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, March 2021 and October 2023 (Point 8).

Changes to Information We Collect as of January 2023 and October 2023 (Point 2).

Changes to Cookies/Google Analytics as of January 2023 (Point 11).

Addition to Your Rights as of October 2023 (Point 13).

 

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.

 

2. Information We Collect

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

 

Search & Selection, General Recruitment and NED

Curriculum Vitae and Profile.  

Email exchanges.

Notes of meetings and telephone calls.

 

General Recruitment and NED

Registration Form:

Section 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), employment and housing status, nationality, emergency contact and source of enquiry.

Section 1A

-Health Checks – number of days’ sickness within last 12 months; ongoing medical conditions.

-Pre-booked holidays.

-Unspent criminal convictions, bankruptcy, fraud/financial misconduct or petty debts/county court judgements or liabilities.

-Termination of employment – any previous disciplinary action. 

-Educational & Professional Qualifications – details of qualifications gained and whether these are still ongoing; membership of professional bodies.

Declaration:

-You understand that the information on the form will be saved by us and may be shared with prospective employers in the event of suitable vacancies being identified.

-You give consent to your personal data being retained for a specific time period by us.

-You note that you can at any time during this time period ask us to delete/modify your data or share it with you.

 

Search & Selection

Data Retention or Deletion:

-You understand that the information on the form will be saved by us and may be shared with prospective employers in the event of suitable vacancies being identified.

-You are informed as to which personal data will be retained for a specific time period by us.

-You note that you can at any time during this time period ask us to delete/modify your data or share it with you.

-You choose via the appropriate hyperlink as to whether you give consent for data retention or wish for the data to be deleted.

General Recruitment 

KYC Documents: 

a) Passport as proof of identity.

b) Two documents less than three months old as proof of current address: utility bills, bank statements, letter from tax office, rates notice, lease documents; educational/professional qualification certificates.

c) Social Security Registration Card; for non-EEC candidates, letter from the Immigration Department and any other relevant document to confirm eligibility to work in Jersey.

d) Qualification certificates.

 

Search & Selection

KYC Documents: as above but only provided if demanded by clients.

 

General Recruitment

Temporary Candidates - at the request of employers:

a) check of the JFSC register of restricted persons (public website)

b) criminal record check (via Disclosure Scotland)

c) Credit Check (via Cashback, Jersey)

d) Sanctions Check (via www.knowyourcandidate.co.uk)   

Temporary Candidates - prior to first assignment: 

a) Statement of Work

b) Assignment Letter(s)

3. 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.

 

4. How We Share and Disclose Your Personal Information

a)   With prospective employers after obtaining your consent.

b) In the event of merger with, or acquisition by, another business.

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. 

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.

e) To enforce our terms and conditions or to protect our operations or users.

 

5. 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, technical protective measures are in place, and data is backed up securely.

 

6.   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.  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.  

 

7. 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.

 

8. Retention of Information 

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

a) Curriculum Vitae:

ALL: FIVE YEARS 

 

b) Registration:

(i) Registration Form:

GENERAL RECRUITMENT AND NED: FIVE YEARS 

(ii)  Data Retention or Deletion:

       SEARCH & SELECTION: FIVE YEARS

 

c) KYC Documents:

GENERAL RECRUITMENT TEMPORARY CANDIDATES: ONE YEAR (or longer if still working)

SEARCH & SELECTION AND NED TEMPORARY CANDIDATES: N/A

SEARCH & SELECTION AND GENERAL RECRUITMENT PERMANENT CANDIDATES – seen and noted but not retained

NED PERMANENT CANDIDATES – N/A

 

d) Notes of Meetings and Telephone Calls:

ALL: FIVE YEARS 

 

e) Email Exchanges

ALL: FIVE YEARS

 

f) Temporary Candidates:

GENERAL RECRUITMENT: 

• 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)

SEARCH & SELECTION AND NED: N/A

 

g) Diversity Monitoring Form

SEARCH & SELECTION AND GENERAL RECRUITMENT – N/A

NED – FIVE 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.

9. Temporary Employee Payroll Records

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

 

10. 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.

 

11. Cookies/Google Analytics

Our website uses Google Analytics via Google Tag Manager, an internet analysis service of Google Inc. (“Google”) which applies “cookies” - text files stored on your computer and used to analyse your usage behaviour on the corresponding website.  The usage information (excluding your IP address) stored in the cookie will be sent and transmitted to a Google server in the USA.  Google will use this information to analyse your behaviour and create a report of your web activity for the website provider who can then offer other services which seem to be interesting for the user.  Google may share such information with third parties, if statutorily required, or to process the information by affiliated companies on behalf of Google.   It is up to you to avoid 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 the services of this website you agree with the way and purpose of processing your collected personal data.

 

12. 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.

13. 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.

A copy of our Complaints Policy and Procedure is available on the Thomas & Dessain website.