Privacy Notice

This Dee Set Privacy Notice (“Privacy Notice”) describes how the Dee Set Group of Companies, including Dee Set Logistics Ltd., (“we” or “Dee Set”) collect, use, share and protect personal data when you interact with our websites (www.deeset.co.uk and https://careers.deeset.co.uk/jobs/home/), as well as all of our affiliated websites (www.reapp.co.uk and www.tactical-solutions.co.uk) where this Privacy Notice is posted, and through our interactions with individuals by emails we send, through our social media accounts, over the telephone, and our online services (collectively, our “Services”).

Dee Set Logistics Ltd. is the data controller of the personal data collected under this Privacy Notice.

This Privacy Notice explains the following:

Please note that this Privacy Notice does not apply to non-Dee Set websites or services that state that they are offered under a different privacy notice. Please review the privacy policies on those websites and applications directly to understand their privacy practices.

This Privacy Notice tells you what to expect when the Dee Set Group collects personal data. We may collect personal data about you by the following means:

• Directly from you, such as when you provide information to us or interact with us on our websites, call our helpline, subscribe to our newsletters, request any form of publication from us, apply for a position at Dee Set, or when you make a data protection or freedom of information complaint or enquiry;
• Automatically from you, when you utilize or interact with our Services;
• From service providers who collect information on our behalf in order to provide services to us;
• Through recordings via our CCTV systems; and
• From online advertising companies who may share information about the marketing and advertisements you have seen or clicked on, and from social networks and other sources of publicly available data.

In order to better provide you with our Services, we may collect the following categories of information:

• Contact information and any other information you choose to include when you communicate with us via e-mail, mail, phone, other channels, contact us about an inquiry, call our helpline, subscribe to a newsletter, or make a complaint. Contact information may include your name, job title, employer, email address, phone number, and employer information.
• Device information when you utilize our technology platforms, including as model, serial number, device location, usage data, and operating information, including as described below in the “Online User Activity, Cookies and Information Collected by Other Automated Means” section.
• Online user activity as described in the next section.

Job Application Information
Job application information may be collected by us directly through the Services, or by email, or may be collected on our behalf by our contracted third-party administrator(s) for applicant tracking purposes and our chat-based assessment tool provider(s). Please see the “Use of Automated Decision-Making in Recruitment” section below for more information about our use of chat-based assessment tools. These third-party administrators are permitted to process the information you provide only for purposes of providing services to us. We collect the information you provide to us, such as your name, email address, phone number, address, the content of any comments, your job application (including your work history, reasonable adjustments for interviews, right to work status, type of right to work documentation, any criminal convictions, and Dee Set employee referral information), your CV (including your employment history and other information provided on the CV), information provided during your chat-based interview, scores and profile results generated from the chat-based interview, and any cover letter you provide. For successful job applicants, we will also collect bank account details and other personal and family details. We also collect your personal data when you sign up to receive job alerts, including your email address.

Social Media Information
If you post information on one of our social media platforms, we may use the information to respond, to promote our business and services, and in the normal course of our business operations. We may collect your personal data, such as your social media username, and other personal characteristics that you have made publicly available on the social media website. Note that the third-party operators of social media websites also receive such information, and their use of your personal data is governed by their own privacy policies. If you send us a private or direct message via social media, the message may be stored on the social media platform for up to 3 months.

If you provide us with information regarding another individual, you represent that you have that person’s consent to give us their information and to permit us to use the information in accordance with this Privacy Notice.

Online User Activity, Cookies and Information Collected by Other Automated Means
When you interact with the Services, certain information about your use of our Services is automatically collected. This may include the following types of information: your location, computer or device configuration, IP address and URL of referring website, if any, pages viewed, number of visitors, and length of visits.

Like many websites, we collect information when you use our Services through cookies, web beacons, and other similar technologies, which may be operated by our partners who assist us in serving ads or providing other services to you. Please see our Cookie Notice for more information.

With respect to any social media pages that we may use, please see the privacy policies and any cookie policies of the applicable social media providers as to their automated data collection practices.

We currently use Google Analytics to collect and process certain website usage data.

We use the information we collect from you to:

• Provide our Services to you and to send you related, important notices;
• Respond to your requests, questions, complaints, and comments and provide customer support;
• Evaluate, recruit, and hire personnel, including to provide job applicants with insights and coaching tips based on their chat-based interviews; and
• Comply with legal requirements and industry standards, detect, investigate, and prevent activities that may violate our policies or be fraudulent or illegal, and protect the rights of Dee Set, you, or others.

We will use the contact details you provide to us as a job applicant to contact you to process your application. We will also use the contact details and other information you provide to assess your suitability for the role you have applied for. We do not collect more information than we need to fulfil our stated purposes and will not retain it for longer than is necessary. The information we ask for is used to assess your suitability for employment. You do not have to provide what we ask for, but it may affect our ability to fully assess your suitability for employment.

Transparency and Use of Automated Decision-Making
Within our recruitment process, we use automated decision-making (ADM) in the form of an automated digital chat-based assessment tool to automate the initial filtering of applications based on specific criteria to assist in our hiring process. We will provide you with further information about the system(s) used and the logic involved upon request; for example, after you use the chat-based assessment tool, you will have the opportunity to request your personality profile. The final recruitment decisions are not made by the ADM but by a member of our recruitment team who considers the tool’s output alongside the applicant’s application.

Lawful Bases and Special Categories of Personal Data
We process personal data when using ADM during recruitment in accordance with Article 6(1)(b) of the UK GDPR (the processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract).
We ask that you not provide sensitive data, or special category data (such as information regarding ethnicity, health, political opinions, or trade union membership), in your responses through the chat-based interview.

Safeguards and Rights
Following a hiring decision, job applicants: (1) have the right to obtain human intervention regarding the decision by contacting us with questions or concerns; (2) may express their point of view and contest the decision; and (3) may request a human review. Job applicants can contact us using the information in the “Contact Information” section below.
We strive to maintain transparency about our use of ADM and job applicants’ rights to request a human intervention.

Data Processors
We may share your information with data processors that we believe need the information to perform a technology, business, or other professional function for us such as billing and collection, chat-based interviews for job applicants, IT services, maintenance and hosting of our Services, payment processors, accounting, auditing, and tax services, and other professional services. Data processors also provide elements of our recruitment. We have contracts in place with our data processors. This means that they cannot do anything with your personal data unless we have instructed them to do so. They will not share your personal data with any organisation apart from us. They will hold it securely and retain it for the period we instruct.

Analytics Partners
We partner with analytics providers, who collect information via tracking technologies on our websites to assist us with measuring visits and traffic on our websites so we can measure and improve the performance of the websites.

Affiliates
We share information with other entities in our corporate family, for purposes consistent with this Privacy Notice.

Social Media
If you interact with us on social media platforms, the platform may be able to collect information about you and your interaction with us. If you interact with social media objects on our Services (for example, by clicking on a Facebook “like” button), both the platform and your connections on the platform may be able to view that activity. Note that the third-party operators of social media websites also receive such information, and their use of your personal data is governed by their own privacy policies.

Corporate Event
We reserve the right to transfer to another entity or its affiliates or service providers some or all information about you in connection with, or during negotiations of, any merger, acquisition, sale of assets or any line of business, change in ownership control, or financing transaction. We cannot promise that an acquiring party or the merged entity will have the same privacy practices or treat your information the same as described in this Privacy Notice.

Legal
We share information where necessary to comply with applicable law, to respond to requests from law enforcement agencies or other government authorities or third-parties, as permitted by law and without your consent when it is necessary to protect our customers, employees, or property; in emergency situations; or to enforce our rights under our terms of service and policies.

We retain your personal data for as long as necessary for the purpose for which it was initially collected, to carry out legitimate business interests, as well as on the basis of applicable legal requirements (such as applicable statutes of limitation). After expiry of the applicable retention periods, your personal data will be deleted. If there is any data that we are unable, for technical reasons, to delete entirely from our systems, we will put in place appropriate measures to prevent any further use of such data.

The criteria we use to determine the retention period is as follows:
• Whether there are contractual or legal obligations that exist that require us to retain the data for a period of time;
• Whether there is an ongoing legal claim that relates to any business (or otherwise) relationship you have with us, or that is otherwise related to your relationship with us;
• Whether any applicable law, statute, or regulation allows for a specific retention period; and
• Whether the personal data is considered to be sensitive personal data, in which case a shorter retention period generally would be applied.

These criteria may also mean we adjust the period of time we retain the categories of personal data detailed above.

If you are job applicant who becomes employed by Dee Set, the information you provide during the application process will be retained by us as part of your employee file for the duration of your employment plus for a time period following the end of your employment as may be required by applicable law. This includes your criminal records declaration, fitness to work, records of any security checks and references.

If you are unsuccessful at any stage of the job applicant process, our retention of the information you provided will vary based on the category of data.

We use a combination of physical, technical, and administrative safeguards in an effort to protect the information we collect through the Services. While we use these precautions to safeguard your information, we cannot guarantee the security of the Internet, networks, systems, servers, devices, and databases we operate or that are operated on our behalf.

We do not knowingly or intentionally gather personal data about children who are under the age of 18. If a child has provided us with personal data, a parent or guardian of that child may contact us at dataprotection@deeset.co.uk to have the information deleted from our records. If we learn that we have inadvertently collected the personal data of a child under the minimum age depending on jurisdiction, we will take steps to delete the information as soon as possible and cease the use of that information in accordance with applicable law.

Certain jurisdictions have specific legal requirements and grant privacy rights with respect to personal data, and we will comply with restrictions and any requests you submit as required by applicable law. For example, you may have the right to: (1) obtain a copy of personal data we maintain about you in a portable format; (2) correct inaccuracies or incompletion in your personal data; (3) object to the continued processing or use of your personal data; (4) complain to a supervisory authority; (5) or request that personal data be blocked, anonymized or deleted. You may also have the right to not be discriminated against for exercising your privacy rights. If you are a UK resident see our "Jurisdiction-Specific Notice - UK" section below for additional information as to how to exercise rights under the laws of this jurisdiction.

If you are located outside of this jurisdiction and seek to exercise your rights under the law of another jurisdiction, please contact us by emailing dataprotection@deeset.co.uk.

To help protect your privacy and maintain security, we may take steps to verify your identity before granting you access to the information. We may need to request specific information from you to help us confirm your identity. This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. When you make a request, we may also contact you to ask you for further information in relation to your request to speed up our response and require you to follow procedures so that we can verify your identity (and the applicable jurisdiction). The verification steps we take may differ depending on your jurisdiction and the request. Where possible, we will attempt to match the information that you provide in your request to information we already have on file to verify your identity. If we are able to verify your request, we will process it. If we cannot verify your request, we may ask you for additional information to help us do so.

We will respond to your request within the time period required by applicable law. However, we may not always be able or required to comply with your request, in whole or in part, and we will notify you in that event.

Under the UK Data Protection Act 2018 and the GDPR legislation, you have rights as an individual which you can exercise in relation to the information we hold about you. You can read more about these rights here – https://ico.org.uk/for-the-public/.

This Privacy Notice was drafted with brevity and clarity in mind. It does not provide exhaustive detail of all aspects of the Dee Set Groups collection and use of personal data. However, we are happy to provide any additional information or explanation needed. Any requests for this should be sent to dataprotection@deeset.co.uk.

Lawful Bases for Processing
We typically will process your personal data pursuant to the following lawful bases: (1) with your consent; (2) as necessary to perform our agreement to provide Services to you; or (3) as necessary for our legitimate interests in providing the Services where those interests do not override your fundamental rights and freedoms related to data privacy. We also may process your information where it is necessary to comply with a legal obligation to which we are subject. If you are a job applicant, please see the “Use of Automated Decision-Making in Recruitment” section above for more information that may apply to you.

Rights
• The right to be informed. You are entitled to be informed of the use of your personal data. This Privacy Notice provides such information to you.
• Right of Access: You have the right to request a copy of your personal data which we hold about you.
• Right to Correction: You have the right to request correction or changes of your personal data if it is found to be inaccurate or out of date.
• Right to be Forgotten: You have the right to request us, at any time, to delete your personal data from our servers and to erase your personal data when it is no longer necessary for us to retain such data. Note, however, that deletion of your personal data will likely impact your ability to use our services.
• Right to Restriction of Processing: You have the right to restrict our processing of your personal data. This enables you to ask us to suspend the processing of your personal data in one of the following scenarios:
       o If you want us to establish the data’s accuracy;
       o Where our use of the data is unlawful but you do not want us to erase it;
       o Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
       o You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
• Right to Data Portability: You have the right to a “portable” copy of personal data that you have submitted to us. Generally, this means your right to request that we move, copy or transmit your personal data stored on our servers / IT environment to another service provider’s servers / IT environment.
• Right to Object (opt-out): You have the right to opt-out of certain uses of your personal data, such as direct marketing, at any time.
• Right to Refuse to be Subjected to Automated Decision-Making, including Profiling. You have the right not to be subject to a decision and insist on human intervention if the decision is based on automated processing and produces a legal effect or a similarly significant effect on you
• Right to Withdraw Consent: If we are processing your personal data based on your consent, you have the right to withdraw your consent at any time.
• Right to Lodge a Complaint with a Supervisory Authority. You have the right to lodge a complaint about our data collection and processing actions with the supervisory authority concerned. You can make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues (www.ico.org.uk).

To submit a request to exercise your rights, please email us at dataprotection@deeset.co.uk. We may have a reason under the law why we do not have to comply with your request, or may comply with it in a more limited way than you anticipated. If we do, we will explain that to you in our response.

In some cases, our ability to uphold these rights for you may depend upon our obligations to process personal data for security, safety, fraud prevention reasons, compliance with regulatory or legal requirements, or because processing is necessary to deliver the services you have requested. Where this is the case, we will inform you of specific details in response to your request.

Dee Set is a part of a global service, and transferring data internationally is essential to the Services provided to our customers. If you use our Services, you understand that we may transfer your personal data outside of your home jurisdiction, including to the United States and other countries that may not have the same level of protection for personal data.

Dee Set complies with laws governing the international transfer of personal data, typically through the execution of legally required data protection agreements incorporating, where applicable, standard contractual clauses, or other instructions or measures that may be specified, updated, amended, replaced or superseded from time to time by the applicable regulatory authority.

Dee Set’s websites may contain links to webpages operated by parties other than Dee Set. We do not control such websites and are not responsible for their contents or the privacy policies or other practices of such websites. Our inclusion of links to such websites does not imply any endorsement of the material on such websites or any association with their operators. This Privacy Notice only applies to Dee Set’s websites.

We may make changes to this Privacy Notice from time to time. The “Effective Date” at the top of this page indicates when this Privacy Notice was last revised. If we make any material changes, we will provide notice of such changes on the pertinent website for a reasonable period of time. We may also notify you in other ways from time to time about the collection, use, and disclosure of your personal data described in this Privacy Notice. We encourage you to review this Privacy Notice periodically, especially if you don’t use the Services regularly.

If you want to request information about our Privacy Nolicy you can:

Dee Set Data Protection Team
The Distribution Centre,
Victoria Road,
Fenton,
Stoke on Trent,
ST4 2HX