Effective Date: 1st May 2018
1. Who are we?
1.1 DigitalGrads is a trading name of LHS Digital Ltd with its company number 08829606, registered address at 20-22 Wenlock Road, London, England, N1 7GU and business address at DigitalGrads, 45 Church Road, Hove, BN3 4JG. We own and operate this website https://www.digitalgrads.com. Our contact details are shown in the footer of our website and in section 12 of this policy. Please contact us if you have any questions or feedback about this policy.
2. What’s the point of this policy?
2.1 This policy applies to information we collect when you choose to use this website, and also to personal data which we process further to supplying services to our clients and candidates.
2.2 This policy tells you how we deal with your “personal data” (a technical term for information about any identified or identifiable living person). Please read on to find out what kinds of personal data we collect, how we use and protect it, to whom we disclose it and how you can access and rectify it.
2.3 Please do not use our website unless you are completely happy with this policy. If you do use our website, Hiring Hub and Academy, we will assume that you do accept it.
3. Might the policy change?
3.1 It may well do and so you should check it whenever you visit our website. We will assume you agree to the revised policy if you use the website after the effective date shown at the top of the policy.
4. What personal or other data do we collect?
4.1 Under the General Data Protection Regulation 2016 (GDPR) we will ensure that your personal data is processed lawfully, fairly, and transparently, without adversely affecting your rights. We will only process your personal data if at least one of the following basis applies:
- a) you have given consent to the processing of your personal data for one or more specific purposes;
- b) processing is necessary for the performance of a contract to which you are a party or in order to take steps at the request of you prior to entering into a contract;
- c) processing is necessary for compliance with a legal obligation to which we are subject;
- d) processing is necessary to protect the vital interests of you or of another natural person;
- e) processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller; and/or
- f) processing is necessary for the purposes of the legitimate interests pursued by us or by a third party such as our credit card payment processing, except where such interests are overridden by the fundamental rights and freedoms of the data subject which require protection of personal data.
4.2 We collect and store the information which you give us via forms on our website – such as your name, email address and company name.
4.3 We collect personal data from recent university graduates to advertise their availability on our Hiring Hub. This data is collected via our Application Form, and includes name, email address, physical address, phone number and details of previous work experience and education and employment details. We will only publish your data on our Hiring Hub with your explicit consent which is normally gathered at the same time as when you agree to our Terms and Conditions but as a separate opt-in.
4.4 We collect personal data from employers, including name, email address, physical address, and phone number upon sign-up to the Hiring Hub. We also collect information about the organisation and open roles once the employer is signed in.
4.5 We process personal information to enable us to provide advice and professional services as an employment agency, to maintain our own accounts and records and to support and manage our employees. We also process personal data for marketing purposes where individuals give their explicit consent or where we have legitimate interests to do so in relation to individuals whose personal data is publicly available and where we contact them in their work-related capacity.
4.6 We may receive and store certain information automatically when you interact with us. Examples include the internet protocol (IP) address used to connect your computer to the internet, connection information such as browser type and version, information about your mobile or other device including device-type and device identifier, operating system and platform, a unique reference number linked to the data you enter on our system, login details, clickstream data, details of your activity on our website with date / time stamps including the pages you visited and searches you made.
4.7 We may obtain information about you from third parties, such as Linkedin, Facebook, Twitter and Instagram when you are looking for and/or you show an interest in working with DigitalGrads. As a recruitment company we have a legitimate business interest to help you find work and to do this we need to process your personal data.
4.8 We will not request or hold any type of sensitive personal data or special category data about you, including your photographs and videos, without your prior explicit consent.
5. Who the information is processed about:
We process personal information about our:
- Customers, clients and employers
- Complainants and enquirers
- Suppliers, subcontractors and their employees
- Advisers and other professional experts
- Graduates and job seekers
6.3 Cookies are widely used to make websites work, or work more efficiently, as well as to provide information to the website owner or others. Session cookies are temporary cookies that remain in the cookie file of your browser only until your browser is closed. They allow websites to link your actions during a browser session. Persistent cookies stay in the cookie file of your browser for longer (though how long will depend on the lifetime of the specific cookie). For further information on cookies, including how to use your browser to block them and how to delete cookies already stored on your device, visit: www.allaboutcookies.org.
6.3 Cookies are used on this website for the following purposes:
We may monitor information about your computer, including where available your IP address, operating system and browser type, how many times you visit the website, which pages you go to, traffic data, location data and the originating domain name of a user’s internet service provider, to improve the user’s experience whilst visiting the website, and better understand how you use it. This information helps us to build a profile of our users. Some of this data will be aggregated or statistical, which means that we will not be able to identify you individually.
Session cookies: We use session cookies to enable the website to keep track of your movement from page to page and store your selections so you do not get asked repeatedly for the same information. These cookies allow you to proceed through many pages of the website quickly and easily without having to authenticate or reprocess each new area you visit.
Google Analytics (“GA”) cookies: Google sets persistent cookies (up to two years) to recognise and count the number of website visitors as well as providing other information about the visit such as duration, route through the website and what sites the visitor came from. This information helps us to improve the way our website works, for example by making sure users find what they need easily.
WordPress cookies: WordPress places persistent cookies (up to one year) to verify details of your logged-in status, to customise your view of our interfaces and to avoid visitors who make repeat comments having to re-enter their details. Click here for more information.
Third party advertising cookies: As do many other sites, we may use third party advertisers and/or internet advertising companies working for them to fill ad space on our website. These third parties may use persistent cookies and other similar technologies (known as action tags, single pixel gifs and web beacons) to assess information about your visits to this and other sites. This is so they can track the effectiveness of their campaigns (including whether these advertisements are clicked on or viewed by users and later purchases by such users), avoid showing you the same advertisement repeatedly and display advertisements on this and other sites tailored to your preferences. We do not have any access to or control over these third party technologies. If you would like more information about these practices and to know your choices about not having this information used by certain of these companies, please visit www.youronlinechoices.com and www.networkadvertising.org/choices. Please contact the third parties directly for more information about their privacy practices.
Cookie-warning cookie: This cookie takes note of whether you are happy to accept cookies on this website based on your response to the message which appeared when you first visited the website. This persistent cookie will remember your preference for up to 60 days.
6.4 Retargeting pixels are used on this website for the following purposes:
Custom Audience via the Pixel Process: This website uses the “Facebook Pixel”, the “Twitter Universal Tag” and the “LinkedIn Insight Pixel”. User behaviour can be tracked after he has seen or clicked on a Facebook, Twitter or LinkedIn advertisement. This process is designed to evaluate the impact of Facebook, Twitter and LinkedIn ads for statistical and market research purposes and may help to optimise future advertising efforts.
You may allow Facebook, Twitter and LinkedIn and their partners to place ads on and outside of Facebook. A cookie may also be stored on your computer for these purposes. These processing operations only take place if express consent is given in accordance with Art. 6 (1) point a GDPR.
Consent to the use of theFacebook, Twitter and LinkedIn pixel may only be given by users who are older than 13 years of age. If you are younger, please ask your legal guardian for permission.
Facebook, Twitter and LinkedIn based in the United States, are certified for the US-European data protection agreement “Privacy Shield”, which guarantees compliance with the data protection level applicable in the EU.
6.5 Google AdWords Remarketing
Our website uses the functions of Google AdWords Remarketing, which enable us to advertise our website in Google search results, as well as on third-party websites. Provider is Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA (“Google”). To this end, Google places a cookie in the browser of your terminal device, which automatically uses a pseudonymous cookie ID on the basis of pages you visited to allow interest-based advertising. Processing is based on our legitimate interest in the optimal marketing of our website in accordance with Art. 6 (1) point f GDPR.
Any additional processing will only take place if you have agreed with Google that your Google Internet and app browsing history will be linked to your Google Account and information from your Google Account will be used for personalised ads you view on the web. If you are logged in to Google while visiting our website, Google will use your data in connection with Google Analytics data to create and define target group lists for cross-device remarketing. To this end, Google temporarily links your personal data with Google Analytics data to create target groups.
You can permanently disable the setting of cookies for advertising preferences. You may download and install the browser plug-in available at the following link: https://www.google.com/settings/ads/onweb/
Alternatively, you can contact the Digital Advertising Alliance at http://www.aboutads.info to find out how to set cookies and to make the relevant settings. Finally, you can set your browser so that you are informed about the setting of cookies and decide individually whether to accept them or to exclude the acceptance of cookies for certain cases or in general. If cookies are not accepted, the functionality of our website may be limited.
Google LLC, based in the United States, is certified for the US-European data protection agreement “Privacy Shield”, which guarantees compliance with the data protection level applicable in the EU.
Further information and the data protection regulations regarding advertising and Google can be viewed at:
6.6 By continuing to use our website, having seen our cookie and remarketing pixel notice, we assume that you consent to use of the cookies outlined above. We gather this information for internal use only and will never authorise the release of this information outside of DigitalGrads. For further information on cookies generally visit www.aboutcookies.org or www.allaboutcookies.org.
7. How do we use your personal data?
7.1 We collect information about you so that we can:
- identify you and manage any accounts you hold with us
- provide our services requested by you, e.g. send service messages, send training course reminders by email and SMS and process payments
- if you agree, let you know about other products or services that may be of interest to you (see ‘Marketing’ section below)
- detect and prevent fraud
- customise our website and its content to your particular preferences
- notify you of any changes to our website or to our services that may affect you
- improve our services
7.2 We use your personal data to help us communicate with you effectively should you try to contact us via our website.
7.3 If you have given permission on our website, we may use your personal data to send you emails (or other communications such as mail, phone or SMS) with details of our graduates ready to hire or other services which may be of interest to you including information about special offers or promotions.
7.4 With your explicit consent we will share your contact details (name, email address and mobile phone number) with employers who request to interview you. You will also be notified by email as soon as your details have been made available to an employer.
7.5 With your explicit consent, we will share your contact details (name, company name, email address and contact phone number) with the graduate who you have requested to interview.
7.7 We retain personal data from closed accounts in order to comply with legal obligations, enforce our terms and conditions, prevent fraud, collect any fees owed, resolve disputes, troubleshoot problems, assist with any investigations and take other actions as permitted by law.
7.8 We may access, remove, alter, store or otherwise use any personal data if we have reason to believe that it breaches our terms and conditions, or that such steps are necessary to protect us or others, or that a criminal act has been committed, or if we are required to do so by law or appropriate authority.
8. How do we protect personal data?
8.1 Security is a high priority for us. We take appropriate precautions to protect personal data.
8.2 Email and other electronic communications are not secure if they have not been encrypted. Your communications will pass through a number of network nodes before they reach us. So we do not accept responsibility for any unauthorised access to or loss of personal data that stems from a cause beyond our control. Nor can we be held responsible for the actions or omissions of other users or third parties who may misuse your personal data which they collect from the website.
8.3 Our staff are bound by obligations of confidentiality and trained in the protection of personal data. We comply with the Legislation and use the appropriate technical and organisational measures necessary to safeguard your personal data. We only share your personal data with third parties who also comply with the Legislation.
8.4 While we will use all reasonable efforts to safeguard your personal data, you acknowledge that the use of the internet is not entirely secure and for this reason we cannot guarantee the security or integrity of any personal data that is transferred from you or to you via the internet. If you have any particular concerns about your information, please contact us (see ‘How to contact us?’ below).
8.5 If you want detailed information on how to protect your information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.
9. To whom do we disclose personal data?
9.1 We may allow access to your personal data by third parties who supply us with a service (but not for marketing purposes). Examples include e-website hosts, content delivery networks and businesses which assist us in undertaking communications or monitoring our website.
9.2 We do not provide your personal data to third parties for marketing purposes.
9.3 Very important: Your name, profile image and video which you provide to us for your Hiring Hub profile page will be visible to other users of our website and no where else.
9.4 We may disclose personal data so far as reasonably necessary:
- if we have reason to believe that it breaches our terms and conditions, or that such steps are necessary to protect us or others, or that a criminal act has been committed, or if there has been a complaint about content posted by you, or if we are required to do so by law or appropriate authority;
- or in the case of an actual or proposed (including negotiations for a) sale or merger or business combination involving all or the relevant part of our business.
9.5 We may store or transfer personal data outside the European Economic Area (EEA) for the purposes stated in this policy. If so, we will of course comply with the applicable laws relating to data transfer outside the EEA.
9.6 Except as otherwise specifically included in this policy, this document addresses only the use and disclosure of information we collect from you. If you disclose your information to third parties, different rules will apply to their use or disclosure of your information. Please check their privacy policies carefully.
10. Retention periods – how long do we keep your data?
We store your personal data on secure servers for a period of:
10.1 Graduates – twelve months from the date of your last application with us.
10.2 Employers / Suppliers – If you are one of our clients or suppliers we will hold your details for as long as we have a business requirement to hold such details. We regularly check our databases and will delete your records if we have not used your personal data for 5 years, unless the law requires us to store the data for a longer period. Please inform us if you would like us to remove any details we hold of you from our records.
11. Your rights
11.1 The GDPR provides the following rights for individuals whose personal data is processed:
- The right to be informed
- The right of access
- The right to rectification
- The right to erasure
- The right to restrict processing
- The right to data portability
- The right to object to processing
- Rights in relation to automated decision making and profiling (We do not carry out automated decision making and profiling)
- Right to access – i.e. to request a copy of your information
11.2 You can request a copy of your information which we hold (this is known as a subject access request). If you would like a copy of some or all of it, please write to us at DigitalGrads, 45 Church Road, Hove BN34JG or email firstname.lastname@example.org a proof of your identity (a copy of your driving licence or passport); and let us know what information you want.
11.3 Your right to correct any mistakes in your information:
You can require us to correct any mistakes in your information which we hold free of charge. If you would like to do this, please email or write to us (see ‘How to contact us?’ below), let us have enough information to identify you and let us know the information that is incorrect and what it should be replaced with.
11.4 Your right to remove your details from our records or restrict how we use your information:
You can ask us to stop contacting you for particular purposes or remove your information completely from our records. There may be a legal reason why we need to keep your personal data and in that circumstance we will destroy your personal data as soon as we are legally entitled to do so. If you would like us to stop contacting you with information about our services, please email or write to us (see ‘How to contact us?’ below). You can also click on the ‘unsubscribe’ button at the bottom of the email and/or newsletter. Let us know what method of contact you are not happy with if you are unhappy with certain ways of contacting you only (for example, you may be happy for us to contact you by email but not by telephone).
11.5 Your right to lodge a complaint with the Supervising Authority
If you have any concerns or complaints about how we use your personal data we hope you will alert us to these directly (see the Contact information below). If you are still unhappy you are entitled to complain to the Information Commissioners Office (ICO) which is the relevant supervising authority in the UK. Their contact details and the procedure can be found at www.ico.gov.uk
12. How to contact us