1. How We Use Your Information

• 1.1 Computer Network Defence are a cyber security consultancy and recruitment agency. This privacy notice tells you what to expect when Computer Network Defence collects personal information to allow us to undertake our business. It applies to personal information we collect about:

• 1.1a Prospective and live client contacts

• 1.1b Prospective and placed candidates for permanent or temporary roles

• 1.1c Supplier contacts to support our services

• 1.1d Employees, partners, associates (temporary workers)

• 1.1e Employees, partners, associates (temporary workers)

2. Information You Give To Us Or We Collect About You

• 2.1 This is information about you that you give us by filling in our application or enquiry forms on our site www.cndltd.com (our website) or by corresponding with us by the mediums detailed below. The information you give us or we collect about you may include your name, address, private and corporate e-mail address and phone number, financial information, compliance documentation and references verifying your qualifications and experience and your right to work in the United Kingdom, curriculum vitae and photograph, links to your professional profiles available in the public domain e.g. LinkedIn, Twitter, business Facebook or corporate website.

• 2.2 People who contact us via social media.We operate Facebook, Twitter and Linkedin accounts, if you send us a private or direct message via social media the message will be stored relevant to their data retention policies. It will not be shared with any other organisations.

• 2.3 People who call our office. When you call CND’s office we collect Calling Line Identification (CLI) information. We use this information to help improve its efficiency and effectiveness. Our phones are answered by a third party company. The company that provides this service will email us the caller’s details should we be unavailable and do not retain any further information from the calls or record them.

• 2.4 People who email us. Any email sent to us, including any attachments, may be monitored and used by us for reasons of security and for monitoring compliance with office policy. Email monitoring or blocking software may also be used. Please be aware that you have a responsibility to ensure that any email you send to us is within the bounds of the law.

3. Information We Collect When You Visit Our Website

• 3.1 Our website and all corresponding software is hosted by us on a dedicated server based in the United Kingdom.

• 3.2 When someone visits our website we collect information to monitor and report on the effectiveness of the site and help us improve it. We use Google Analytics to perform this task Information collected includes Internet Protocol (IP) address and visited page, as well as any other actions taken while interacting with the website for example links clicked on. We use cookies to collect standard internet log information and details of visitor behaviour patterns. Google's privacy notice can be found here.

• 3.3 We actively service and maintain the security of our website. To be able to do this, we process the IP addresses of visitors to the website. We support both https and http (encrypted and unencrypted traffic) on our website to enable all visitors to access our content.  If encryption of your web browsing activity is desirable, please use https: in the URLs and verify the connection is secure through whatever method your browser uses to indicate an encrypted connection.

4. Purposes of the Processing and the Legal Basis for the Processing

• We use information held about you in the following ways:

  4.1 To carry out our obligations arising from any contracts we intend to enter into or have entered into between you and us and to provide you with the information, products and services that you request from us or we think will be of interest to you because it is relevant to your career or to your organisation.

• 4.2 To provide you with information about other goods and services we offer that are similar to those that you have already purchased, been provided with or enquired about.  
  

• 4.3 The core service we offer to our candidates and clients is the introduction of candidates to our clients for the purpose of temporary or permanent engagement.  However, our service expands to supporting individuals throughout their career and to supporting businesses’ resourcing needs and strategies.

  Examples:

  • 4.3a We may send a candidate the Hiring Manager’s name and experience so they can effectively prepare for an interview.
  • 4.3b We may send a client’s details to one of our penetration testing partners should a client send us an enquiry and choose a partner’s particular skillset.

• 4.4 Our legal basis for the processing of personal data is our legitimate business interests, described in more detail in section 6, although we will also rely on contract, legal obligation and consent for specific uses of data.

• 4.5 We will rely on contract if we are negotiating or have entered into a placement agreement with you or your organisation or any other contract to provide services to you or receive services from you or your organisation.

• 4.6 We will rely on legal obligation if we are legally required to hold information on to you to fulfil our legal obligations.

• 4.7 We will in some circumstances rely on consent for particular uses of your data and you will be asked for your express consent, if legally required.  Examples of when consent may be the lawful basis for processing include permission to introduce you to a client (if you are a candidate or a partner).

5. Our Legitimate Business Interests

• Our legitimate interests in collecting and retaining your personal data is described below:

  5.1 As a recruitment and consultancy business and recruitment agency we introduce candidates or partners to clients for permanent employment, temporary worker placements or independent professional contracts. The exchange of personal data of our candidates, partners and our client contacts is a fundamental, essential part of this process.

• 5.2 In order to support our candidates’ career aspirations and our clients’ resourcing and requirement needs we require a database of candidate and client personal data containing historical information as well as current resourcing requirements.

• 5.3 To maintain, expand and develop our business we need to record the personal data of prospective candidates, partners and client contacts.

• 5.4 Following an enquiry, we will keep client and candidate information for 3 years, unless contacted by them and directed otherwise.

• 5.5 Following an engagement, we will keep client or candidate information for 6 years, unless contacted by them and directed otherwise.

6. Consent

• 6.1 Should we want or need to rely on consent to lawfully process your data we will request your consent orally, by email or by an online process for the specific activity we require consent for and record your response on our system. Where consent is the lawful basis for our processing you have the right to withdraw your consent to this particular processing at any time.

7. Disclosure of Your Information Inside and Outside of the EEA

• 7.1 We will share your personal information selected third parties including:

• 7.1a Clients for the purpose of introducing candidates to them

• 7.1b Candidates for the purpose of arranging interviews and engagements

• 7.1c Clients, business partners, suppliers and sub-contractors for the performance and compliance obligations of any contract we enter into with them or you

• 7.1d Subcontractors including our accountants and other financial service providers

• 7.1e Analytics and search engine providers that assist us in the improvement and optimisation of our site

• 7.1f Credit reference agencies, our insurance broker, compliance partners and other sub-contractors for the purpose of assessing your suitability for a role where this is a condition of us entering into a contract with you

• 7.2 We will disclose your personal information to third parties:

• 7.2a If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms of use or Master Framework Agreement or Supply of Services Agreement and other agreements; or to protect the rights, property, or safety of Computer Network Defence our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

• 7.2b The lawful basis for the third party processing will include:

  • 7.2b.1 Their own legitimate business interests in processing your personal data, in most cases to fulfil their internal resourcing needs;
  • 7.2b.2 Satisfaction of their contractual obligations to us as our data processor
  • 7.2b.3 For the purpose of a contract in place or in contemplation
  • 7.2b.4 To fulfil their legal obligations

• 7.2c We do not control your data once it is disclosed to a third party and therefore you should satisfy yourself of their Privacy Policy and how they may collect and distribute information.

8. Where We Store and Process Your Personal Data

• 8.1 The data that we collect from you will be transferred to, and stored in the European Economic Area (with the exception of financial information processed by market-leading accounting software, as they have yet to confirm the location of their data storage). It may also be transferred to third parties outside of the EEA for the purpose of our recruitment services. By submitting your personal data, you agree to this transfer, storing or processing. Computer Network Defence will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy notice.

• 8.2 All information you provide to us is stored on our secure servers. Any payment transactions will be encrypted using SSL technology.

• 8.3 Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

9. Retention of Your Data

• 9.1 We understand our legal duty to retain accurate data and only retain personal data for as long as we need it for our legitimate business interests and that you are happy for us to do so.  Accordingly, we have a data retention notice and run data routines to remove data that we no longer have a legitimate business interest in maintaining.

• 9.2 We do the following to try to ensure our data is accurate:

• 9.1a Prior to making an introduction we check that we have accurate information about you.

• 9.1b We keep in touch with you so you can let us know of changes to your personal data.

• 9.2 We segregate our data so that we keep different types of data for different time periods.  The criteria we use to determine whether we should retain your personal data includes:

• 9.2a The nature of the personal data

• 9.2b Its perceived accuracy

• 9.2c Our legal obligations

• 9.2d Whether an interview or placement has been arranged

• 9.2e Whether a requirement has been scoped, quoted or service delivered

• 9.3 We may archive part or all of your personal data or retain it on our financial systems only, deleting all or part of it from our main Customer Relationship Manager (CRM) system. We may pseudonymise parts of your data, particularly following a request for suppression or deletion of your data, to ensure that we do not re-enter your personal data on to our database, unless requested to do so.

• 9.4 Our current retention notice is available upon request.  

10. Your Rights

• 10.1 You have the right to ask us not to process your personal data for marketing purposes. We will usually inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes and we will collect express consent from you if legally required prior to using your personal data for marketing purposes.

• 10.2 You can exercise your right to accept or prevent such processing by checking certain boxes on the forms we use to collect your data. You can also exercise the right at any time by contacting us at the address provided below.

• 10.3 The GDPR provides you with the following rights. To:

• 10.3a Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.

• 10.3b Request erasure of your personal information. This enables you to ask us to delete or remove personal information 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 information where you have exercised your right to object to processing (see below).

• 10.3c Object to processing of your personal information 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. You also have the right to object where we are processing your personal information for direct marketing purposes.

• 10.3d Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.

• 10.3e Request the transfer of your personal information to another party in certain formats, if practicable.

• 10.3f Make a complaint to a supervisory body which in the United Kingdom is the Information Commissioner’s Office. The ICO can be contacted through this link:  https://ico.org.uk/concerns/

11. Complaints or Queries

• 11.1 CND tries to meet the highest standards when collecting and using personal information. For this reason, we take any complaints we receive about this very seriously. We encourage you to bring it to our attention if you think that our collection or use of information is unfair, misleading or inappropriate. We would also welcome any suggestions for improving our procedures.

• 11.2 This privacy notice was drafted with brevity and clarity in mind. It does not provide exhaustive detail of all aspects of CND’s collection and use of personal information. However, we are happy to provide any additional information or explanation needed. Any requests for this should be sent to the relevant address provided below.

12. Links to Other Websites

• 12.1 This privacy notice does not cover the links within this site linking to other websites. We encourage you to read the privacy statements on the other websites you visit.

13. Changes to This Privacy Notice

• 13.1 We keep our privacy notice under regular review. This privacy notice was last updated on 14th May 2018.

14. How to Contact Us

• 14.1 If you want to request more information on our privacy policy or personal details we may hold you can contact us:

  cnd.dpo@cndltd.com

  FAO: Data Protection Officer
  Computer Network Defence Ltd
  22 St Lawrence Street
  Bath 
  Somerset 
  BA11AN