1. Who are we?
We are CDT Programme Consulting Limited, registered office Batchworth House, Batchworth Place, Church Street, Rickmansworth, WD3 1JE, telephone number +44 (0)1494 814241
We provide management consultancy solutions and interim resources for clients looking to recruit personnel for their businesses.
2. What does this Privacy Policy cover?
We at CDT Programme Consulting Limited take the privacy of your personal data seriously. We understand that the information you trust us with is important to you. We are committed to protecting and respecting your privacy. This policy explains how, when and why we collect your personal information. Specifically, this policy:
sets out the types of personal data that we collect about you;
explains how and why we collect and use your personal data;
explains how long we keep your personal data for;
explains when, why and with whom we will share your personal data;
sets out the legal basis we have for using your personal data;
explains the effect of refusing to provide the personal data requested;
explains the different rights and choices you have when it comes to your personal data;
and
explains how we may contact you and how you can contact us.
3. What personal data do we collect about you?
Our business includes the selection of skilled interims and consultants.
We therefore need to collect the information necessary to identify individuals either as a relevant professional candidate, or as a potential buyer of our services. Following this, for candidates we then need to assess their eligibility for a specific opportunity.
We may also seek to engage with individuals for marketing purposes, for example to draw their attention to material which might be of interest to them, or to invite them to relevant events, or to take part in market research and surveys. At any time that we contact any individual for marketing purposes we will also include a simultaneous opportunity for that individual to opt out of receiving this or any further marketing contact from us.
The information we collect for the above purposes may therefore include your contact details and your current employment information. For candidates, this may also include your CV, your identification documents, your educational and professional qualification records, your work history, and relevant references.
For candidates only we may also collect limited sensitive personal data about you that could be required by a potential client, in the form of diversity data, and criminal record checks. Please note, we will only collect sensitive personal data from you, and make use of this data, for example by passing it on to the potential client, once we have asked for and you have given us your explicit consent for this.
4. Where do we collect your personal data from?
The following are the different sources we may use. From you directly, this is information you provide while searching for a new interim or consulting role.
From an agent/third party acting on your behalf. e.g. an Interim Management Company. Through publicly available sources, for example LinkedIn, or employers’ websites.
By reference or word of mouth, for example, you may be recommended by a friend, a former employer, a former colleague or even a present employer.
5. How long do we keep your personal data?
We follow good practice in aiming to keep personal data that we hold for the shortest relevant period, and also to make efforts to ensure that the personal data we hold is accurate and up to date.
We only retain your information for as long as is necessary for us to use your information as described in this Privacy Policy or to comply with our legal obligations, such as retaining the information for tax and accounting purposes. That means that we may need to retain some of your information after we cease to engage with you.
When determining the relevant retention periods, we will take into account factors including:
(a) our contractual obligations and rights in relation to the information involved;
(b) legal obligation(s) under applicable law to retain data for a certain period of time;
(c) statute of limitations under applicable law(s);
(d) (potential) disputes;
(e) if you have made a request to have your information deleted; and
(f) guidelines issued by relevant data protection authorities.
Otherwise, we securely erase your information once this is no longer needed.
6. Who do we share your personal data with?
We share your personal data with the client in relation to a consultancy assignment.
CDT Programme Consulting Limited work with a common data set, and work to the same data assurance and privacy standards that are outlined in this Privacy Policy, except where local legislation requires these standards to be exceeded.
We may also conduct checks on you to verify the information you have provided, and where we do this we may necessarily share your information with contacts referred to in the information you have provided to us. We do not outsource the verification process to third parties.
7. What legal basis do we have for using your information?
For prospective consultants and interims, for referees and for clients, our legal basis for collecting and using your personal data (this is also referred to as processing your information) is in the first place, our legitimate interest, in that we need the information in order to be able to assess suitability for potential assignments.
For clients, we may also rely on our processing being necessary to perform a contract for you, for example in contacting you.
If you are shortlisted as a potential consultant or interim, then this may involve the processing of more detailed personal data including sensitive data such as ethnicity and criminal record checks that you or others provide about you. In that case, we always ask for your specific consent before undertaking such processing.
For processing your information for marketing purposes, our legal basis is your consent, which you can withdraw at any time, including at the first instance that we contact you for this purpose.
We will only contact you for marketing purposes if we already have a legal basis for doing this.
8. What happens if you do not provide us with the information we request or ask that we stop processing your information?
If you do not provide the personal data necessary, or ask us to stop processing your personal data, we may not then be able to match you with available assignments. or make our services available to you as a client.
9. Do we make automated decisions concerning you?
No, we do not carry out automated profiling.
10. Do we use Cookies to collect personal data on you?
No.
11. Do we transfer your data outside the European Economic Area (EEA)?
To better match your profile with relevant current opportunities we may transfer your personal data to clients and partners in countries outside the EEA. These countries’ privacy laws may be different from those in your home country. Where we transfer data to a country which has not been deemed under the EU General Data Protection Regulation (GDPR) to provide adequate data protection standards we always have security measures and approved model clauses in place to protect your personal data. To find out more about how we safeguard your information when conducting these transfers please contact us at info@cdtpc.co.uk.
12. What rights do you have in relation to the data we hold for 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 rights below are based on current United Kingdom legislation and regulations.
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 Privacy Policy.
The right of access
You have the right to obtain access to your information if we’re processing it, and certain other information (similar to that provided in this Privacy Policy). This is known as a Data Subject Access Request (DSAR)
This right is so that you’re aware and can check that we’re using your information in accordance with data protection
law. To make a DSAR, you will need to send an email to info@cdtpc.co.uk.
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
Under the GDPR, because at CDT Programme Consulting Limited we do not carry out any automated processing, this right to data portability does not apply.
The right to object to processing
You have the right to object to certain types of processing, 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.
13. How will we contact you?
We may contact you by phone, email or social media. If you prefer one particular contact means over another please let us know.
14. How can you contact us?
If you are unhappy with how we’ve handled your information, or have further questions on the processing of your personal data, please contact us at info@cdtpc.co.uk.