Canary Wharf & City LTD, trading as "The Difference Engine" ("We") are committed to protecting and respecting your privacy.
Any mention of "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 together with our terms of use sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us.
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.
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 Canary Wharf & City LTD (trading as "The Difference Engine") of Suite 501, The Nexus Building, Broadway, Letchworth Garden City, Herts, SG6 9BL, United Kingdom.
Who we are and what we do
We are a recruitment agency and recruitment business as defined in the Employment Agencies and Employment Businesses Regulations 2003 (our business). We also provide consultancy services. We collect the personal data of the following types of people to allow us to undertake our business;
- Prospective and placed candidates for permanent or temporary roles;
- Prospective and live client contacts;
- Supplier contacts to support our services;
- Employees, consultants, temporary workers;
We collect information about you to carry out our core business and ancillary activities.
Information you give to us, or we collect about you.
This is information about you that you give us by filling in forms on our site https://thedifferenceengine.tech (our site), or by corresponding with us by phone, e-mail or otherwise. It includes information you provide when you when you fill out the 'Contact Us' form on our site.
The information you give us, or we collect about you may include your name, address, private and corporate e-mail address and phone number.
Information we collect about you when you visit our website.
With regard to each of your visits to our site we will automatically collect the following information:
technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information if applicable, browser type and version, browser plug-in types and versions and operating system and platform;
information about your visit, including the full Uniform Resource Locators (URL), clickstream to, through and from our site (including date and time), pages you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs) and methods used to browse away from the page.
Information we obtain from other sources.
This is information we obtain about you from other sources such as LinkedIn, job board websites, your business card, personal recommendations, and Timesheet Portal (our online timesheet system). In this case we will inform you, by sending you this privacy notice, within a maximum of 30 days of collecting the data of the fact we hold personal data about you, the source the personal data originates from and whether it came from publicly accessible sources, and for what purpose we intend to retain and process your personal data.
We are working closely with third parties including analytics providers, search information providers, credit reference agencies, professional advisors and digital identity verification services. We may receive information about you from them for the purposes of our recruitment services and ancillary support services.
Purposes of the processing and the legal basis for the processing
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 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 services we offer that are similar to those that you have already 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 interests, described in more detail below, although we will also rely on contractual obligations to which you are subject, legal obligations and consent for specific uses of data.
We will rely on contractual obligations 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 obligation in some cases, where we are required by law or regulation to process your data.
We will in some circumstances rely on consent for particular uses of your data. Where we rely on consent, you will be asked for your express consent. An example of when we will rely on consent as the legal basis for processing your data is when we process your data for marketing purposes.
Our Legitimate Interests
Our legitimate interests in collecting and retaining your personal data is described below:
As a recruitment business and recruitment agency we introduce candidates to clients for permanent employment, temporary worker placements or independent professional contracts. The exchange of personal data of our candidates and our client contact details is a fundamental 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. The database will contain historical information as well as current resourcing requirements.
To maintain, expand and develop our business we need to record the personal data of prospective candidates and client contacts. This data may include employment history, educational history, contact data, data about personal circumstances as they relate to career movements and emergency contact data.
We also may contact you regarding ancillary activities outside of direct recruiting. This could include sharing market data or compliance news where it seems relevant to both our work and our client's business development or our candidates' career aspirations.
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.
Other Uses we will make of your data:
We will also use your data:
- 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 when you are using your computer or other devices;
- To notify you about changes to our service;
- 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 services that may interest you or them.
Automated Decision Making
As part of our ongoing commitment to innovation, we may undertake automated decision-making, or utilize Artificial Intelligence (AI) tools, as a part of our larger recruitment processes. A person will always be involved in any decision-making process, and the automated or AI tool will never be the final decision-maker in any process.
We are committed to carrying out any automated decisions (including those made with the use of AI) with full transparency. As such, the full details of how we use automation and/or AI tools are as follows:
If you apply as a candidate to a job vacancy with us, we may input your details into an automated or AI tool, which will measure your details against specific, pre-determined parameters that have been set by a person. Any tool we opt to use will not share your details beyond our organisation, and your details will not be stored by the system or used to train tools external to our organisation.
We take our commitment to Diversity, Equality, and Inclusion (DEI) very seriously and all tools in use have been designed with DEI at the forefront, with every measure possible taken to ensure that we do not unintentionally discriminate against any profile that is measured by an automated or AI tool.
As such, the parameters profiles are automatically measured against will be limited to:
- employment or educational history relevant to the specific vacancy we are reviewing your profile against
- training, skills, and knowledge relevant to the specific vacancy we are reviewing your profile against
A human will review and verify the decisions being taken and our systems will be routinely monitored for any potential discriminatory or dissatisfactory outputs.
We recognise that certain groups of individuals are more likely to be negatively impacted by automation and AI tools. Any automated or AI tools we use will therefore never measure profiles against protected characteristics such as race or gender. We also recognise that some protected characteristics, such as age or disability, may have an impact on employment or education history in ways that leave them open to discrimination via automated or AI tools. We will continually test and monitor these tools to ensure that individuals in these categories are not being negatively impacted by automated decision-making.
Once a profile has been initially reviewed by an automated or AI tool, a person will review the results. Any decisions throughout the remainder of the process will be made by a person unless you are otherwise notified. If we do notify you of further automated decisions, we will include details on how these decisions are carried out and what the impact is to you.
If you have any further questions about how we utilise automated or AI tools in our processes, please get in touch with lauren.fonseca@thedifferenceengine.tech.
Do you have to provide us with personal data?
You may refuse to give us your personal and sensitive personal data. Furthermore, you have the right to ask us to delete, change or stop processing your data that we have already received or collected. If you do not provide us with personal or sensitive personal data, or if you request a restriction of processing however, we may not be able to provide you with the services that you have requested and that are stated in this policy.
Cookies
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. For more information on the cookies we use, please refer to our Cookie Policy.
Disclosure of your information inside and outside of the UK and the EEA
We will share your personal information with:
Any member of our group both in the UK, the EEA and outside of the EEA.
Selected third parties including:
- Clients for the purpose of introducing candidates to them;
- 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
- 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 Canary Wharf & City (recruitment) LTD 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 and conditions of supply of services and other agreements; or to protect the rights, property, or safety of Canary Wharf & City (recruitment) LTD, our clients, 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 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.
Where we store and process your personal data
The data that we collect from you may/will be transferred to, and stored at, a destination outside the UK or European Economic Area ("EEA"). It may be transferred to third parties outside of the UK or the EEA for the purpose of our recruitment services. It may/will also be processed by staff operating outside the UK or the EEA who work for us or for one of our suppliers. This includes staff engaged in, among other things, our recruitment services and the provision of support services. By submitting your personal data, you agree to this processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy notice.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
Retention of your data
We understand our legal duty to retain accurate data and only retain personal data for as long as we need it for our legitimate interests and that you are happy for us to do so. Accordingly, we have a data retention notice and run data routines to remove data that we no longer have a legitimate interest in maintaining.
We do the following to try to ensure that the data we hold on you is accurate:
- prior to making an introduction we check that we have accurate information about you;
- we keep in touch with you so you can let us know of changes to your personal data;
We segregate our data so that we keep different types of data for different time periods. The criteria we use to determine whether we should retain your personal data include:
- the nature of the personal data;
- its perceived accuracy;
- our legal obligations;
- whether an interview or placement has been arranged; and
- our recruitment expertise and knowledge of the industry by country, sector and job role.
We may store and handle your data in the following ways:
- We may archive part or all of your personal data, retain it on our financial systems only or delete all or part of the data from our main Customer Relationship Manager (CRM) system.
- We may pseudonymise parts of your data, particularly following a request for restriction or erasure of your data, to ensure that we do not re-enter your personal data on to our database, unless requested to do so.
For your information, Pseudonymised Data is created by taking identifying fields within a database and replacing them with artificial identifiers, or pseudonyms.
Our current retention notice is available upon request.
Your rights
You have the right to ask us not to process your personal data for marketing purposes. We will usually inform you (before collecting your data) if we intend to use your data for marketing purposes or if we intend to disclose your information to any third party for marketing purposes. We will collect express consent from you, if legally required, prior to using your personal data for marketing purposes.
You can exercise your right to accept or prevent processing for marketing purposes by checking the boxes on the forms we provide you when we collect your data. You can also exercise the right to not have your data used for marketing purposes at any time by contacting us at lauren.fonseca@thedifferenceengine.tech.
Our site may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliate. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
The UK GDPR provides you with the right to:
- Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
- Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
- Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.
- Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
- Request the transfer of your personal information to another party in certain formats, if practicable.
- Make a complaint to a supervisory body which in the United Kingdom is the Information Commissioner's Office. The ICO can be contacted through this link: https://ico.org.uk/concerns/.
Access to information
The Data Protection Act 2018 and the UK GDPR give you the right to access information held about you. We also encourage you to contact us to ensure your data is accurate and complete. Your right of access can be exercised in accordance with the Act and the UK GDPR.
A subject access request should be submitted to lauren.fonseca@thedifferenceengine.tech. No fee will apply unless the requests from a data subject are manifestly unfounded or excessive, in particular because of their repetitive character. In such circumstances, we may charge a fee or refuse to act on the request. In order to process your request compliantly, we may ask you to sufficiently verify your identity before we are able to carry out your request.
Changes to our privacy notice
Any changes we make to our privacy notice in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our privacy notice.
Contact
Questions, comments and requests regarding this privacy notice are welcomed and should be addressed to lauren.fonseca@thedifferenceengine.tech
