REGULATION IN BRIEF
The General Data Protection Regulation (“GDPR”) (Regulation (EU) 2016/679) is a regulation which replaces the Data Protection Regulation (Directive 95/46/EC). GDPR aims to harmonise data protection legislation across EU member states, enhancing privacy rights for individuals and providing a strict framework within which commercial organisations can legally collect, retain and use personal information. GDPR has been enforceable in the UK since 25 May 2018.
For the purposes of GDPR, the data controller is Talent for Care Ltd of 20 Marsham Lane, Gerrards Cross, SL9 8EY. For the purposes of this privacy notice, Talent for Care is the Company.
INFORMATION WE MAY COLLECT AND HOLD ABOUT YOU
We collect information about you to carry out activities relating to our core business and ancillary services as a workforce solutions business. You might be:
- A participant in one of our workforce support programs
- A candidate seeking new work opportunities
- A client/care organisation we engage with for recruitment and retention services
- A referee
- A supplier, partner or sub-contractor to support our services
- An employee (permanent, temporary or on a consultant basis)
The information we collect and retain about you may be different depending on who you are, but will typically include name, address, private and/or corporate e-mail address and phone number, position and company details, compliance documentation and references verifying qualifications and experience and right to work in the United Kingdom, curriculum vitae, salary details, links to professional profiles available in the public domain e.g. LinkedIn, Twitter, business Facebook or corporate website, marketing and event interests.
WHY WE COLLECT AND HOLD YOUR INFORMATION
As a workforce solution business we are dedicated to supporting our candidates’ career aspirations and our clients’ workforce needs and as such require a database of candidate and client personal information containing historical information as well as current workforce requirements.
A fundamental and essential process of our business is to introduce candidates to clients for permanent or substantive employment. Using your information in this way is called our Legitimate Business Interest.
We also use your information to:
- Provide you with information and services that you request from us or we think will be of interest to you because it is relevant to your career or to your organisation
- Provide you with information about other goods and services we offer that are similar to those that you have already been provided with or enquired about
- Notify you about changes to our service
- Ensure that content from our website is presented in the most effective manner for you and for your computer
In addition to using your information for our Legitimate Business Interest, we may also rely on contract, legal obligation and consent for specific uses of information:
We will rely on contract if we are negotiating or have entered into a placement agreement with you or your organisation or any other contract to provide services to you or receive services from you or your organisation.
We will rely on legal obligation if we are legally required to hold information about you to fulfil our legal obligations.
We will in some circumstances rely on consent for particular uses of your information and you will be asked for your express consent, if legally required.
Should we want or need to rely on consent to lawfully process your information we will request your consent orally, by email or by an online process for the specific activity we require consent for and record your response on our systems. Where consent is the lawful basis for processing your information, you have the right to withdraw your consent to this particular processing at any time.
HOW WE COLLECT YOUR PERSONAL INFORMATION
We collect personal information from a range of sources, including directly from the information you provide to Talent for Care Ltd or through third parties we may work with such as reference agencies, as well as via our website when you complete an online form, and through a range of other publicly available sources such as social media sites, corporate websites, and LinkedIn.
In the case of information we collect via publicly available sources, we will inform you – within 30 days, but no later than 60 days of collecting the information – that we hold the information, where the information originates from, and for what purpose we intend to retain and process the information. As part of this communication we will ask for your consent to add your information to our database.
In addition to information you may provide by completing an online form or on our website, there is some technical information which is automatically collected each time you visit our website, including (but not limited to) your computer’s IP address, browser type and version, the date and time of your visit, and which pages you visit. This information is collected via cookies.
WE USE THIS TECHNICAL INFORMATION TO:
- Administer our website and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes
- Improve our website to ensure that content is presented in the most effective manner for you and for your computer
- Allow you to participate in interactive features on our website, when you choose to do so
- Keep our website safe and secure
- Make suggestions and recommendations to you and other users of our website about services that may interest you or them
We do not undertake automated decision-making or profiling. We do use our computer systems to search and identify personal data in accordance with parameters set by a person. A person will always be involved in the decision making process.
DISCLOSURE OF PERSONAL INFORMATION
In the course of running our business, we may need to share your personal information with selected third parties either within or outside of the European Economic Area (EEA). Depending on who you are, these third parties may include:
- Any member of our Company both in the EEA and outside of the EEA
- Clients for the purpose of introducing candidates to them
- Candidates for the purpose of arranging interviews and work placements
- References for the purpose of assessing your suitability for a role
- Suppliers or subcontractors to support our services.
- Analytics and search engine providers that assist us in the improvement and optimisation of our website.
We may also disclose your personal information to third parties in the following circumstances:
In the event that we sell or buy any business or assets, in which case we will disclose your personal information to the prospective buyer or seller of such business or assets.
If the Company or substantially all of its assets are acquired by a third party, in which case personal information held by the Company about its candidates and clients will be one of the transferred assets.
The lawful basis for third parties to process your personal information include:
- Their own legitimate business interests
- Satisfaction of their contractual obligations to us as our data processor
- For the purpose of a contract in place or in contemplation
- To fulfil their legal obligations
HOW WE STORE AND PROCESS YOUR PERSONAL INFORMATION
The information that we collect from you may be transferred to, and stored at, a destination outside of the EEA, but within the Company. It may also be transferred to third parties outside of the EEA for the purpose of providing our recruitment services. It may be processed by staff operating outside of the EEA who work for us or for one of our suppliers. This includes staff engaged in, among other things, our recruitment services and the provision of support services. By submitting your personal information, you agree to this transfer, storing or processing. The Company will take all reasonable steps to ensure that your information is treated securely and in accordance with this privacy notice.
All information you provide to us is stored on our secure data repositories.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal information, we cannot guarantee the security of information transmitted to us through our website and any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
RETENTION OF YOUR INFORMATION
We understand our legal duty to retain accurate information and only retain personal information for as long as we need it for our legitimate business interests and that you are happy for us to do so. Accordingly, we have a data retention notice and routinely remove data that we no longer have a legitimate business interest in maintaining.
We try to ensure the information we hold about you is accurate by:
Enabling you to manage your information by contacting our Team at firstname.lastname@example.org and to review whether the details we hold about you are accurate
Enabling you to keep in touch with us so you can let us know of changes to your personal information
The criteria we use to determine whether we should retain your personal information include:
- The nature of the personal information
- The perceived accuracy of the information
- Our legal obligations
- Whether an interview or placement has been arranged
- Our recruitment expertise and knowledge of the industry by country, sector and job role
- Whether you have told us you want to be contacted about future job opportunities
Due to legal obligations, we may archive part or all of your personal information or retain it on our financial systems only, deleting all or part of it from our main Customer Relationship Manager (CRM) system. We may anonymise parts of your information, particularly following a request for suppression or deletion of your information. If your information is deleted we will have no records remaining, so may re-engage with you if your information is available in a public location.
Our current retention notice is available upon request.
YOUR RIGHTS UNDER GDPR
You have the right to ask us not to process your personal information for marketing purposes. We will usually inform you (before holding your information) if we intend to use your information for such purposes or if we intend to disclose your information to any third party for such purposes, and we will collect express consent from you if legally required prior to using your personal information for marketing purposes.
You can exercise your right to accept or prevent such processing by emailing email@example.com and requesting this.
Our website may, from time to time, contain links to and from the websites of our partner networks and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
THE GDPR PROVIDES YOU WITH THE RIGHT TO:
Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.
Request the restriction of processing your personal information. This enables you to ask us to suspend the processing of your personal information, for example if you want us to establish its accuracy or the reason for processing it.
Request the transfer of your personal information to another party in certain formats, if practicable.
Make a complaint. In the first instance we would ask to you to contact us at firstname.lastname@example.org and register the issues, allowing us to respond within 14 days. If you are not satisfied with the response, we suggest you contact a supervisory body, which in the United Kingdom is the Information Commissioner’s Office.
ACCESS TO INFORMATION
GDPR gives you the right to access information held about you.
Your right of access can be exercised in accordance with the Data Protection Act 1998 (and the GDPR once it is in force from 25 May 2018).
A subject access request should be submitted to email@example.com
CHANGES TO OUR PRIVACY NOTICE
Any changes we make to our privacy notice in the future will be posted on this webpage (www.Talentforcare.uk/privacy) and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our privacy notice.
Questions, comments and requests regarding this privacy notice should be addressed to our Team at firstname.lastname@example.org