DSW is committed to providing our clients with a market leading, managed consultancy service that represents total quality and exceptional value for money. Our fulfillment model involves a combination of in house expertise, carefully selected Associates and strategic partners. Accordingly, the provision of our services could involve the collection, use and disclosure of some personal information about our Associates and protecting their personal information is one of our highest priorities.

Whilst we have always respected the privacy of our Associates and safeguarded their personal information, we have further strengthened our commitment to protecting personal information as a result of the Personal Information Protection and Electronic Documents Act (PIPEDA), which sets out the ground rules for how businesses and not-for-profit organisations may collect, use and disclose personal information.

We will inform our Associates of why and how we collect, use and disclose their personal information, obtain their consent where required, and only handle their personal information in a manner that a reasonable person would consider appropriate in the circumstances.

This Personal Information Protection Policy, in compliance with PIPEDA, outlines the principles and practices we will follow in protecting our Associates personal information. Our privacy commitment includes ensuring the accuracy, confidentiality, and security of our Associates personal information and allowing our Associates to request access to, and correction of, their personal information.

Definitions
Personal Information - means information about an identifiable individual. At DSW, this information is usually provided by an Associate in the form of a CV, which typically includes name, address, phone numbers, marital status, email address and work/education history. Personal information does not include contact information (described below).
Contact information - means information that would enable an individual to be contacted at a place of business and includes name, position name or title, business telephone number, business address, business email or business fax number. Contact information is not covered by this policy or PIPEDA.
Privacy Officer - means the individual designated responsibility for ensuring that DSW complies with this policy and PIPEDA.

Collecting Personal Information
Unless the purposes for collecting personal information are obvious and the Associate voluntarily provides his or her personal information for those purposes, we will communicate the purposes for which personal information is being collected, either orally or in writing, before or at the time of collection.
We will only collect information from an Associate that is necessary to fulfill the following purposes:
• To verify past employment; we may collect reference information and past work history information.
• To verify education and professional qualifications; we may collect educational information and contact the institutions, if required.
• To establish trading identity; we will collect information which verifies the trading entity involved, which is usually a private limited company.
• To establish VAT status; we may collect information and request copies of VAT registration documents etc.
• To establish professional indemnity cover; we may collect information and request copies of professional indemnity insurance documentation.
• Associate preferences; we may collect information regarding your preferred roles to carry out and geographical locations you would prefer to work within etc.
• To help establish financial fitness and probity; we may contact credit agencies or similar organisations

Consent
We will obtain Associate consent to collect, use or disclose personal information (except where, as noted below, we are authorised to do so without consent).
Consent can be provided orally, in writing or electronically or it can be implied where the purpose for collecting using or disclosing the personal information would be considered obvious and the Associate voluntarily provides personal information for that purpose.
Subject to certain exceptions (e.g., the personal information is necessary to provide the service or product, or the withdrawal of consent would frustrate the performance of a legal obligation), Associates can withhold or withdraw their consent for DSW to use their personal information in certain ways. An Associate’s decision to withhold or withdraw their consent to certain uses of personal information may restrict our ability to provide a particular service or product. If so, we will explain the situation to assist the Associate in making their decision.
We may collect, use or disclose personal information without an Associate’s knowledge or consent in the following limited circumstance:
The use is clearly in the interests of the individual Associate and consent cannot be obtained in a timely way.

Using and Disclosing Personal Information
We will only use or disclose Associate personal information where necessary to fulfill the purposes identified at the time of collection.
We will not use or disclose Associate personal information for any additional purpose unless we obtain consent to do so.
We will not sell Associate lists or personal information to other/third parties.

Retaining Personal Information
If we use Associate personal information to make a decision that directly affects the Associate, we will retain that personal information for at least one year so that the Associate has a reasonable opportunity to request access to it.
We will retain Associate personal information only as long as necessary to fulfill the identified purposes or a legal or business purpose

Ensuring Accuracy of Personal Information
We will make reasonable efforts to ensure that Associate personal information is accurate and complete where it may be used to make a decision about the Associate or disclosed to another organisation.
Associates may request correction to their personal information in order to ensure its accuracy and completeness. A request to correct personal information must be made in writing and provide sufficient detail to identify the personal information and the correction being sought.
If the personal information is demonstrated to be inaccurate or incomplete, we will correct the information as required and send the corrected information to any organisation to which we disclosed the personal information in the previous year. If the correction is not made, we will note the Associate’s correction request in the file.

Securing Personal Information
We are committed to ensuring the security of Associate personal information in order to protect it from unauthorised access, collection, use, disclosure, copying, modification or disposal or similar risks.
The following security measures will be followed to ensure that Associate personal information is appropriately protected:
• Use of locked filing cabinets
• Physically securing the office
• Restricting employee access to personal information as appropriate
• Passwords on every computer
We will continually review and update our security policies and controls as technology changes to ensure ongoing personal information security.

Providing Associates Access to Personal Information
Associates have a right to access their personal information, subject to limited exceptions.
A request to access personal information must be made in writing and provide sufficient detail to identify the personal information being sought.
Upon request, we will also tell Associates how we use their personal information and to whom it has been disclosed if applicable.
We will make the requested information available within 30 business days, or provide written notice of an extension where additional time is required to fulfill the request.
A minimal fee may be charged for providing access to personal information. Where a fee may apply, we will inform the Associate of the cost and request further direction from the Associate on whether or not we should proceed with the request.
If a request is refused in full or in part, we will notify the Associate in writing, providing the reasons for refusal and the recourse available to the Associate.

Questions and Complaints: The Role of the Privacy Officer or designated individual
The Privacy Officer, is responsible for ensuring DSW’s compliance with this policy and the Personal Information Protection and Electronic Documents Act.
Associates should direct any complaints, concerns or questions regarding DSW compliance in writing to the Privacy Officer.

Attention: Privacy Policy Officer
DSW.
Richmonds House
White Rose Way
Doncaster DN4 5JH