Privacy Policy

As a trading division of TWYD Group Limited, TWYD & Co (TWYD) is a provider of Executive Search, Coaching and Mentoring and Business Advisory services. We provide these services to individuals to help them define their next career steps and provide practical support and guidance to help them achieve their career goals.

Your privacy is important to us and we take it very seriously. The policy below lays out in plain English how TWYD handles your personal data. We want to ensure that you know exactly how we use your personal information, that you continue to have peace of mind about how we use your data and that we act transparently, only collecting information about you that we need.

DEFINITIONS

Clients:
An employer or other Institution to whom we may provide your data in the provision of our Services.

You, Your:
References to ‘you or ‘your’ refer to you as the recipient and user of our Services that are initiated by you directly.

Services:
The career support that TWYD provide to you including but not limited to Permanent or Interim Placement or Personal Coaching or Mentoring (telephone and face to face).

 

TWYD AS A DATA CONTROLLER AND OUR REGULATOR

  1. TWYD Group Ltd is registered as a Data Controller with the Information Commissioner’s Office Certificate Number ZA517358
  2. Our Data Protection Representative is David Twiddle, Managing Partner. If you have any queries in relation to data security or wish to make a subject access request, you can email dt@twyd.co
  3. The office of the Information Commissioner is the office appointed by the UK Government with responsibility for data protection, and they can also assist with any complaints or questions you may have. They can be contacted at ico.org.uk.

 

HOW DO WE COLLECT INFORMATION ABOUT YOU?

  1. Directly provided by you to TWYD during the provision of the Services e.g. by applying to a job opportunity through a third-party platform, by email, by post or by telephone.
  2. Indirectly from you, via the use of Cookies when you browse our online resources.

 

WHAT PERSONAL INFORMATION DO WE COLLECT ABOUT YOU?

We may collect and process different types of information about you in order that we can effectively provide the Services. Some examples of the information we collect include:

  1. Standard contact information including your name, address, post code, telephone number(s), email address, etc.
  2. Records of your education, work experience, achievements, skills, preferences or other biographical information that you may provide to us or hold in documents stored by us while accessing the Services.
  3. Information pertaining to your specific job search, including roles applied for, interviews, feedback and outcomes.
  4. Information relating to your eligibility to work within the United Kingdom (including a copy of your passport / visa).
  5. Information relating to any disclosures you make in respect of criminal convictions.
  6. Information relating to your views on our Services including e.g. responses to survey information.
  7. Usage and log data automatically collected when you visit our website(s), including IP address and associated general location, device information, browser type, operating system, your progression through the site, what areas you viewed and where you abandoned it.
  8. Social media data you choose to provide, such as links to LinkedIn or Twitter profiles.

 

WHY DO YOU NEED TO PROCESS MY PERSONAL DATA?

TWYD is committed to processing your personal data in accordance with the principles of lawfulness, fairness and transparency, data minimization, accuracy, storage limitation and integrity, and confidentiality. In simple terms we need to process your personal data in order that we can:

  1. Effectively provide the Services to you, including communicating with you, recording activities and administering your account.
  2. Fulfil our contractual obligations to our Clients and to you to provide the Services.
  3. Meet legal or regulatory requirements.
  4. Administer, maintain and improve our Services by monitoring interaction with various aspects of those Services, e.g. candidate care.

 

WHO WE MAY SHARE PERSONAL DATA WITH

We do not sell mailing lists to any third parties for their marketing purposes. We stress that we will not disclose your personal information to any third parties unconnected to the provision of the Services to you. For clarity, however, it is worth noting that:

  1. We may share your data with potential employers or other institutions where you have specifically given TWYD permission to do so.
  2. We may use carefully selected third parties to carry out certain activities to help us provide the Services to you effectively. These third parties would operate as our Data Processors, e.g. providers of assessment tools. Data processors that have access to, and are associated with, the processing of your personal information are legally obliged to respect the confidentiality of your data and are bound by contract to do so.
  3. If the Services being provided to you have been sponsored by our Clients (e.g. an employer), we may disclose information to them for the purposes of them assessing the success and quality of the Services being provided to you. You have the right to request that this information is not shared with our Clients by emailing dt@twyd.co
  4. Regulators or Law Enforcement agencies if required by law to do so.

 

HOW LONG WILL MY DATA BE STORED AND WHAT CRITERIA WILL DETERMINE HOW LONG YOU HOLD IT?

 We store personal data in line with legal, regulatory, financial and best-practice business requirements. We have a process in place on an annual basis to review the different categories of data we hold and determine the necessity to hold that data, taking into account fully the lawful bases for continuing to process that data.

 

YOUR RIGHTS OVER YOUR PERSONAL DATA

 It is important to us that you understand your rights as set out in Article 13 (1) (C) of the current Data Protection Legislation. You have the rights to:

  1. Access a copy of the personal information we keep about you by making a Subject Access Request. Please direct your enquiry to our Data Protection Representative at david@twiddleandco.com We will provide you with a hard copy of the personal data we keep (at no charge) within 30 days. We will, however, require proof of identity.
  2. The right to object to processing that is likely to cause, or is causing damage or distress.
  3. The right to prevent processing for Direct Marketing.
  4. The right to object to decisions being taken by automatic means.
  5. The right to have inaccurate personal data rectified, blocked, erased or destroyed.
  6. The right to data portability
  7. The right to make a complaint to a supervisory body

 

CROSS BORDER TRANSFERS OF PERSONAL DATA

We do not transfer your personal data from the European Economic Area (EEA) or the European Union (EU) to a country outside the EEA or the EU except when you access the Services from outside the EEA or the EU. In the event that this was deemed necessary for the effective provision of the Services, we would guarantee only to use third parties that meet the data protection regulation standards in the EEA or EU.

 

SECURITY

TWYD has comprehensive IT, data and physical security arrangements in place. All of our data is held securely within the EEA and appropriate back-up procedures are in place. Our staff are subject to screening and are trained in the importance of ensuring data is used and managed correctly in line with current Data Protection Legislation.

In the event of a suspected breach, we have a clear process in place for investigation and notification of data subjects.

Please be aware that communications over the internet, such as e-mails/webmails that may form part of our communication to you while delivering the Services, are not secure unless they have been encrypted. We cannot accept responsibility for any unauthorised access or loss of personal information that is beyond our control.

 

HOW AND WHEN WE MAY CHANGE THIS POLICY

We will keep this Policy under review and any changes made from time to time will be posted on this page. Please check back regularly to keep informed of updates or changes to this privacy statement. Your continued use of the Services shall constitute your acknowledgment of these changes.