Our Privacy Notice
This section explains who our company is, the regulations that cover how we look after your data and who our data controller is… Denholm Associates are committed to protecting and respecting your privacy.
Our Group means our subsidiaries, our ultimate holding company and its subsidiaries, our associated companies as defined in section 1159 of the UK Companies Act 2006 (our Group)
This notice sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us.
Website terms of use…
Visitors to our website are required to accept the following terms and conditions in return for the information given to them on this website. We use our reasonable efforts to include accurate and up to date information on all pages of our website.
Information is for guidance only and is not intended to form any part of a contract and can be subject to change without notice. We shall not be liable for any direct, indirect, incidental, consequential or cumulative losses or damages arising out of the use or inability to use these pages, any errors, misrepresentations or omissions on the material contained on them. The information on the pages of this website has been prepared with reasonable care and is believed by us to be legal, honest, decent and truthful as of the date of its preparation. You agree that the material downloaded or otherwise accessed through the use of the web pages on our website is obtained entirely at your own risk and that you will be entirely responsible for any resulting damage to software or computer systems and/or any resulting loss of data even if we have been advised of the possibility of any such damage. We do not accept any liability in connection with any third party websites which may be linked or accessible through our own website and we do not endorse or approve the contents of any such site. In relation to a dispute arising out of this website, you the user and Denholm Associates agree to submit exclusively to the jurisdiction of the courts of England and Wales. Except where expressly stated to the contrary the text and graphics in the information contained in this website is the copyright of Denholm Associates. You may download or print out individual selections of the web pages on our website only if explicitly used for your own personal information and not to be publicly reproduced. Permanent copying or storage of whole or part of this website or the information contained in it or reproduction or incorporation of any part of it in any other work or publication whether on paper or electronic media or any other form is expressly prohibited. The entire contents of this website remains our property and is copyright with all rights reserved.
The UK General Data Protection Regulation (UK GDPR) (Regulation (EU) 2016/679) is a regulation which replaces the Data Protection Regulation (Directive 95/46/EC). The Regulation aims to harmonise data protection legislation across EU member states, enhancing privacy rights for individuals and providing a strict framework within which commercial organisations can legally operate.
The Brexit transition period ended on 31 December 2020 and the UK has now officially left the EU. The UK GDPR has been directly incorporated into UK law sitting alongside the Data Protection Act 2018.
The Government intends for the GDPR to continue in UK law post-Brexit and has also introduced a Data Protection Bill to replace the current Data Protection Act in due course.
Your new rights under the GDPR are set out in this notice but will only apply once the GDPR becomes law on 25th May 2018. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. For the purposes of data protection legislation in force from time to time, the data controller is Denholm Associates, 8/4 Maritime House, The Shore, Edinburgh, EH6 6QN.
Our nominated representatives are Marisa Carroll, COO and Keren Van Den Broek Finance Director.
How we use your info
This is how we use the information to help you find a job and our legal obligations to store that information. This bit also covers our legitimate business interests (to help provide a better service) and how we’ll ask for your permission and your right to change your mind.
It’s important to us that we’re able to provide a highly personalised service to both our candidates and clients.
As such, we use information held about you in the following ways:
To carry out our obligations arising from any contracts we intend to enter into or have entered into between you and us and to provide you with the information, products and services that you request from us or we think will be of interest to you because it is relevant to your career or to your organisation.
To provide you with information about other goods and services we offer that are similar to those that you have already purchased, been provided with or enquired about.
The core service we offer to our candidates and clients is the introduction of candidates to our clients for the purpose of temporary or permanent engagement. However, our service expands to supporting individuals throughout their career and to supporting businesses’ resourcing needs and strategies.
Our legal basis for the processing of personal data is our legitimate business interests, described in more detail below, although we have segmented our activities and will also rely on contract, legal obligation and consent for specific uses of data.
Specifically, we will rely on:
We will rely on contract if we are negotiating or have entered into a placement agreement with you or your organisation or any other contract to provide services to you or receive services from you or your organisation
We will rely on legal if we are legally required to hold information on you to fulfil our legal obligations. An example would be asking for a copy of your passport, or relevant documentation in order to prove your right to work in the United Kingdom. We may work in partnership with Amiqus ID and/or TrustID to process and handle such personal data.
We will in rely on consent for particular uses of your data including marketing through an email list or seeking permission before we introduce you to a client. We will also request ‘just in time’ consent before your details are submitted for a vacancy
a) Our Legitimate Business Interests
Our legitimate interests in collecting and retaining your personal data is described below:
As a business specialising in Recruitment, Executive Search & Employer Branding, we introduce candidates to clients for permanent employment, temporary worker placements or independent professional contracts, as well as providing vital insight to companies on their employer brand. The exchange of personal data of our candidates and our client contacts is a fundamental, essential part of this process.
In order to support our candidates’ career aspirations and our clients’ resourcing needs we require a database of candidate and client personal data containing historical information as well as current resourcing requirements. This is essential in allowing us to talent map for assignments we work on, particularly for senior roles or where there are skill shortages. Many of our candidates and contacts are people we have worked with over many, many years often placing candidates several times throughout their career. Such historic data is essential in helping nurture our relationships and to ensure we are best placed to support all our customers.
Holding historic data is also essential for the purposes of developing and growing our business. Such information is utilised when it comes to Denholm providing intelligence for new business tenders.
Our newly launched employer brand service also replies on drawing insight from our CRM utilising historic data developed over the years.
b) Consent
Should we want or need to rely on consent to lawfully process your data we will request your consent orally, by email or by an online process for the specific activity we require consent for and record your response on our system. Where consent is the lawful basis for our processing you have the right to withdraw your consent to this particular processing at any time. We would seek consent for marketing purposes and ‘just in time’ consent before your details are submitted for a vacancy.
Use of data & Cookie Policy
How we use your data to improve your experience of our website…
Use of our website;
- to notify you about changes to our service;
- to ensure that content from our site is presented in the most effective manner for you and for your computer
We will use this information:
- to administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
- to improve our site to ensure that content is presented in the most effective manner for you and for your computer;
- to allow you to participate in interactive features of our service when you choose to do so;
- as part of our efforts to keep our site safe and secure;
- to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you;
- to make suggestions and recommendations to you and other users of our site about goods or services that may interest you or them
We do not undertake automated decision making or profiling. We do use our computer systems to search and identify personal data in accordance with parameters set by a person. A person will always be involved in the decision-making process.
How these work and how they help us make the website helpful to you…Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site.
But cookies are not strictly necessary for using our services, so we’ll ask you to consent to our use of cookies when you first visit our website.
About cookies
A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server. Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed. Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.
Cookies that we use
Authentication – we use cookies to identify you when you visit our website and as you navigate our website
Status – we use cookies to help us to determine if you are logged into our website
Personalisation – we use cookies to store information about your preferences and to personalise our website for you
Analysis – we use cookies to help us to analyse the use and performance of our website and service
Cookies used by our service providers
Our service providers use cookies and those cookies may be stored on your computer when you visit our website, they gather non-personally identifiable information such as your browser version, your operating system version, your IP address, cookie information, time stamps (time page accessed as well as time spent per web page), and clickstream information (for example, which pages you viewed and for how long).
We use Google Analytics to analyse the use of our website. Google Analytics gathers information about website use by means of cookies. The information gathered relating to our website is used to create reports about the use of our website. Google’s privacy policy is available at: https://www.google.com/policies/privacy/
Managing cookies
Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these URLs:
https://support.google.com/chrome/answer/95647?hl=en (Chrome);
https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences (Firefox);
http://www.opera.com/help/tutorials/security/cookies/ (Opera);
https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);
https://support.apple.com/kb/PH21411 (Safari); and
https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy (Edge)
Our partners at Force24 Cookies & Tracking
Our organisation utilises Force24’s marketing automation platform.
Force24 cookies are first party cookies and are enabled at the point of cookie acceptance on this website. The cookies are named below:
They allow us to understand our audience engagement thus allowing better optimisation of marketing activity.
f24_autoId – This is a temporary identifier on a local machine or phone browser that helps us track anonymous information to be later married up with f24_personid. If this is left anonymous it will be deleted after 6 months . Non-essential, first party, 10 years, persistent.
f24_personId – This is an ID generated per individual contact in the Force24 system to be able to track behaviour and form submissions into the Force24 system from outside sources per user. This is used for personalisation and ability to segment decisions for further communications. Non-essential, first party, 10 years, persistent.
The information stored by Force24 cookies remains anonymous until:
- Our website is visited via clicking from an email or SMS message, sent via the Force24 platform and cookies are accepted on the website.
- A user of the website completes a form containing email address from either our website or our Force24 landing pages.
The Force24 cookies will remain on a device for 10 years unless they are deleted.
Other Tracking
We also use similar technologies including tracking pixels and link tracking to monitor your viewing activities
Device & browser type and open statistics
All emails have a tracking pixel ( a tiny invisible image ) with a query string in the URL. Within the URL we have user details to identify who opened an email for statistical purposes.
Link Tracking
All links within emails and SMS messages sent from the Force24 platform contain a unique tracking reference, this reference help us identify who clicked an email for statistical purposes.
Our details
This website is owned and operated by Denholm Associates. We are registered in Scotland under registration number SC 205833, and our registered office is at 8/4 Maritime House, The Shore, Edinburgh, EH6 6QN.
You can contact us on dataprotection@denholmassociates.com.
(This document was created using a template from SEQ Legal (https://seqlegal.com)
Outside the EEA
We sometimes have to share your information with third-party companies. And sometimes these companies are based outside the European Economic Area (EEA). This lets you know when and how we’ll do that… We will share your personal information with:
Any member of our group both in the EEA and outside of the EEA.
Selected third parties including:
- our clients for the purpose of introducing candidates to them;
- our candidates for the purpose of arranging interviews and engagements;
- clients, business partners, suppliers and sub-contractors for the performance and compliance obligations of any contract we enter into with them or you;
- subcontractors including email marketing specialists, event organisers, payment and other financial service providers
- advertisers and advertising networks that require the data to select and serve relevant adverts to you and others. We do not disclose information about identifiable individuals to our advertisers, but we will provide them with aggregate information about our users (for example, we may inform them that 500 men aged under 30 have clicked on their advertisement on any given day). We may also use such aggregate information to help advertisers reach the kind of audience they want to target (for example, women in SW1). We may make use of the personal data we have collected from you to enable us to comply with our advertisers’ wishes by displaying their advertisement to that target audience
- analytics and search engine providers that assist us in the improvement and optimisation of our site;
- credit reference agencies, our insurance broker, compliance partners and other sub-contractors for the purpose of assessing your suitability for a role where this is a condition of us entering into a contract with you.
We will disclose your personal information to third parties:
- In the event that we sell or buy any business or assets, in which case we will disclose your personal data to the prospective seller or buyer of such business or assets.
- If Denholm Associates or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
- If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms of use (found in 1. Our Privacy Policy) and other agreements; or to protect the rights, property, or safety of Denholm Associates, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
The lawful basis for the third party processing will include:
- Their own legitimate business interests in processing your personal data, in most cases to fulfil their internal resourcing needs;
- satisfaction of their contractual obligations to us as our data processor;
- for the purpose of a contract in place or in contemplation;
- to fulfil their legal obligations
Modern Slavery Statement
Modern Slavery Statement
This statement sets out Denholm Associates actions to understand all potential modern slavery risks related to its business and to put in place steps that are aimed at ensuring that there is no slavery or human trafficking in its own business and its supply chains. This statement relates to actions and activities during the financial year 1 January 2023 to 31 December 2023.
As part of the recruitment industry, the Company recognises that it has a responsibility to take a robust approach to slavery and human trafficking.
The Company is absolutely committed to preventing slavery and human trafficking in its corporate activities, and to ensuring that its supply chains are free from slavery and human trafficking.
Our business
Denholm Associates Ltd is an independent, privately-owned recruitment company. We are a search, recruitment and employer brand consultancy that specialises in commercial marketing, sales & digital opportunities.
Our suppliers
Due to the nature of our work, Denholm Associates engage with a very limited number of suppliers and conduct due diligence on all suppliers before engaging in business. This due diligence includes an online search to ensure that the particular organisation has never been convicted of offenses relating to modern slavery. We also require confirmation that suppliers:
1. Have taken steps to eradicate modern slavery within their business
2. Hold their own suppliers to account over modern slavery
3. Pay their employees at last the national minimum wage (for UK based suppliers)
4. Pay their employees any prevailing minimum wage applicable within their county of operations (for international suppliers)
We may terminate a contract at any time should any instances of modern slavery come to light.
Training
As part of our commitment to ensuring awareness of modern slavery and eliminating practices which may constitute modern slavery, training forms part of our induction process and is reinforced at regular intervals throughout the year.
Compliance
The prevention, detection and reporting of modern slavery in any part of our business or supply chain is the responsibility of all those working for us or under our control. Employees must ensure that they have read, understand and comply with this statement and avoid any activity that might lead to, or suggest. A breach of this statement.
Employees are encouraged to raise concerns about any issues or suspicion of modern slavery in any parts of our business or supply chains of any supplier tier at the earliest possible stage.
If you believe of suspect a breach of this statement has occurred or that it may occur, employees must notify their line manager or a member of the Board as soon as possible.
Any reports from employees, the public. Or law enforcement agencies to indicate modern slavery practices have been identified will be properly investigated to a satisfactory conclusion.
Board approval
This statement has been approved by the Company’s board of directors, who will review and update it annually.
