Disclosure Services Ltd understands that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of all of our Clients and Applicants and we will only collect and use personal data in ways that are described here, and in a way that is consistent with our obligations and your rights under the law.
- Information About Us
Disclosure Services Ltd.
A Limited Company registered in England & Wales under company number 04198359.
Main trading and registered address: Ellice House, Ellice Way, Yale Business Village, Wrexham, LL13 7YL.
VAT number: GB989 8230 52
Data Protection Officer: Steven Burgess
Telephone number: 01978 510100
- What Does This Notice Cover?
This Privacy Information explains how we use your personal data: how it is collected, how it is held, and how it is processed. It also explains your rights under the law relating to your personal data.
- What is Personal Data?
Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) as ‘any information relating to an identifiable person who can be directly or indirectly identified by reference to an identifier’.
Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.
The personal data that we use is set out in Part 5, below.
- What Are My Rights?
Under the GDPR, you have the following rights, which we will always work to uphold:
a) The right to be informed about our collection and use of your personal data. This privacy notice should tell you everything you need to know, but you can always contact us to find out more or to ask any questions using the details in Part 11.
b) The right to access the personal data we hold about you. Part 10 will tell you how to do this.
c) The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in Part 11 to find out more.
d) The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we have. Please contact us using the details in Part 11 to find out more.
e) The right to restrict (i.e. prevent) the processing of your personal data.
f) The right to object to us using your personal data for a particular purpose or purposes.
g) The right to data portability. This means that, if you have provided personal data to us directly, we can provide you with a copy, for you to transfer to another IT system.
h) Rights relating to automated decision-making and profiling. We do not use your personal data in this way.
For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Part 11.
Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.
If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office.
- What Personal Data Do We Collect?
We may collect some or all of the following personal data (this may vary according to your relationship with us):
- Date of birth;
- Place of birth;
- Address history;
- Identity document detail;
- Email address;
- Telephone number;
- Organisation/Business name;
- Job title;
- Payment information; (We do not hold payment card data, this service is provided to us by a third party, Barclays PLC).
Personal data may be obtained from the following third parties:
- The employer or recruiting organisation;
- The applicant;
- The Disclosure and Barring Service;
- Disclosure Scotland;
- Access Northern Ireland;
- Experian UK; (For the use of credit checks only, not criminal records checks)
- How Do You Use My Personal Data?
Under the GDPR, we must always have a lawful basis for processing personal data. This may be because the data is necessary for our performance of a contract with you, because you have consented to our use of your personal data, or because it is in our legitimate business interests to use it. Your personal data will be used for one or more of the following purposes:
- Providing and managing your account (clients).
- Applying for a Disclosure to the relevant disclosure body (applicants).
- Supplying our services to you. Your personal details are required for us to enter into a contract with you and provide you with a criminal record check service.
- Personalising and tailoring our services for you.
- Communicating with you. This may include responding to emails or calls from you.
- Supplying you with information by email and/or post that you have opted-in to (you may unsubscribe or opt-out of emails at any time by clicking on the email unsubscribe link).
We may also use your personal data for marketing purposes, which may include contacting you by email and/or telephone and/or post with relevant account information, news, and offers on our services. You will not be sent any unlawful marketing or spam. We will always work to fully protect your rights and comply with our obligations under the GDPR (General Data Protection Regulations) 2016, DPA (Data Protection Act) 2018 and the PECR (Privacy and Electronic Communications Regulations) 2003, and you will always have the opportunity to opt-out of communications.
- How Long Will You Keep My Personal Data?
We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Your personal data will therefore be kept for the following periods (or, where there is no fixed period, the following factors will be used to determine how long it is kept):
- Applicant Personal Data will be retained for three months following the issue of the disclosure certificate;
- Business accounting information will be retained for seven years.
- How and Where Do You Store or Transfer My Personal Data?
We will only store or transfer your personal data within the UK. Our servers are based in Manchester and London, United Kingdom.
- Do You Share My Personal Data?
For DBS Certificates – to The Disclosure and Barring Service
For Disclosure Scotland Certificates – to Disclosure Scotland
For Access Northern Ireland Certificates – to Access NI
For payment processing information – Barclays Bank Plc
In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.
- How Can I Access My Personal Data?
If you want to know what personal data, we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.
All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 11. A form is available from us for this purpose.
There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.
We will respond to your subject access request within thirty days. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request.
- How Do I Contact Disclosure Services?
To contact us about anything to do with your personal data and data protection, including how to make a subject access request, please use the following details (for the attention of Steven Burgess):
Telephone number: 01978 510100
Postal Address: Disclosure Service Ltd, Ellice House, Ellice Way, Yale Business Village, Wrexham, LL13 7YL.
- Legitimate Interests Assessment Statement (for marketing)
We at Disclosure Services have a legitimate interest in our industry by providing background screening services for companies. We also have a legitimate interest in the activities of clients and potential clients by helping them to be safer and more comfortable with their recruitment decisions. Therefore, the processing is important for the purpose of providing background screening check services.
We feel that there is a clear justification for promoting our services and feel that the rights and freedoms of individuals remain unaffected if legislation is followed in ensuring that legally, we are in the correct position. Therefore, we feel that we have a lawful basis (legitimate interests) for processing and are fair and transparent in what we do as a company.
We use our marketing lists to contact companies who we feel would welcome our services and we are open and honest about our identity. We help companies to safeguard their environment by helping to screen employees and potential employees.
We use email addresses and telephone numbers to contact potential clients and ensure that we abide by the Privacy and Electronic Communications Regulations by ensuring that we keep a list of clients who do not want to be contacted.
- Criminal convictions (for criminal records applications)
To process personal data about criminal convictions or offences, we have a lawful basis (Consent) whereby the data subject (applicant) has given consent to the processing of his or her personal data under Article 6 of the GDPR; and we have legal authority for the processing under Article 10 because we are a registered umbrella body with the Disclosure and Barring Service, Disclosure Scotland and Access NI.
- Changes to this Privacy Notice
We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection.