DATA PROTECTION AND PRIVACY POLICY
We at Doxa Partners LLP (the "Company") respect your privacy and are aware that we are expected to handle all personal data responsibly. We have therefore developed this Policy to describe the type of information we gather, how this information is collected, stored, and used, and with whom it is shared and why, in compliance with the Data Protection Act 2018 (“DPA 2018”) and the “UK GDPR” as defined by section 3(10) (as supplemented by section 205(4)) of the DPA 2018 (collectively, “Data Protection Legislation”).This policy notice also explains your rights in relation to your personal data.
This privacy notice is provided in a layered format so you can click through to the specific areas set out below.
1. IMPORTANT INFORMATION AND WHO WE ARE
2. THE DATA WE COLLECT ABOUT YOU
3. HOW IS YOUR PERSONAL DATA COLLECTED?
4. HOW WE USE YOUR PERSONAL DATA
5. HOW WE SHARE YOUR PERSONAL DATA
6. INTERNATIONAL TRANSFERS
7. DATA SECURITY
8. DATA RETENTION
9. YOUR LEGAL RIGHTS
1. IMPORTANT INFORMATION AND WHO WE ARE
Purpose of this Privacy Notice
This notice (the “Privacy Notice”) aims to give you information about how Doxa Partners LLP collects and processes your personal data, whether through our website, through our exchanges with you, or through any services we may provide to you.
It is important that you read this Privacy Notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This Privacy Notice supplements any other notices and is not intended to override them.
Controller
We are Doxa Partners LLP (company number OC389190), registered at 5 Hanover Square, London, United Kingdom, W1S 1HE (referred to as “the Company”, "we", "us" or "our" in this Privacy Notice). For the purposes of Data Protection Legislation, we are a data controller and responsible for your personal data.
We have appointed a data privacy team who is responsible for overseeing question in relations to this Privacy Notice. If you have any questions about this Privacy Notice, including any requests to exercise your legal rights, please contact the data privacy team using the details set out below:
Full name of legal entity: Doxa Partners LLP
Data privacy team/email address: privacy@doxa.partners
Postal address: 5 Hanover Square, London, W1S 1HE
Changes to the Privacy Notice
We reserve the right to amend our Privacy Notice as required to ensure its accuracy and compliance with data protection legislation.
This Privacy Notice was last updated on 17 April 2024.
2. THE DATA WE COLLECT ABOUT YOU
Personal data or personal information means information relating to an identified or identifiable individual. It does not include data where the identity has been removed (anonymous data).
Where necessary we collect and process the following different kinds of personal data:
(a) Identity Data, such as your name (and proof of name), image, nationality, citizenship, marital status, title, date of birth, gender, and employment and education history. Note that our recruitment process allows third party recruitment companies to submit your name and email address to us, and we ask those companies to confirm that they are entitled to do so before submitting such information.
(b) Contact Data, such as your email address and telephone numbers. Note that our recruitment process allows third party recruitment companies to submit your name and email address to us, and we ask those companies to confirm that they are entitled to do so before submitting such information.
(c) Employment Data, details that are relevant to any recruitment process in which you are engaged for a role with us (or any third party role we advertise on our website), which may include your name, contact details, education details, employment history, emergency contacts, immigration status, financial information (where we need to carry out financial background checks) social security number, business contacts, as well as verbal and written references. Where appropriate and in accordance with local laws and requirements, we may also collect information related to your health and any criminal convictions.
(d) Financial Data, such as your bank account details for any payments you make to us or we make to you.
(e) Technical Data, such as your internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
(f) Contractual Data, such as details about your products or services or any services we may provide to you.
(g) Test Data, if you take an online test, the answers you provided to this test
(h) Interview Data, such as notes from interviews with you and any case studies or other written materials submitted or taken during the interview processes.
We may also collect, use and share Aggregated Data such as statistical data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature or the percentage of users coming from a particular advertising source. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Privacy Notice.
We generally do not collect Special Categories of Personal Data about you (such as your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, your health, and genetic and biometric data). Nor do we collect any information relating to criminal convictions and/or offences, or personal data relating to children. However, where you are applying for a position with us, we may collect certain information relevant to your application (for example, where you have a health condition or disability or caring responsibilities which require appropriate adjustments to be made) and/or information relating to any criminal convictions. We will only process this type of data with your consent or where it is necessary for carrying out our obligations under employment laws. Where you provide us with any personal data about a third party, we will treat that personal data in accordance with this policy.
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you. In this case, we may have to cancel a product or service you have with us, but we will notify you if this is the case at the time.
Third Party Links
Our website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
Automated Decision-Making
We do use some automated decision-making in relation to Test Data. Our tests may be marked automatically and emails are sent automatically informing candidates that they have passed/failed based on pre-set margins. You have the right to have this reviewed by a non-automated means (please see “Your Legal Rights” below).
3. HOW IS YOUR PERSONAL DATA COLLECTED?
We use different methods to collect data from and about you during the course of your involvement with us and otherwise in your interaction and correspondence with us and our representatives. These include collecting information through:
(a) Direct interactions. You may give us your Identity, Contact, Employment, Financial, Contractual, Test and Interview Data by corresponding with us by post, phone, email, through our website or otherwise, or by visiting our offices. This includes personal data you provide when you:
(i) apply for a position in our Company or in a third party whose positions we have listed on our website;
(ii) offer your or your company's business services to the Company;
(iii) work for or provide services to one of the Company's clients, business partners, consultants, advisors or other third parties the Company interacts with in a business context;
(iv) attend our offices and are recorded on CCTV; and
(v) otherwise interact with us for your and our business purposes, including marketing to us (whether by email or in person) or meeting us or any of our representatives in a business context.
(b) Automated technologies or interactions. Where you use our website, we may collect Technical Data about your equipment, browsing actions and patterns using cookies, server logs, and other similar technologies. We also use some automated decision-making in relation to Test Data (see above).
(c) Third party provision. A recruiter may submit to us your name and email address to us electronically, for example, through a portal on our website.
(d) CCTV. CCTV has been installed in the offices at 5 Hanover Square.
4. HOW WE USE YOUR PERSONAL DATA
We will only use your personal data when the law allows us to. The information which we collect and the purposes for which we use it will depend on the nature of our relationship with you. Most commonly, we will use your personal data in the following circumstances:
(a) To enter into a contract with you or your employer, to take steps at your or your employer’s request prior to entering into such a contract, or to perform our contractual obligations under a contract with you or your employer;
(b) Where it is necessary for our legitimate interests (or those of a third party) in circumstances where your privacy rights do not override those interests. Legitimate interests means our interest in conducting and managing our business. These legitimate interests may include ensuring the quality of any services we provide, communicating with you, and managing our business;
(c) Where we need to comply with a legal or regulatory obligation;
(d) Where you have given us your consent, and that consent has not been withdrawn; and
(e) To establish, exercise or defend our legal rights for the purposes of legal proceedings.
Purposes For Which We Will Use Your Personal Data
We have set out below, in a table format, a description of ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate. You can obtain further information about how we assess our legitimate interests against any potential impact on your in respect of specific activities by Contacting us.
Note that we may process your personal data on the basis of more than one lawful ground depending on the specific purpose for which we are using your data. Please Contact us if you would like more information relating to our legal grounds for processing personal information.
Purpose / Activity | Type of Data | Lawful basis for processing, including basis of legitimate interest. |
|---|---|---|
To register and process job applications for positions in our Company | (a) Identity, (b) Contact, (c) Employment, (d) Technical, (e) Interview, (f) Test | Necessary for compliance with legal obligations whether to you or third parties; necessary to take steps prior to entering into a contract with you. |
To register and process job applications for positions in any third party company who advertise positions on our website and/or use our online recruitment test, and to provide your data to any third party entity associated with us or our partners who we believe may have a suitable employment opportunity for you (we will not receive any payment for making such recommendation). | (a) Identity, (b) Contact, (c) Employment, (d) Technical, (e) Interview, (f) Test | Necessary for performance of a contract with you or for the third party's prospective contract with you. |
To consider, evaluate and respond to marketing and/or business proposals from third parties. | (a) Identity, (b) Contact, (c) Contractual | Necessary for our legitimate interests (to keep our records updated and to assess services available to us). |
To maintain and develop business relationships with clients, business partners, consultants, advisors or other third parties. | (a) Identity, (b) Contact, (c) Financial, (d) Contractual | Necessary for our legitimate interests (to keep our records updated, to assess services available to us, to maintain and develop our business relationships with current and prospective clients, and to grow our business). |
To maintain and develop business contact with existing, former or potential future clients, partners or third parties. | (a) Identity, (b) Contact, (c) Contractual | Necessary for our legitimate interests (to keep our records updated, to maintain and develop our business relationships, and to grow our business). |
To administer our business and any of our websites. | (a) Identity, (b) Contact, (c) Financial, (d) Contractual, (e) Technical, (f) Test, (g) Employment, (h) Interview | Necessary for our legitimate interests (for running our business, to prevent fraud, for office security). Necessary to comply with legal obligations. |
Change Of Purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please Contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
5. HOW WE SHARE YOUR PERSONAL DATA
We will share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above:
(a) Other companies or entities associated with Doxa Partners LLP or its partners (“Related Entities”). Without limitation, we share our office premises with certain of those companies, who will also have access to CCTV footage, but this access is strictly limited and the footage is only retained for a defined period of time.
(b) Our clients and their respective representatives (“Clients”)
(c) External third parties based in the UK or the European Economic Area (“EEA”) such as:
(i) Service providers acting as processors who provide IT and system administration services to us or any Related Entity;
(ii) Professional advisers including lawyers, bankers, auditors, and insurers who provide consultancy, banking, legal, insurance, and accounting services to us or any Related Entity, and also including recruitment agencies who have submitted your details to us;
(iii) HM Revenue & Customs, regulators and other authorities who require reporting of processing activities in certain circumstances; and
(iv) Other UK / EEA public bodies.
We require all such external third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions; and
(d) Specific third parties such as third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this Privacy Notice.
6. INTERNATIONAL TRANSFERS
We may share your personal data with our Related Entities and Clients. This may involve transferring your data outside of the UK / EEA.
Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by:
(a) only transferring your personal data to countries that have been deemed to provide an adequate level of protection for personal data; or
(b) using specific contracts approved for use in the UK which give personal data the same protection it has in the UK.
Please Contact us if you have any questions regarding such transfers.
7. DATA SECURITY
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
8. DATA RETENTION
How long will you use my personal data for?
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
For further information regarding how long we retain your personal data, please Contact us.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
9. YOUR LEGAL RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your personal data, such as the right to:
(a) Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
(b) Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
(c) Request erasure of your personal data. This enables you to ask us to delete or remove personal data 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 data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
(d) Object to processing of your personal data 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 as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
(e) Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it (i.e. whilst we determine to what extent the right to object applies).
(f) Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
(g) Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
If you wish to exercise any of the rights set out above, please Contact us.
We try to respond to all legitimate requests within one month of receipt of the request. Occasionally it may take us longer if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated on our progress.
Fees
There is normally no charge for exercising any of your rights, though in some circumstances we may charge a reasonable fee to cover our administrative costs (for example where repeated data subject access requests are made or if your request is unfounded or excessive). Alternatively, we may refuse to comply with your request in circumstances where such requests are repetitive, unfounded or excessive.
Your right to complain
You also have the right to file a complaint with the Information Commissioner’s Office (“the ICO”). We encourage you to Contact us first as we may be able to address your concerns directly. The UK’s ICO can be contacted at https://ico.org.uk/global/contact-us/.
Your duty to inform us of changes
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.