries which are outside the European Economic Area may not offer the same level of legal protection for your personal information as under UK law, although any collection, storage and use of your personal data by us (or on our behalf) will continue to be governed by this privacy policy.
Where we transfer personal information to such third parties, we put in place the following measures to ensure it is afforded appropriate protection e.g. model clauses.


Security


We take appropriate technical and organisational measures to safeguard the personal information that you provide to us, such as physical and IT controls.  Please note that no transmission over the Internet can ever be guaranteed secure.  Consequently, please note that we cannot guarantee the security of any personal information that you transfer over the Internet to us.

Data Retention


We will retain information (including personal information) about Candidates for up to 6 years and will delete it after that time except where we need to keep any personal information to comply with our legal obligations, resolve disputes, or enforce our agreements.


Your rights


You have certain rights in relation to your personal information. If you would like further information in relation to these or would like to exercise any of them, please contact us at correspondence@dianaduggan.co.uk at any time. You have the right to request that we:

  • provide access to any personal information we hold about you;
  • update any of your personal information which is out of date or incorrect;
  • delete any personal information which we are holding about you;
  • restrict the way that we process your personal information;
  • prevent the processing of your personal information for direct-marketing purposes;
  • provide your personal information to a third party provider of services;
  • provide you with a copy of any personal information which we hold about you; or
  • consider any valid objections which you have to our use of your personal information.

We will consider all such requests and provide our response within a reasonable period (and in any event within any time period required by applicable law). Please note, however, that certain personal information may be exempt from such requests in certain circumstances. 

If an exception applies, we will tell you this when responding to your request.  We may request you provide us with information necessary to confirm your identity before responding to any request you make. 


Third party sites


This website contains links to other websites operated by third parties.  Please note that this privacy policy applies only to the personal information that we collect through the Site or the Services, and we cannot be responsible for personal information that third parties may collect, store and use through their website.  You should always read the privacy policy of each website you visit carefully.


Changes to this Privacy Policy


This privacy policy was last updated May 2018. 

Please check back regularly to keep informed of updates to this privacy policy. Where we make significant changes to this privacy policy, and we have your email address, we will send you notification of the changes.


Complaints, questions and suggestions


We have a Data Protection Officer to assist with all queries regarding our processing of personal information; Carly Auletta who can be contacted at Carly.Auletta@dianaduggan.co.uk, telephone 020 7374 2921

If you have any complaints about our Site or services, please contact us at:
Diana Duggan Associates (UK) Ltd
5 London Wall Buildings
Finsbury Circus
London EC2M 5NS

Email: correspondence@dianaduggan.co.uk
Telephone: 020 7374 2921

 

In the EEA, you can also make a complaint to our supervisory body for data protection matters (the Information Commissioner's Office in the UK) or seek a remedy through local courts if you believe your rights have been breached.
May 2018