Who are we?
Discovery provides a range of recruitment and performance services to help businesses build their workforce of the future.
What does this policy cover?
At Discovery, we take your personal data seriously. This policy outlines:
(a) the types of personal data that we collect about you
(b) how and why we collect and use your personal data
(c) how long we keep your personal data for and where do we store it
(d) when, why and with who we will share your personal data;
(e) the legal basis we have for using your personal data;
(f) the effect of refusing to provide the personal data requested;
(g) the different rights and choices you have when it comes to your personal data; and
(h) how we may contact you and how you can contact us.
What personal data do we collect about you?
We collect any information that is required in order to assess your suitability for a role, including your CV (full name, contact details, education/work history, etc.), references and identification documents. The information required may differ depending on the role that you are applying for. If you provide us with any sensitive data, e.g. regarding health, we will only process this with your permission.
If you subscribe to receive our email communications, we will collect your first and last names, organisation, job title, email address, phone number and areas of interest. This information will be used to tailor the email communications you receive and to contact you about product that may be of interest to you.
Where do we collect personal data about you from?
The different sources we may collect data about you includes:
• From you – this could be by becoming a client, a candidate application, during a telephone call, by attending a training course or at any stage during the process.
• From a third party – this could be information provided by employers about training course delegates, information about a key stakeholder in a company provided by their colleague, via CV searching on Job Boards, via a third party commercial email verification service provider, etc.
• Via publicly available sources, such as Job Boards, LinkedIn, company websites, etc.
• By word of mouth, including recommendations from friends, family, (former) colleagues, etc.
How and why we use your personal data?
We could use your personal data for a number of reasons. As a candidate applying for a job, we will use your personal data to assess your suitability for roles, including your education, skills and work history. This information may be gathered via our website, job boards, LinkedIn, etc. We will then store your details for 6 years from the last point of communication, and may contact you about future opportunities that we think you will be interested in. You can opt out at any point by emailing GDPR@thediscoveryway.com. As a delegate on a performance course/programme, we will use your data to contact you with any information that you may require, or to gain information from you that we require.
If you’re a client, we will use your personal data to keep you up-to-date with the progress of your campaign(s) or performance courses, and for us to keep up-to-date with what’s happening in your organisation. We will also send you marketing communications that will include industry insights, advice on best practice, event invitations and more.
If we have received your data from a third party commercial email verification service provider, we will contact you on the basis of ‘Legitimate Interest’. This interest will be classed as a commercial interest, as we are intending to help you build an effective workforce for the future. You may unsubscribe at any time via the link at the bottom of the email or by emailing GDPR@thediscoveryway.com.
How long do we keep your personal data for?
We keep your information in accordance as follows:
- Candidate data: We will process your details on the basis of ‘legitimate interest’, which means that we will store you details for 6 years from the last contact (as outlined in the disclaimer at the bottom of our job adverts) – you can unsubscribe at any point by emailing GDPR@thediscoveryway.com. If we successfully place you, we may retain some basic details past 6 years for our records.
- CV searched candidates: If we have located your details via a third party site, the same information applies.
- Delegate data: Full details will be kept for 6 years from the last contact, but we may retain some basic details past 6 years for our records..
- Client contact details: Full details will be stored for 6 years from the last contact, but some basic details may be kept longer than this for our records. Your details will be processed and stored under ‘Legitimate Interest’ , as we are required to do so in order to complete the work you have hired us to do, therefore it is as part of a contract. In regards to email marketing, we will process your details on the basis of ‘legitimate interest’, however, you will be able to amend your preferences or unsubscribe any time, and a link to do each will be included at the bottom of each marketing email.
You can contact us via GDPR@thediscoveryway.com if you have any queries surrounding this, or would like to unsubscribe from receiving email marketing.
Who do we share your personal data with?
As a candidate, your personal data may be shared with any potential employer.
What legal basis do we have for using your information?
For candidates, delegates, referees and clients, we are required to process data to match candidates with roles and to contact delegates, clients and referees. Your details are processed due to you expressing a legitimate interest.
What happens if you do not provide us with the information we request or ask that we stop processing your information?
If the required data isn’t provided or you withdraw your consent, we may be unable to: fulfil projects for clients, place candidates and provide the same level of service to delegates.
Do we make automated decisions concerning you?
Where do we store your data? Do we transfer your data outside the European Economic Area (EEA)?
Your personal data is stored on our servers, which are located in the EEA.
In some cases, data will be transferred outside of the EEA. For candidates who are suitable for roles outside of the EEA, we may share your information with employers, but this is only likely to happen with your knowledge or consent. Client and candidate details may be transferred outside of the EEA (to America) when using third party email marketing software – security measures are in place regarding this.
What rights do you have in relation to the data we hold on you?
By law, you have a number of rights when it comes to your personal data. Further information and advice about your rights can be obtained from the data protection regulator in your country.
The right to be informed – You have the right to be provided with clear, transparent and easily understandable information about how we use your information and your rights. This is why we’re providing you with the information in this policy.
The right to rectification – You are entitled to have your information corrected if it’s inaccurate or incomplete.
The right to erasure – This is also known as ‘the right to be forgotten’ and, in simple terms, enables you to request the deletion or removal of your information where there’s no compelling reason for us to keep using it. This is not a general right to erasure; there are exceptions.
The right to restrict processing – You have rights to ‘block’ or suppress further use of your information. When processing is restricted, we can still store your information, but may not use it further. We keep lists of people who have asked for further use of their information to be ‘blocked’ to make sure the restriction is respected in future.
The right to data portability – You have rights to obtain and reuse your personal data for your own purposes across different services. For example, if you decide to switch to a new provider, this enables you to move, copy or transfer your information easily between our IT systems and theirs safely and securely, without affecting its usability.
The right to object to processing – You have the right to object to certain types of processing, including processing for direct marketing (i.e. if you no longer want to be contacted with potential opportunities).
The right to lodge a complaint – You have the right to lodge a complaint about the way we handle or process your personal data with your national data protection regulator.
The right to withdraw consent – If you have given your consent to anything we do with your personal data, you have the right to withdraw your consent at any time (although if you do so, it does not mean that anything we have done with your personal data with your consent up to that point is unlawful). This includes your right to withdraw consent to us using your personal data for marketing purposes.
We usually act on requests and provide information free of charge, but we may charge a reasonable fee to cover the administrative costs of providing the information for:
- baseless or excessive/repeated requests, or
- further copies of the same information
Alternatively, we may be entitled to refuse to act on the request.
Please consider your request responsibly before submitting it. We’ll respond as soon as we can. Generally, this will be within one month from when we receive your request, but if the request is going to take longer to deal with, we’ll come back to you and let you know.
How will we contact you?
We may contact you by phone, email or social media.
How can you contact us?
If you are unhappy with how we’ve handled your information, you would like to unsubscribe or have further questions on the processing of your personal data, please contact us via GDPR@thediscoveryway.com.
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