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Privacy Policy

THOMAS & DESSAIN CANDIDATE PRIVACY POLICY

Addition of Candidate Diversity Monitoring as of July 2020 (Point 6).

Changes to Retention of Information as of July 2020 and March 2021 (Point 8).

 

We are committed under the terms of the Data Protection (Jersey) Law 2018 and the Data Protection Authority (Jersey) Law 2018 to preserving your privacy, and we have created this Privacy Policy as part of our Terms of Business to explain what information we collect from you, how your information is collected, how we will process it, and how we may share it with relevant third parties.

 

  1. Definitions

“We” or “the company” refers to Thomas & Dessain Ltd or Thomas & Dessain UK Ltd Executive Recruitment Search & Selection company, together with the company employees, directors, officers, affiliates, and subsidiaries.

“You” refers to you as the candidate registered with us in order to use our services.

“Information” refers to all the different forms of personal data with which you provide us and which we collect from you in the course of our duties in order to render you service.

 

  1. Information We Collect

Information you provide to us: when you register with and use our services, you provide us with information, which we collect. 

Curriculum Vitae 

Registration Form:

Section 1

  1. Personal Data – your first and family names, date of birth, address, contact details, information on your current employment and benefits, email address, phone number(s), Social Security and Tax numbers, passport number and expiry date, date of arrival in Jersey, employment and housing status, nationality, emergency contact and source of enquiry

Section 1A

  1. Health Checks – number of days’ sickness within last 12 months; ongoing medical conditions.
  2. Pre-booked holidays
  3. Unspent criminal convictions, bankruptcy, fraud/financial misconduct or petty debts/county court judgements or liabilities.
  4. Termination of employment – any previous disciplinary action
  5. Educational & Professional Qualifications – details of qualifications gained and whether these are still ongoing; membership of professional bodies
  6. Employer References – two, one of which should be most recent employer (may not be taken up immediately)

KYC Documents

  1. Passport as proof of identity.
  2. Two documents dated within the previous three months as proof of current address – these can be utility bills, bank statements, letter from the tax office, rates notice or lease documents; educational/professional qualification certificates.
  3. Social Security Registration Card, with Social Security number and Residential Status; in the case of non-EEC candidates, letter from the Immigration Department and any other relevant document to confirm eligibility to work in Jersey.
  4. Qualification certificates (if applicable).

Meeting Notes (first meeting and any subsequent meetings and telephone calls).

Additional for Temporary Candidates

At the request of employers

  1. check of the JFSC register of restricted persons (public website)
  2. criminal record check (via Disclosure Scotland)
  3. c) Credit Check (via Cashback, Jersey)
  4. d) Sanctions Check (via www.knowyourcandidate.co.uk)

 

Prior to first assignment

 

  1. e) Statement of Work

 

  1. Assignment Letter(s)

 

 

  1. How We Use Your Information

With your consent, we will use your information:

  1. To create your profile and enter your data on our secure database and hardware drive.
  2. To transfer your information to prospective employers in the event of a prospective job.
  3. To contact you about prospective jobs.

 

  1. How We Share and Disclose Your Personal Information
  2. a) With prospective employers after obtaining your consent.
  3. b) In the event of merger with, or acquisition by, another business.
  4. c) If and when we are required by law or a legal process to disclose that information, such as a     valid court order or a valid subpoena.
  5. d) If and when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond, or respond to a valid government request.
  6. e) To enforce our terms and conditions or to protect our operations or users.

 

  1. Security

We, and our service providers, take stringent precautions – including administrative, technical and physical measures – to safeguard your personal information against loss, theft and misuse, as well as against unauthorised access, disclosure, alteration, and destruction.

We follow generally accepted industry standards to protect your information, during transmission, once we receive it and in storing it. 

When your personal information is entered into our secure database and hardware drive, all user identity is multi factor authenticated and data is backed up securely.

 

  1. Candidate Diversity Monitoring

On occasions, clients may require Thomas & Dessain to perform candidate diversity monitoring in respect of recruitment to certain roles.  This is more likely to be the case, and has been the case up until now, for NED roles which fall under the remit of the Jersey Appointments Commission (although it is possible that this may apply to general candidate recruitment in the future).  This may require the collection by Thomas & Dessain of special category data about you.  Collection of such data for the purposes of diversity monitoring will take place anonymously and such information will be kept separate from any other recruitment information or documentation held. 

Such information is collected through a standardised diversity monitoring form circulated with the application pack and will not be used to make decisions about suitability for a role. The diversity monitoring form is optional and you can, if you prefer, opt out of returning it.  However, we would encourage all those applying for roles where diversity monitoring has been specified to return the information in the best interests of ensuring diversity and fairness in our workforces.

The information collected anonymously will, as soon as reasonably practicable at the end of the recruitment process for the particular role, be turned into statistical data maintained by Thomas & Dessain and the underlying information destroyed. The statistical data recorded will be made available to the underlying client company, if requested. 

Diversity monitoring forms are to be marked for the attention of Thomas & Dessain’s Data Protection Officer, Caroline Renouf, as opposed to the Recruitment Consultant overseeing the recruitment exercise. 

 

  1. Correcting, Accessing, Updating and Deleting Information

If you wish to access the information which you have provided or obtain confirmation on the information being held which you have provided, you may contact us by email or telephone or letter in order to request us to do this.  We will respond to your request within one month. We will only decline to process unreasonable requests or requests which are not otherwise required under the terms of the Data Protection (Jersey) Law 2018.

 

If you wish us to delete the information which you have provided, you may contact us by email or telephone or letter in order to request us to do this.  We will respond to your request within 7 days.

If you wish to modify the information which you have provided, you may contact us by email or telephone or letter in order to request us to do this.  We will respond to your request within 7 days.

 

  1. Retention of Information

We retain your personal information after obtaining your consent for the following time periods:

  1. Curriculum Vitae:

FIVE YEARS (except NED REGISTRATION – THREE YEARS and NED PLACEMENT – SIX YEARS)

 

  1. Registration Form:

FIVE YEARS (except NED REGISTRATION – THREE YEARS and NED PLACEMENT – SIX YEARS)

 

  1. KYC Documents:

ONE YEAR TEMPORARY CANDIDATES (or longer if still working)

PERMANENT CANDIDATES – seen and noted but not retained

NED – N/A

 

  1. Meeting Notes (and all subsequent Meeting and Telephone Notes):

FIVE YEARS (except NED REGISTRATION – THREE YEARS and NED PLACEMENT – SIX YEARS)

 

  1. Temporary Candidates:
  • JFSC Check of Restricted Persons – no consent needed as information on public website
  • Criminal Record Check – ONE YEAR (or longer if still working)
  • Credit Check – ONE YEAR (or longer if still working)
  • Sanctions Check – ONE YEAR (or longer if still working)
  • Statement of Work – ONE YEAR (or longer if still working)
  • Assignment Letter(s) – ONE YEAR (or longer if still working)
  1. Diversity Monitoring Form

NED REGISTRATION – THREE YEARS; NED PLACEMENT – SIX YEARS

 

The date the retention period commences for all information is the date of Registration.  The date the retention period finishes is calculated from the date of Registration.

 

 

  1. Temporary Employee Payroll Records

 

If you are a temporary employee engaged and paid by the company, records will be kept to prove you have been paid the minimum wage (where eligible) for 10 years in line with statutory requirements.

 

  1. Legitimate Interest

When finding or searching for a new candidate, either independently  or on behalf of a client, through a publicly-available channel such as website, social media network or job board,  this sourcing is deemed to constitute legitimate interest on behalf of the recruiter/client as a reasonable expectation of contact would exist.   In such cases, the only data which would be processed prior to contact with the candidate is the profile, and no data is stored before contact has been made.  If the candidate does not respond to the initial contact or specifically asks not to be contacted, the profile is deleted.

 

  1. Cookies/Google Analytics

Our website uses Google Analytics, an internet analysis service of Google Inc. (“Google”) which applies “cookies”, that is to say text files stored on your computer and used to analyse your usage behaviour on the corresponding website.  The usage information (including your IP address) stored in the cookie will be sent and transmitted to a Google server in the United States of America.  Google will use this information to analyse your behaviour and create a report of your web activity for the website provider.  With this report the website provider can offer other services which seem to be interesting for the user.  Google may share such information with third parties, as far as this is statutory required or in order to process the information by affiliated companies on behalf of Google.  By no means will Google link your IP address with other data of Google Inc.  It is up to you to avoid the installation of cookies through your browser settings.  In that case we must point out that you may not be able to properly use the provided features and services of the website.  By using services of this website you agree with the aforementioned way and purpose of processing your collected personal data.

 

  1. Changes to the Privacy Policy

This privacy policy may be changed by Thomas & Dessain at any time.  If we change this privacy policy in the future, we will set out these changes clearly so that you will always know what personal information we gather, the purposes for which it may be used and shared, and to whom we may disclose it.

 

  1. Your Rights

You may update your information with us, request copies of it or ask that it be deleted.  To do so please contact the Data Protection Officer, Caroline Renouf, at caroline.renouf@thomasdessain.com.

Should you wish to make a complaint, object to the processing of your information or any aspect of this policy, please contact the Data Protection Officer, Caroline Renouf, at caroline.renouf@thomasdessain.com