Cadogan James Privacy Notice
We respect the privacy of every person who visits, or registers with, or submits personal information through our website at www.cadoganjames.com (the "Site") and who uses the recruitment services that we offer, including from the Site (our "Services").
1. Purpose of this Privacy Notice
This Privacy Notice ("Privacy Notice") explains our approach to any personal information that we might collect from you or which we have obtained about you from a third party and the purposes for which we process your personal information. This Privacy Notice also sets out your rights in respect of our processing of your personal information.
This Privacy Notice will inform you of the nature of the personal information about you that is processed by us and how you can request that we delete it, update it, transfer it and/or provide you with access to it.
This Privacy Notice is intended to assist you in making informed decisions when using the Site and our Services. Please take a moment to read and understand it.
Please also note that this Privacy Notice only applies to the use of your personal information obtained by us, it does not apply to your personal information collected during your communications with third parties who collect it for their own purposes.
2. About Us
The Site and our Services are operated by Cadogan James Ltd, ("we", "us" or "our").
Cadogan James Ltd is the data controller responsible for your personal information and is a private limited company registered in England under company registration number 12110407 with its registered office address located at 20-22 Wenlock Road, London N1 7GU.
Cadogan James Ltd is registered as a data controller with the UK’s Information Commissioner’s Office under registration number ZA567277.
3. Compliance with GDPR
Under the General Data Protection Regulation (GDPR) Cadogan James Ltd is a ‘data controller’ because we hold personal information about individuals.
We comply with data protection law and principles, which means that data we hold about individuals will be:
Used lawfully, fairly and in a transparent way.
Collected only for valid purposes that we have clearly explained to each individual we work with and not used in any way that is incompatible with those purposes.
Relevant to and limited only to those purposes.
Accurate and kept up to date.
Kept only as long as necessary for the relevant purposes.
Kept securely.
We obtain some information on potential candidates from publicly accessible sources, such as the Law Society, LinkedIn and the legal press. In some circumstances we may obtain information from third parties, such as personal contacts or individuals we have worked with in the past. We also obtain information from candidates directly.
The type of personal information about individuals that we collect, store and use might include the following:
General biographical information such as full name, date of birth and education.
Professional biographical information such as current role and employer, date of qualification and previous employers, as well as recent experience.
Generally we do not collect, store or use any ‘special categories’ of sensitive personal information or information about criminal convictions. If we may need to do so in a particular case we will let the individual concerned know and advise them of how we will use this information.
We use the personal information we collect about individuals to gauge potential interest from law firms and whether they would be a potential fit.
Our business is the recruitment and search of lawyers for law firms. It is in our legitimate interest to try and introduce potential candidates to potential employers with a view to both parties entering into a new employment relationship. To do this we speak to law firms to discuss their hiring needs. We review possible candidates and then discuss those individuals with law firms to ascertain whether there is a potential fit. We then introduce candidates and law firms.
The nature of our business means that we share information about candidates with potential recruiters within law firms. We limit the information that we share to that which is required to ascertain whether a law firm is interested in the possibility of employing an individual and whether they may be a suitable candidate. In the event that we do hold any special category information we would not share this without the individual’s consent.
4. How to contact us
If you have any questions about this Privacy Notice or want to exercise your rights set out in this Privacy Notice, please contact us by:
Sending us an email at: neil@cadoganjames.com
Calling us on: +44 (0)203 874 2090
5. How we may collect your personal information
We may collect your personal information directly from you where we have a relationship with you either because you are a candidate, client or supplier to us, or you have given us your information directly, or through your use of the Site.
We may also collect your personal information from third parties or, where permitted, from a publicly available source such as LinkedIn, Chambers and Partners or Legal 500.
6. Personal information we collect and how we use it
Our primary goal in collecting personal information from you is to: (i) provide our Services to you, whether you are a business looking to recruit, or a potential candidate looking for a new job role; (ii) verify your identity (where applicable); (iii) help us improve our Site and our Services and develop and market new products and services; (iv) carry out requests made by you on the Site; (v) investigate or settle inquiries or disputes; (vi) comply with any applicable law, court order, other judicial process, or the requirements of a regulator; (vii) where we have a contractual agreement with you, enforce such agreement with you; (viii) protect the rights, property or safety of us or third parties, including our other clients and users of the Site; (ix) provide support for the provision of our Services; (x) carry out internal recruitment activities; and (xi) use as otherwise required or permitted by law.
In particular, we use your personal information for the following purposes:
Fulfilment of our Services
We collect and maintain personal information that you voluntarily submit to us during your use of the Site, or otherwise and in the provision of our Services generally to law firms and candidates.
Candidate placement: If you are a candidate seeking job opportunities, we will use your name and contact information (e.g. email address, postal address, telephone number), personal information concerning your education, qualifications and employment history and any other personal information which appears in your curriculum vitae or which is relevant in order to identify relevant job opportunities for you. We will also collect information about your eligibility to work in the United Kingdom and information about any unspent criminal convictions you may have where required by our client.
Recruitment services: If you are a business who is looking to fill a job vacancy, we will use your name and contact information (e.g. email address and telephone number) in order to provide our Services to you and send you details of our search progress.
Who do we share your personal information with for this purpose?
If you are a candidate, we will share your personal information obtained from you or from publicly available sources with our clients who have requested us to source a candidate if we think that you are a potential fit for their business. Some of these clients may be located outside of the EEA, for example in the US by virtue of the client being a US company.
We also store business clients and candidates’ names and contact details in a database operated by third party software providers.
Please note there may be other circumstances where we need to share personal information with third parties in order to provide the products and services as effectively as we can.
What is our legal basis?
It is necessary for us to use your personal information to perform our obligations in accordance with any contract (in the case of a law firm where terms have been agreed) or it is in our legitimate interest or a third party’s legitimate interest to use personal information in such a way to ensure that we provide the Services you have requested in the most effective and efficient way that we can. As a recruitment company it is fundamental to our business to use and store certain personal information in order to find job roles for candidates and likewise to source candidates for clients.
Where we provide your CV to a client for a particular job role or opportunity, we will only do so provided you have given us your consent.
We will not process any special (or sensitive) categories of personal information or personal information relating to criminal convictions or offences except where we are able to do so under applicable legislation or with your explicit consent.
Customer service and enquiries
Our Site provides you with contact information to enable you to enquire about our Services either by email or telephone. When making an enquiry, the enquirer’s name and contact information (email address, postal address, telephone number) may be requested, together with details of other personal information that is relevant to the enquiry. This information is used in order to enable us to manage and respond to your enquiries and requests.
Who do we share your personal information with for this purpose?
We do not share your personal information for this purpose.
What is our legal basis?
It is in our legitimate interest to use your personal information in such a way to ensure that we provide the very best customer service we can to you.
Notification of job roles or to find out whether you need recruitment support.
If you are a potential candidate, we may use your telephone number or email address to contact you directly about a specific job role that we have available, or to find out whether you are interested in moving job roles.
If you are a business, we may use your telephone number or email address to contact you directly to identify whether you need any recruitment support for current or future job opportunities that you may have available.
Who do we share your personal information with for these purposes?
We do not share your personal information with anyone else for this purpose.
What is our legal basis?
It is in our legitimate interest to contact you about potential job opportunities, or to identify whether you need any recruitment support.
Email marketing
From time to time we may use your name and email address to send you marketing communications by email, where you have consented to receive such marketing communications or where we have another lawful basis to do so.
Who do we share your personal information with for these purposes?
All marketing emails are sent to you directly by us and we do not share your personal information with anyone else for this purpose.
What is our legal basis?
We will only send you marketing communications by email where you have consented to receive such communications, or where we have a lawful right to do so.
Internal Recruitment
We use your personal information for internal recruitment purposes, in particular, to assess your suitability for any of our positions which you may apply for, whether such application has been received by us online, by email or by hard copy.
We may process any personal information about you that you volunteer when you apply for a job with us. Such information may include your name and contact information (e.g. email address, postal address, telephone number), personal information concerning your education, qualifications and employment history and any other personal information which appears in your curriculum vitae or which is relevant to your potential recruitment.
As well as the other information referred to in this section, we will also collect information about your eligibility to work in the United Kingdom and information about any unspent criminal convictions you may have.
We also use your personal information for the purposes of reviewing our equal opportunity profile in accordance with applicable legislation. We do not discriminate on the grounds of gender, race, ethnic origin, age, religion, sexual orientation, disability or any other basis covered by local legislation. All employment-related decisions are made entirely on merit.
Who do we share your personal information with for these purposes?
Where applicable, we may share your personal information with third party providers that undertake background checks on our behalf.
What is our legal basis?
Where we use your personal information in connection with internal recruitment, it will be in connection with us taking steps at your request to enter into a contract we may have with you or it is in our legitimate interest to use personal information in such a way to ensure that we can make the best recruitment decisions.
We will not process any special (or sensitive) categories of personal information or personal information relating to criminal convictions or offences except where we are able to do so under applicable legislation or with your explicit consent.
Business administration and legal compliance
We use your personal information for the following business administration and legal compliance purposes:
to comply with our legal obligations;
to enforce our legal rights;
to protect the rights of third parties; and in connection with a business transition such as a merger, acquisition by another company, or sale of all or a portion of our assets.
Who do we share your personal information with for these purposes?
We will share your personal information with professional advisers such as lawyers and accountants and/or governmental or regulatory authorities.
We may also share personal information with other entities within our group of companies for these purposes.
What is our legal basis?
Where we use your personal information in connection with a business transition, to enforce our legal rights or to protect the rights of third parties, it is in our legitimate interest to do so. For all other purposes described in this section, it is our legal obligation to use your personal information to comply with any legal obligations imposed upon us such as a court order.
We will not process any special (or sensitive) categories of personal information or personal information relating to criminal convictions or offences except where we are able to do so under applicable legislation or with your explicit consent.
Receipt of services from third party suppliers
If we have engaged you directly or the company you work for to provide us with services (e.g. you are a third party supplier providing us with a service such as IT support or financial advice), we will collect your name, contact information and bank account details.
Who do we share your personal information with for this purpose?
We may share your information with our property manager to inform them that you are visiting our office or a payment provider in order to pay your invoices.
What is our legal basis?
It is necessary for us to use your personal information to perform our obligations in accordance with any contract that we may have with you or it is in our legitimate interest to use personal information in such a way to ensure that we have an effective working relationship.
Any other purposes for which we wish to use your personal information that are not listed above, or any other changes we propose to make to the existing purposes, will be notified to you.
7. How we obtain your consent
Where our use of your personal information requires your consent, you can provide such consent:
at the time we collect your personal information following the instructions provided;or
by informing us by email, post or telephone using the contact details set out in the “How to contact us” section above.
8. Transfers outside the eea
Where necessary in order to deliver our services, we will transfer personal information to countries outside the EEA. When doing so, we will comply with our legal and regulatory obligations in relation to the personal information including having a lawful basis for transferring personal information and putting appropriate safeguards in place to ensure an adequate level of protection for the personal information.
9. How long we keep your personal information
Regarding personal information we have processed in connection with the supply of our products and services to any client or receipt of services from a supplier, we will retain personal information relevant to that transaction for six years from the date of supply and in compliance with our obligations under the EU General Data Protection Regulation (or similar legislation around the world). We may then destroy such files without further notice or liability.
Regarding any other personal information we have processed, we will retain relevant personal information for five years from the date of our last interaction with the relevant individual and in compliance with our obligations under the EU General Data Protection Regulation (or similar legislation around the world). We may then destroy such files without further notice or liability.
If any personal information is only useful for a short period (e.g. for a specific marketing campaign), we may delete it at the end of that period.
10. Confidentiality and security of your personal information
We are committed to keeping the personal information you provide to us secure and we will take reasonable precautions to protect your personal information from loss, misuse or alteration.
We have implemented information security policies, rules and technical measures to protect the personal information that we have under our control from:
unauthorised access;
improper use or disclosure;
unauthorised modification; and
unlawful destruction or accidental loss.
All our employees and data processors (i.e. those who process your personal information on our behalf, for the purposes listed above) who have access to and are associated with the processing of personal information are obliged to respect the confidentiality of the personal information of all users of our Site and our Services.
11. How to access your information and your other rights
You have the following rights in relation to the personal information we hold about you:
Your right of access
If you ask us, we will confirm whether we are processing your personal information and, if so, provide you with a copy of that personal information (along with certain other details). If you require additional copies, we may charge a reasonable fee for producing those additional copies.
Your right to rectification
If the personal information we hold about you is inaccurate or incomplete, you are entitled to have it rectified. If we have shared your personal information with others, we will let them know about the rectification where possible. If you ask us, where possible and lawful to do so, we will also tell you who we have shared your personal information with so that you can contact them directly.
Your right to erasure
You can ask us to delete or remove your personal information in some circumstances, such as where we no longer need it or where you withdraw your consent (where applicable). If we have shared your personal information with others, we will let them know about the erasure where possible. If you ask us, where it is possible and lawful for us to do so, we will also tell you who we have shared your personal information with so that you can contact them directly.
Your right to restrict processing
You can ask us to block or suppress the processing of your personal information in certain circumstances, such as where you contest the accuracy of that personal information or you object to us processing it. It won’t stop us from storing your personal information, though. We will tell you before we lift any restriction. If we have shared your personal information with others, we will let them know about the restriction where it is possible for us to do so. If you ask us, where it is possible and lawful for us to do so, we will also tell you who we have shared your personal information with so that you can contact them directly.
Your right to data portability
With effect from 25 May 2018, you have the right, in certain circumstances, to obtain personal information you have provided to us (in a structured, commonly used and machine readable format) and to reuse it elsewhere or to ask us to transfer it to a third party of your choice.
Your right to object
You can ask us to stop processing your personal information, and we will do so, if we are:
relying on our own or someone else's legitimate interest to process your personal information, except if we can demonstrate compelling legal grounds for the processing; or processing your personal information for the purposes of direct marketing.
Your rights in relation to automated decision-making and profiling
We do not undertake automated decision-making and profiling. You have, however, the right not to be subject to a decision when it is based on automatic processing, including profiling, if it produces a legal effect or similarly significantly affects you, unless such profiling is necessary for the entering into, or the performance of, a contract between you and us.
Your right to withdraw consent
If we rely on your consent (or explicit consent) as our legal basis for processing your personal information, you have the right to withdraw that consent at any time. You can exercise your right of withdrawal by contacting us using our contact details in the “How to contact us” section above or by using any other opt-out mechanism we may provide, such as an unsubscribe link in an email.
Your right to lodge a complaint with the supervisory authority
If you have a concern about any aspect of our privacy practices, including the way we have handled your personal information, you can report it to the Information Commissioner’s Office (ICO). You can find details about how to report a concern on the ICO website at https://ico.org.uk/concerns/ or by calling their helpline on 0303 123 1113.
12. Changes to this privacy notice
We may make changes to this Privacy Notice from time to time
To ensure that you are always aware of how we use your personal information we will update this Privacy Notice from time to time to reflect any changes to our use of your personal information. We may also make changes as required to comply with changes in applicable law or regulatory requirements. We will notify you by email of any significant changes. However, we encourage you to review this Privacy Notice periodically to be informed of how we use your personal information.