Privacy statement
1. Introduction
This Privacy Policy contains important information about who we are, how and why we collect, store, use and share your personal information and your rights in relation to your personal information. Please read it carefully. The types of personal information that we collect and our uses of that personal information will depend on your relationship with us.
Delaware Digital LLP is a UK Limited Liability Partnership whose registered office is at 83 Baker Street, London W1U 6AG (delaware). To enable us to provide our services, to provide information about the services we offer and to deal with any queries or complaints that might arise, we need to collect and use certain personal information about you. For the purposes of data protection legislation, this means we are a data controller and we are responsible for complying with data protection legislation and keeping your personal information safe and secure.
In this Privacy Policy, we use the terms “we”, “us” and “our” to refer to Delaware. Our contact details are set out towards the end of this Privacy Policy and you can find out further information about us at https://www.delaware.co.uk/en-GB/About-us.
The personal information we collect about you and our uses of that personal information will depend on your relationship with us. In order to make this privacy policy as user friendly as possible, we have split parts of it into the following different sections:
- current and prospective customers
- business partners and suppliers
- website users
- event attendees
- information purchased from third parties (Marketing Leads).
- job applicants
Please refer to the sections that apply to you.
If you provide personal information to us about other individuals (for example your employees) we will also be data controller of, and responsible for, their personal information. Please refer them to this Privacy Policy so that they understand how we will use their personal information.
2. Collection, use and sharing of your personal information
2.1 Current and Prospective Customers
Collection of your personal information
If you are a customer or a prospective customer, the personal information we collect will include:
- your name, your address and contact details (including telephone number and email address)
- your job title and details of the company you work for
- information about any services we provide to you
- details of any feedback you give us
- any additional personal information that you give us or we obtain in connection with our provision of services, you attending our offices or any meetings or events or our business relationship.
We collect most of your personal information directly from you, however we may also collect it from:
- publicly accessible sources including Companies House and LinkedIn
- third parties such as customer due diligence providers, sanctions screening providers and commercial credit reference agencies
- cookies and tracking technologies on our website, within our emails or other communication channels. You can access a copy of our cookie policy at /en-GB/About-Us/Cookie-policy.
Use of your personal information
We may use your personal information for a number of different purposes. In each case, we must have a legal ground to do so. We will rely on the following legal grounds when we process your personal information:
- we need to use your personal information to enter into a contract with you or to perform a contract that we have in place with you (e.g. we need to use your personal information to deliver services to you)
- we have a legitimate interest in using your personal information (e.g. to keep business and accounting records, to manage our business operations, to develop and improve our services) - when using your personal information for these purposes, we will assess our need to use your personal information against your rights to privacy to ensure that we are protecting your rights and interests
- we have a legal obligation to use your personal information (e.g. prevention of fraud, anti-bribery due diligence, economic sanctions background check)
- we have your consent.
The following table sets out the legal grounds we rely on for each processing activity:
Purpose for processing | Legal grounds for using your personal information |
To verify your identity |
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To provide our services, fulfil our contractual obligations and generally communicate with you |
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To deal with your enquiries and reply to your requests |
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Managing our business operations such as maintaining business records and accounting records, file keeping, analysing financial and performance results, carrying out internal and external audits, strategic business planning and receiving professional advice (e.g. tax or legal advice) |
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To provide and improve our services |
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To deal with any complaint you may have |
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To notify you of any changes to our services or terms and conditions that may affect you |
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To comply with any applicable legal obligations (e.g. relating to prevention of fraud, anti-bribery and economic sanctions checking) |
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To trace and recover debt |
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To transfer or sell part of our business or re-organise our company structure |
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To send you marketing communications |
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To apply for and claim on our insurance |
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Sharing of your personal information
We may share your personal information with third parties in certain circumstances. These include:
- other companies in the Delaware group, to help us provide and improve our services
- our business partners
- our service providers (e.g. companies providing IT systems, software and support (including cloud service providers), document and information storage provisions, business support services such as marketing agencies, document processing, confidential waste disposal, couriers)
- our professional advisors (e.g. legal counsel, auditors, tax advisors) and professional indemnity insurers (in the event of a claim or potential claim)
- law enforcement agencies, courts, regulators and governmental authorities where we believe this is necessary to comply with our legal or regulatory obligations, to enforce any agreements between you and us, to resolve any dispute or otherwise to protect our rights and the rights of any third party
- selected third parties in connection with any sale, transfer or disposal of our business.
We carry out due diligence on all third party service providers with whom we share your personal information and put in place appropriate contractual protections to protect the confidentiality and use of your personal information.
2.2 Business partners and contacts at suppliers
Collection of your personal information
If you are our business partner or a contact at one of our suppliers or service providers, we will collect:
- your name, your address and contact details (including telephone number and email address)
- your job title and details of the company you work for
- any additional personal information that you give us or we obtain in connection with the provision and procurement of your services.
We collect most of your personal information directly from you, however we may also collect it from publicly accessible sources including LinkedIn.
Use of your personal information
We may use your personal information for a number of different purposes. In each case, we must have a legal ground to do so. We will rely on the following legal grounds, when we process your personal information:
- we need to use your personal information to enter into or perform the contract that we hold with you (e.g. we need to use your personal information to fulfil our contractual obligations and/or procure your services)
- we have a legitimate interest in using your personal information (e.g. to keep business records of all third parties we engage, to review performance of business partners and suppliers and to manage our business operations) - when using your personal information for these purposes, we will assess our need to use your personal information against your rights to privacy to ensure that we are protecting your rights and interests.
The following table sets out the legal grounds we rely on for each processing activity:
Purpose for processing | Legal grounds for using your personal information |
To verify your identity |
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To comply with our contractual obligations for example arranging payment to you |
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To deal with your enquiries and reply to your requests |
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Managing our business operations such as maintaining business records and accounting records, file keeping, analysing financial and performance results, carrying out internal and external audits, strategic business planning and receiving professional advice (e.g. tax or legal advice) |
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To deal with any complaint you may have |
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To notify you of any changes to our terms and conditions that may affect you |
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To comply with any applicable legal obligations (e.g. relating to prevention of fraud, anti-bribery and economic sanctions checking) |
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To trace and recover debt |
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To transfer or sell part of our business or re-organise our company structure |
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To apply for and claim on our insurance |
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Sharing of your personal information
We may share your personal information with third parties in certain circumstances. These include:
- if you are a business partner of or supplier to other Delaware group companies as well as to Delaware, those other Delaware group companies for the purposes of monitoring, enhancing and streamlining the arrangements in place between you and us
- our service providers (e.g. companies providing IT systems, software and support, document and information storage provisions, business support services such as marketing agencies, document processing, confidential waste disposal, couriers)
- our professional advisors (e.g. legal counsel, auditors, tax advisors) and professional indemnity insurers (in the event of a claim or potential claim)
- law enforcement agencies, courts, regulators and governmental authorities where we believe this is necessary to comply with our legal or regulatory obligations, to enforce any agreements between you and us, to resolve any dispute or otherwise to protect our rights and the rights of any third party
- selected third parties in connection with any sale, transfer or disposal of our business
We carry out due diligence on all third party service providers with whom we share your personal information and put in place appropriate contractual protections to protect the confidentiality and use of your personal information.
2.3 Website users
Collection of your personal information
If you use our website, then depending on the activities you carry out on our website, the personal information we may collect will include:
- details of your IP address
- details of the pages you visit
- other personal information which is accessible via the device you use to access our website
- details you provide via our “contact us” facility, including your name, your email address, your job title and phone number telephone number and email address
We collect most of your personal information directly from our website, however we may also collect it from cookies and tracking technologies on our website. You can access a copy of our cookie policy here: cookie policy.
Use of your personal information
We may use your personal information for a number of different purposes. In each case, we must have a legal ground to do so. We will rely on the following legal grounds, when we process your personal information:
- we have a legitimate interest in using your personal information (e.g. to respond to your enquiry, to monitor usage of our website and to manage our business operations) - when using your personal information for these purposes, we will assess our need to use your personal information against your rights to privacy to ensure that we are protecting your rights and interests;
- we have your consent (e.g. to send you marketing communications).
The following table sets out the legal grounds we rely on for each processing activity:
Purpose for processing | Legal grounds for using your personal information |
To respond to any enquiries you have submitted |
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To monitor usage of our website |
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To send you marketing communications |
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Sharing of your personal information
We may share your personal information with third parties in certain circumstances. These include:
- other companies in the Delaware group, in order to help us answer your query
- our business partners
- our service providers (e.g. companies providing IT systems, website providers and software and support)
- web analytics providers
We carry out due diligence on all third party service providers with whom we share your personal information and put in place appropriate contractual protections to protect the confidentiality and use of your personal information.
2.4 Event attendees
Collection of your personal information
If you register to attend or attend an event which we host or sponsor, the personal information we may collect will include:
- your name, your address and contact details (including telephone number and email address)
- your job title and details of the company you work for
Use of your personal information
We will use your information to interact with you about the event register for and/or attend and to send you information about our services, Delaware news, invitations to events and other communications which we think you may be interested in. The legal ground on which we will rely when doing this is that we have a legitimate interest in generating new business with you.
Sharing of your personal information
We may share your personal information with our service providers (e.g. companies providing marketing services, IT systems, software and support). We carry out due diligence on all third party service providers with whom we share your personal information and put in place appropriate contractual protections to protect the confidentiality and use of your personal information.
2.5 Marketing Leads
From time to time we purchase personal information from a third party for inclusion in our future marketing campaigns.
We currently receive personal information for our marketing campaigns from Lead Forensics (www.leadforensics.com/). Please see their privacy policy for details of how your personal information is used and shared by them. This can be found at: https://www.leadforensics.com/privacy-policy/
Collection of your personal information
The personal information we collect will include:
- your name, your business address and contact details (including telephone number and email address)
- your job title and details of the company you work for
Use of your personal information
We will use your information to send you information about our services, Delaware news, invitations to events and other communications which we think you may be interested in. The legal ground on which we will rely when doing this is that we have a legitimate interest in generating new business with you.
Sharing of your personal information
We may share your personal information with our service providers (e.g. companies providing marketing services, IT systems, software and support). We carry out due diligence on all third party service providers with whom we share your personal information and put in place appropriate contractual protections to protect the confidentiality and use of your personal information.
3. Transferring your personal information outside the UK
We may share your personal information outside the United Kingdom(UK) in certain circumstances, including:
- with other companies in the Delaware group
- with your and our service providers located outside the UK
- where there is an international dimension to the services we are providing to you
- if you are based outside the UK
Where we share your personal information with a service provider outside of the UK, we will take appropriate safeguarding measures to ensure that your personal information is secure and protected and we will comply with data protection laws by using one of the following methods:
- transferring personal information only to countries which have been deemed to have adequate levels of data protection.
- putting in place appropriate contractual protections – we will use specific contracts approved for use in the UK which give personal data the same protection it has in the UK.
4. Keeping your personal information secure
We are committed to keeping your personal information secure. We have implemented appropriate information security procedures, 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.
We limit access to your personal information to those who have a genuine business need to know it. Our partners, employees, consultants and third party processors will only process your personal information in an authorised manner and are subject to a duty of confidentiality.
5. Marketing activities
From time to time we may send you information about our services, Delaware news, invitations to events and other communications which we think you may be interested in or which you have provided your consent to receive.
You can opt-out of marketing communications at any time by clicking the “unsubscribe” link at the bottom of any marketing email communication or by contacting us at info@delaware.co.uk.
6. Retaining your personal information
6.1 Customers, business partners and contacts at suppliers
We will keep your personal information for as long as we have a relationship with you. Once our relationship with you has come to an end, we will retain your personal information for a period of 7 years from the date of our last interaction with you or longer if we are required to do so by law or regulation or by our insurers. We will delete your personal information when we are no longer required to retain it. If there is any information which (for technical reasons) we are unable to delete entirely from our systems, we will put in place appropriate measures to prevent any further processing or use of that information.
6.2 Prospective customers, event attendees and website users
We will keep your personal information for a period of 3 years from the date of our last interaction with you or longer if we are required to do so by law or regulation or by our insurers. We will delete your personal information when we are no longer required to retain it. If there is any information which (for technical reasons) we are unable to delete entirely from our systems, we will put in place appropriate measures to prevent any further processing or use of that information.
6.3 Marketing Leads
We will keep your personal information for as long as we are permitted do so by the third party from whom we purchase it (typically this will be for a period of 1 year) or longer if we are required to do so by law or regulation or by our insurers. We will delete your personal information when we are no longer required to retain it. If there is any information which (for technical reasons) we are unable to delete entirely from our systems, we will put in place appropriate measures to prevent any further processing or use of that information.
7. Automated decision making and profiling
We do not carry out any profiling or automated decision making.
8. Your rights over your personal information
You have a number of important legal rights in respect of the personal information that we hold about you and you can exercise any of them at any time by using the contact details below.
Please note that although we take your rights very seriously, there may be some circumstances where we cannot comply with your request because the right does not apply in those particular circumstances or because complying with it would mean that we are unable to comply with our own legal or regulatory obligations. However we will consider each request carefully and, if we cannot comply with it, we will let you know why not.
- The right to access your personal information – you are entitled to a copy of the personal information that we hold about you and certain information about how we use it. We will usually respond to your subject access request in writing unless you request otherwise. Where your request is made electronically (e.g. by email), a copy of your personal information will be provided to you by electronic means where possible
- The right to require us to correct any mistakes in your personal information – if you believe that the personal information we hold about you is inaccurate or there are any discrepancies or gaps, please let us know and we can update it or amend it to ensure that the personal information we hold about you is accurate and where necessary up to date
- The right to require us to delete your personal information in certain situations for example where we no longer need your personal information for the original purpose which it was collected. When assessing whether we can comply with your request, we will need to take other factors into consideration such as our legal and regulatory obligations to keep your personal information
- The right to receive personal information that you have provided to us in a usable electronic format and/or request that we transmit that personal information to a third party in certain situations
- The right to restrict our use or disclosure of your personal information in certain situations for example where you think that the personal information we hold about you is inaccurate or where you think that we no longer need to use your personal information
- The right to object to our use of your personal information for direct marketing purposes - you can opt-out of marketing communications at any time by contacting us using the details set out below or by clicking the “unsubscribe” link at the bottom of any marketing email communication. Please note that where you exercise this right, we will send you communications which are related to the services we provide to you
- The right to object to processing based on our justifiable purpose – where we have indicated that we rely on a justifiable purpose to process your personal information, you can object to such processing unless our purpose outweighs any prejudice to your right to privacy
- The right to withdraw your consent to our processing of your personal information – where we have indicated that we rely on your consent, you have the right to withdraw such consent
- The right to reconsider a decision taken by automated means – however, we do not currently undertake any automated decision making
- The right to complain about our processing of your personal information to the ICO (UK Information Commissioner’s Office) if you believe that we have breached data protection laws.
For further information on these rights, including the circumstances in which they apply, see the ICO Guidance on individuals’ rights under the GDPR at https://ico.org.uk/. Please note that lodging a complaint will not affect any other legal rights or remedies that you have.
If you would like to exercise any of these rights please email, call or write to us using the details set out in the How to contact us section below. We will contact you if we need additional information from you in order to consider your requests.
9. How to contact us
If you have any queries or concerns about this privacy notice or our use of your personal data or wish to make a complaint please contact us in one of the following ways:
email: info@delaware.co.uk
post: Delaware Digital LLP
83 Baker Street
London
W1U 6AG
Tel: 01174 573 578
If you have a complaint which we are unable to resolve you may lodge your complaint with the UK Information Commissioner: https://ico.org.uk/concerns/ or tel: 0303 123 1113.
Privacy Notice - Recruitment
Last updated: August 2023
Introduction
We are committed to protecting the personal information of our candidates. This Privacy Policy contains important information about who we are, how and why we collect, store, use and share your personal information and your rights in relation to your personal information. Please read it carefully. If you have any questions about this policy, please contact a member of our HR team.
For the purposes of data protection legislation, Delaware Digital LLP, a UK Limited Liability Partnership whose registered office is at 83 Baker Street, London W1U 6AG (Delaware) is a data controller and collects and uses certain personal information about you in connection with your application and our recruitment processes. In this Privacy Policy, we use the terms “we”, “us” and “our” to refer to Delaware. Our contact details are set out towards the end of this Privacy Policy and you can find out further information about us here.
Collection of your personal information
If you apply for a job with us or are otherwise in touch with us about potential opportunities to work for us we will collect certain personal information about you. This information may include:
- your name, home address, personal phone numbers and personal email addresses and any business contact details you provide to us
- your current job title, role details and department you work in
- your cv, including details of your education, employment history, academic and professional qualifications and memberships (including degrees awarded and transcripts), salary/pay details and similar information that you may provide to us
- information collected during phone and/or video screenings and interviews
- your professional bio including any professional social media profile (e.g. LinkedIn profile)
- personal information in references about you that we receive from others (e.g. former employers and/or educational institutions)
- documents evidencing your right to work including information about your nationality and immigration status and information from those documents, such as your passport or other identification number
- details revealed by security screening and background checks undertaken on certain roles and/or for certain assignments (including address history, credit check results, employer/educational institution references)
- personal information in applications you have made for other positions within Delaware or with one of our affiliated entities
- any other personal data which you otherwise voluntarily provide
- information gathered through the monitoring of our IT systems and building access records in relation to your communications with us and attendance at our premises.
The majority of the personal information to be provided by you is mandatory in connection with our recruiting activities. Failure to provide mandatory personal information may affect our ability to accomplish the purposes stated in this Privacy Policy, including considering your suitability for employment with us or engagement by us and/or entering into an employment contract or contract for services with you.
We collect the majority of this personal information from you but also collect some information from third parties such as recruitment agencies, background screening service providers, your referees, your education providers, any relevant professional bodies, official bodies (such as the Home Office), credit reference agencies and relevant publicly accessible sources (e.g. Linked In). We may collect this information ourselves or via a third party agency we instruct to carry out recruitment and/or screening. If you are applying for a post as a contractor or intern we may not collect all of the categories of personal information listed above.
Referencing and Vetting
As part of our referencing and vetting procedures, we will contact certain third parties in order to verify your personal information (including personal information that you provide as part of the application and recruitment process). These third parties will include:
- former employers in order to verify your previous employment history
- universities and/or other establishments for higher education that you attended in order to verify your education history
- credit reference agencies in order to check your credit history.
We will only seek this information in relation to successful candidates that have accepted a conditional offer of employment with us or engagement by us and we will specifically inform such candidates that we will be contacting these third parties in advance of doing so.
Use of your personal data
We use your personal information for a variety of purposes including to:
- verify your identity and candidate information and carry out employment, background and reference checks, where applicable and in order to prevent fraud
- identify and evaluate applicants, including to assess suitability as an employee or contractor
- communicate with you about the recruitment process and your application
- comply with any applicable legal or regulatory obligations
- assist with and enhance our recruitment process.
In addition to using your personal information to consider you for the role you applied for, we will process your personal information to inform you about and to consider you for other roles that may be appropriate for you. If you do not want us to consider you for other roles which we consider may be appropriate for you, please inform a member of our Recruitment team.
Legal basis for processing
When we collect and use your personal information we are required to have a legal basis for doing so. There are various different legal bases upon which we may rely, depending on what personal information we process and why.
In most cases, the legal basis will be one of the following:
- to perform a contract with you or to take steps to enter into a contract (e.g. employment contract or contract for services)
- to meet our legitimate interests or those of a third party (e.g. a recruiter who has introduced you to us)
- to comply with our legal obligations (e.g. to check your right to work in the UK or to comply with legal requirements relating to disabled applicants).
If we have asked for your consent to process your personal information, you may withdraw your consent at any time by emailing info@delaware.co.uk
Special categories of personal data
Certain categories of data including health are considered "special categories of personal data" and are subject to additional safeguards.
We will always treat special categories of personal data as confidential and will only share such data internally where there is a specific and legitimate purpose to do so. We have also implemented appropriate physical, technical, and organisational security measures designed to secure your personal information against accidental loss and unauthorised access, use, alteration, or disclosure.
We will only process information about your physical or mental health in compliance with our legal obligations to disabled applicants.
If you are successful in your application, any health information processed as part of the recruitment process that is relevant to our compliance with our obligations in connection with your employment with us or engagement by us will be retained and processed in accordance with our Employee Privacy Notice.
If you are unsuccessful in your application, any health information obtained as part of recruitment process will be deleted, together with the rest of your personal data, within 12 months of your last interaction with Delaware.
Sharing your personal information
In certain circumstances, we may need to share some of your personal information with other parties, such as our affiliated entities (the Delaware group), clients to whom you may be being recruited to provide services, third party service providers (including recruitment agencies, background screening agencies, and occupational health providers), relevant government bodies and our professional advisers such as our insurers and lawyers.
Outside the Delaware group and with the exception of regulators or other government bodies, your personal information will only be shared under the terms of a written agreement between us and the third party which includes appropriate security measures to protect the personal information in line with this policy and our obligations. The third parties are permitted to use the personal information only for the purposes which we have identified, and not for their own purposes, and they are not permitted to further share the data without our express permission or as required by law.
Your personal information may be held at our offices and at those of our group entities, third party service providers etc. with whom we share your personal information. We may, in certain circumstances transfer your personal information outside the UK. In all cases, where your personal information is transferred to a third party in a country which is deemed not to have the same level of protection for personal data as the UK, we will ensure that adequate safeguards are in place to protect your personal information.
Keeping your personal information secure
We are committed to keeping your personal information secure. We have implemented appropriate information security procedures, 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.
We limit access to your personal information to those who have a genuine business need to know it. Our partners, employees, contractors, group entities, clients and third party processors may only process your personal information in an authorised manner and are subject to a duty of confidentiality.
Retaining your personal information
If you successfully apply for a position with us, we will keep your personal information in accordance with our Employee Privacy Policy. If you would like to request a copy of this please contact a member of our HR team.
If you are unsuccessful in your application, we will keep your personal information for no longer than 12 months from the date of your last interaction with Delaware. If there is any information which (for technical reasons) we are unable to delete entirely from our systems, we will put in place appropriate measures to prevent any further processing or use of that information.
Your rights in relation to your personal information
We will always seek to process your personal information in accordance with our obligations and your rights.
You will not be subject to decisions based solely on automated data processing without your prior consent.
In certain circumstances, you have the right to seek the erasure or correction of your personal information, to object to particular aspects of how your personal information is processed, and otherwise to seek the restriction of the processing of your personal information. You also have the right to request the transfer of your personal information to another party in a commonly used format. If you have any questions about these rights, please contact a member of our Recruitment team.
You have a separate right of access to your personal data processed by us. You may be asked for information to confirm your identity and/or to assist us to locate the data you are seeking as part of our response to your request. If you wish to exercise your right of access you should set out your request in writing to our Recruitment team.
How to complain
If you have any questions about this policy or any concerns about our collection, use or sharing of your personal information, please contact a member of our Recruitment team.
We hope that we can resolve any query or concern you raise about our use of your personal information. If not, contact the UK Information Commissioner’s Office at ico.org.uk/concerns/ or telephone: 0303 123 1113 for further information about your rights and how to make a formal complaint.