Last Updated: 27/08/2026
1. Purpose
Davies Shared Services India Private Limited is the Indian subsidiary of Davies Group Limited, whose registered office is in the United Kingdom. Davies Shared Service India Private Limited (hereinafter referred to as ‘DSSI’) is committed to being transparent about how it processes your personal data.
The purpose of this notice is to outline how we will collect, hold, process, and share your personal data throughout the recruitment and selection process.
The objective of this notice is to ensure transparency in personal data handling and maintain compliance with relevant data protection regulations, such as Indian Digital Personal Data Protection Act (DPDPA), Information Technology Act (“IT Act”) and the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules (“SPDI Rules”).
This notice is in furtherance and supplemental to our privacy policy, which can be accessed at Davies Group website.
2. Scope
This Privacy Notice applies to all Davies entities, including all regulated entities, in the following territories:
| Jurisdiction |
| India |
In this Privacy Notice, the terms ‘we’, ‘our’ or ‘us’ are used to refer to DSSI, who are the data fiduciary responsible for processing your personal data.
3. Definitions
The following key terms and definitions are used in this Privacy Notice and should be interpreted in accordance with applicable privacy and data protection laws.
| Application | Means an application made for any job, role, or opportunity-whether permanent or temporary at DSSI, submitted directly or indirectly through any channel (including email, career portals, recruitment agencies, or referrals). |
| Opportunity | Refers to any job role, position, or work requirement that is advertised by, or available with DSSI. |
| Personal Data | Information relating to an identified or identifiable individual, such as name, address, or job details etc. |
| Special Categories of Data | Sensitive information including health, race, ethnicity, and criminal records. |
| Data Fiduciary | Entity responsible for determining how personal data is processed. |
| Data Retention | The practice of keeping data for a specified period, defined by legal and business requirements, after which it is securely deleted. |
| Data Principal | The individual to whom the personal data relates. |
| Data Principal Rights | User rights under data protection regulations, including access, correction, deletion, and restriction of their personal data. |
| International Transfers | Movement of personal data outside the India under strict security controls to ensure compliance with data protection standards. |
4. The types of personal data we collect
We may collect and process a range of information about you during the recruitment and selection process, including information that you choose to share with us. This may include your:
• Name, address, contact details (including email address and mobile / telephone numbers), government ID proof(s) such as Aadhar/ PAN card/ Passport/ Voter ID card etc, photograph(s), work permit/ visa status, nationality/ citizenship, ethnicity, sex, place of birth, religion.
• Recruitment information, including copies of your right to work documentation, references and other information included in your CV, cover letter or application form as part of the application process.
• Employment records, including job titles, work history, previous salary information, leave date and reason for leaving, working hours, holidays, willingness to relocate, or other job preferences, bank account details, training records and professional memberships.
• Records of your communication with us during the recruitment and selection process, including emails you send to our Recruitment Team.
• A recording of your interview(s), if carried out remotely via Microsoft Teams, or any other online platform.
• If you visit a DSSI site where security cameras are in use, your presence, location, and activities within the premises may be observed or recorded through CCTV systems for security purposes.
• Records relating to any pre-employment checks we conduct for you, such as credit and/or criminal record checks.
• Psychometric testing data.
• Information received through reference checks or background verification, where applicable, including details shared by third-party agencies.
• Details about how you came to know about the role, such as referrals, job portals, or information shared by someone who referred you.
• Information related to any previous job applications you may have submitted to us or any past employment with the organisation.
• Online identifiers: When you browse our website, we use cookies to collect usage data, which may include, but is not limited to, your IP address, browser type/version, browsing behaviour on our site (including the pages that you visit, the time spent on those pages and the date and time of your visit) and your geolocation data. More information about the types of cookies we use and our reasons for using them can be in our Cookie Policy.
• Any other information you voluntarily choose to share with us as part of your application.
DSSI may also collect, store, and use the following ‘special categories’ of personal data about you:
• Information about your medical or health conditions, including whether or not you have a disability or other underlying conditions for which DSSI needs to make reasonable adjustments.
• Information about your health, including any medical condition, health or sickness records, medical information, or health insurance information.
• Information about your criminal convictions and / or offences.
• Information relating to your race or ethnic origin, sexual life and orientation, or your religious / philosophical / moral beliefs, where this information is needed to facilitate equal opportunities monitoring.
5. Where we obtain your personal data from
DSSI collects your personal data in a variety of ways. For example, data is collected directly from you through:
• Application forms, CVs or resumes.
• Your identity documents.
• Forms completed by you as part of the recruitment and selection process.
• Correspondence and conversations we have with you.
• Information you enter into our systems as part of the recruitment and selection process.
• Interviews, meetings, and other assessments.
We may also request information about you from third parties, including (but not limited to):
• Recruitment companies.
• Background check providers.
• Former employers.
• Credit reference and other agencies, as part of the background checking process.
6. How we use your personal data
DSSI processes your personal data to assess your suitability for a role as part of the recruitment and selection process. This includes activities such as managing job applications, human resources administration, compensation and benefits planning, meeting legal requirements, supporting business operations, and taking steps to enter into an employment contract with you.
In some cases, we may need to process your personal data to ensure that we are complying with our legal obligations. For example, to:
• Verify your entitlement to work.
• Carry out criminal record or other background checks to ensure that you are permitted to undertake the role for which you have applied. We will only collect information relating to criminal convictions where we are legally permitted to do so, however if you refuse to provide any information when requested, we may be unable to recruit you.
• Ensure that we comply with our duties in relation to candidates with disabilities or underlying conditions who require reasonable adjustments, and to meet our obligations to you under health and safety law.
• Respond to and defend ourselves against legal claims.
• Ensure meaningful equal opportunities monitoring and reporting.
In other cases, DSSI may have a legitimate interest to process your personal data, such as to ensure effective business management and planning, or to keep adequate records of the recruitment and selection process. Where DSSI relies on its legitimate interests to process your personal data, we will ensure that those interests do not undermine your fundamental rights and freedoms as an individual.
7. Our lawful grounds for processing your personal data
We may collect, use, store, disclose, transfer or otherwise process your personal data for recruitment and selection purposes based on the following grounds:
• Consent: You have provided free, specific, informed, unconditional and unambiguous consent for us to process your personal data for a specified recruitment purpose. You may withdraw your consent at any time by contacting our India Data Protection Officer at dpo.india@davies-group.com. Withdrawal will not affect processing undertaken before your consent was withdrawn.
• Personal Data Voluntarily Provided for Recruitment: You have voluntarily provided your personal data to apply for a position or participate in our recruitment process and have not indicated that you do not consent to its use for that specified purpose. This may include reviewing your application, assessing your suitability, communicating with you, scheduling interviews and progressing your application.
• Compliance with Applicable Law or Legal Proceedings: We may process or disclose your personal data where necessary to fulfil an obligation under Indian law or comply with a judgment, decree or order issued under applicable law.
• Employment-Related Purposes: If you are offered and accept employment with DSSI, we may process your personal data for employment-related purposes, including onboarding, providing employment services or benefits, protecting confidential information and safeguarding DSSI from loss or liability.
8. Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
Please note – we may process your personal data without your knowledge or consent in compliance with the above rules, where this is required or permitted by applicable law. For example, where the processing relates to the detection and prevention of crime.
9. Automated decision-making
We may use automated tools, such as Applicant Tracking Systems (ATS), to manage, organise and support the review and shortlisting of applications. These tools assist our recruitment team, but we do not currently make final recruitment decisions based solely on automated processing without meaningful human involvement.
DSSI will not process your personal data for any purpose other than the recruitment and selection process, except where required or permitted by applicable law or regulatory obligations.
10. Who we share your personal data with
Your personal data will be shared internally within DSSI with those colleagues who need it to carry out their roles, including (but not limited to) members of the Recruitment Team and the recruitment panel for the role for which you have applied. We may share your personal information with DSSI’s affiliates under common ownership or control. This is done to support recruitment and evaluation of job applicants, resource planning, talent management, and other legitimate business purposes, including human resources administration and general business operations.
We may also share your personal data with selected third parties who are external to DSSI, for example where it is necessary:
• To obtain pre-employment references from your past employer(s).
• To carry out pre-employment background checks, including credit and criminal record checks.
• To obtain confirmation from regulators of all necessary regulatory permissions, or to otherwise make appropriate notifications to regulators, where it is a requirement of the role for which you have applied.
• To obtain the services of third-party service providers who carry out activities, provide services, or undertake business operations on DSSI’s behalf.
In any such cases, the data we share will be limited to that which is strictly necessary and will be subject to appropriate contractual and confidentiality arrangements being in place.
Additionally, all of our third-party service providers are required to take appropriate security measures to protect your personal data, in line with DSSI policies, and we do not allow them to use your personal data for their own purposes under any circumstances.
11. International transfers
Davies Group operates internationally and personal data may be transferred to, accessed from, or processed in countries other than the country in which it was collected, including by Davies Group entities, and authorised third-party service providers.
Where we transfer, disclose, store, or otherwise make personal data available outside the country in which it was collected, we will take appropriate steps to protect that data in accordance with applicable data protection laws. These steps may include:
• conducting due diligence on overseas recipients and service providers;
• relying on adequacy decisions, recognised comparable protection mechanisms, or equivalent legal safeguards where available;
• entering into appropriate contractual arrangements, such as standard contractual clauses, model contract clauses, intra-group transfer arrangements, data processing agreements, or other equivalent contractual protections;
• carrying out transfer risk assessments where required or appropriate;
• implementing supplementary technical and organisational measures;
• ensuring overseas recipients are required to protect personal data to a standard that is comparable or equivalent to the protection required under applicable data protection laws;
• limiting overseas transfers to what is necessary for the relevant purpose.
If you would like to understand more about this, please send an email outlining your query to DPO@davies-group.com.
For a list of Davies Group subsidiaries and legal entities, please refer to our Global Privacy Notice.
12. How long we keep your personal data for
We will retain your personal information for as long as necessary to process your application or as required by applicable law. Typically, unsuccessful applications are retained for up to 1 year from the date of your application. If you are offered a role and choose to join us, the information collected during your application and recruitment process will form part of your employment records and will be kept only for as long as required for business or legal purposes. In all cases, personal information will be securely deleted or anonymized once it is no longer needed, unless retention is required by law or for legitimate business purposes.
If you require any further information, this can be obtained by contacting the Recruitment Team.
13. How we keep your data secure
Davies Group has implemented an Information Security Management System (ISMS), which is globally certified to the International Organization for Standardization (ISO) 27001 standard for Information Security. This demonstrates our commitment to managing risks related to the security of the personal data we own and handle. We implement a range of technical, organisational, and physical security measures aligned with industry standards to protect your personal data from loss, misuse, unauthorised access, disclosure, alteration, or destruction. Our robust controls, policies, and procedures ensure that only authorised personnel have access to your information, maintaining its security throughout its lifecycle. These measures are further supported by an internal audit function and annual external certification.
14. Your rights
Under Indian data protection laws, you may be able to exercise several individual rights, including:
• Right to access: You have the right to access the personal data we hold about you and receive information about how it is being processed.
• Right to correction: You have the right to correct or update any inaccurate or incomplete personal data.
• Right to erasure (deletion): You have the right to request deletion of your personal data when it is no longer necessary for the purpose it was collected, unless retention is required by law or for legitimate business purposes.
• Right to withdraw consent: You have the right to withdraw consent for the processing of your personal data at any time, where processing is based on consent. If you choose to withdraw your consent for us to collect, store, process, use, or transfer your personal information, please note that without certain information, DSSI may not be able to continue processing your application.
• Right to nominate: You have the right to nominate another person to exercise your rights on your behalf in case of your death, incapacity, or inability.
• Right to grievance redressal: You have the right to raise grievances or complaints with us regarding the processing of your personal data and escalate unresolved concerns to the Data Protection Board of India.
To exercise any of the rights outlined above, please contact us at SAR@davies-group.com. We may request specific information from you to confirm your identity and to help us respond to your request securely.
We may refuse or restrict a request where permitted by applicable law, including where the request is unrelated to the rights available under applicable law, excessively repetitive, conflicts with judicial procedures or investigations, may negatively affects the privacy or confidentiality of personal data relating to others, or where we are required or permitted to retain or continue processing the personal data under applicable laws.
15. How to complain
We are committed to protecting your personal data and addressing any privacy-related concerns promptly and fairly. If you have any concerns about our use of your personal information, you can make a complaint to DSSI’s Data Protection Officer by emailing dpo.india@davies-group.com and DPO@davies-group.com
Whilst we hope we can resolve any concerns between us, you also have the right to lodge a complaint with the supervisory authority in the country where you work, or where you consider any data protection rules to have been breached. If you are in India, this would be the Data Protection Board of India. Information about the Data Protection Board of India and its official complaint-submission mechanism will be available through the official channels published by the Government of India.
For information concerning India’s data protection framework, please visit the Ministry of Electronics and Information Technology website: https://www.meity.gov.in/
16. Contact us
Our Group Data Protection Officer is Adam B Smith. Atul Karale acts as our India Data Protection Officer and privacy contact.
If you have any questions about this Privacy Notice or how we process your personal data, wish to exercise your rights, or raise a privacy-related concern or grievance, please contact:
• India Data Protection Officer and Privacy Contact: dpo.india@davies-group.com
• Group Data Protection Officer: DPO@davies-group.com
We will review and respond to your request or grievance in accordance with applicable Indian data protection laws.
17. Changes to this privacy notice
We reserve the right to update this Privacy Notice at any time, and we will provide you with a copy of the updated Privacy Notice (displayed electronically) when we make any substantial changes. We may also notify you in other ways from time to time about changes to the processing of your personal data.
18. Acknowledgement of this notice
By applying for a role with us or continuing with your candidature through our career’s portal or any other channel, you confirm that you have read and understood this Privacy Notice and how we handle your personal data as part of the recruitment process.
Where you apply through a third-party job platform, recruitment partner, or similar service provider, your application may also be subject to that party’s own privacy practices. Such platforms may retain your personal data and may share relevant updates with us in connection with your application. Any processing carried out by these third parties will be governed by their respective privacy notices.