PRIVACY & COOKIES NOTICE
In summary (for those who don’t want to read the whole document):
Your data will only be used for recruitment purposes
We will request your permission before sharing your details with prospective employers/employees
We will store the data from your CV and/or of any communications between us
We store your data with partners that are SOC 3, PCI DSS 3.2, ISO 9001, ISO 27001, ISO 27017 and ISO 27018 ISO 27001 and ISO 27018 certified
You are entitled and welcome to request your data from us at any time
Human Talent and Training respect and value the privacy of all of our Candidates and Clients and will only collect and use personal data in ways that are described here, and in a way that are consistent with our obligations and your rights under the law.
1. Information About Us
Human Talent and Training Limited.
Registered in England under company number 10984188.
Registered address: 8 High street, Heathfield, East Sussex, TN21 8LS.
VAT number: 279566344.
Data Protection Officer: Chris Yea.
Email address: firstname.lastname@example.org.
Telephone number: 01435 865000.
2. What Does This Notice Cover?
This Privacy Information explains how we use your personal data: how it is collected, how it is held, and how it is processed. It also explains your rights under the law relating to your personal data.
3. What is Personal Data?
Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.
Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.
The personal data that we use is set out in Part 5, below.
4. What Are My Rights?
Under the GDPR, you have the following rights, which we will always work to uphold:
a) The right to be informed about our collection and use of your personal data. This Privacy Notice should tell you everything you need to know, but you can always contact us to find out more or to ask any questions using the details in Part 11.
b) The right to access the personal data we hold about you. Part 10 will tell you how to do this.
c) The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in Part 11 to find out more.
d) The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we have. Please contact us using the details in Part 11 to find out more.
e) The right to restrict (i.e. prevent) the processing of your personal data.
f) The right to object to us using your personal data for a particular purpose or purposes.
g) The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.
h) Rights relating to automated decision-making and profiling. Part 6 explains more about how we use your personal data, including automated decision-making and profiling.
For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Part 11.
Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.
If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office.
5. What Is the Personal Data You Collect And Where Does It Come From?
We may collect some or all of the following personal data (this may vary according to your relationship with us.
Professional experience and work history
Education & Training
Job preferences including role, geographical areas and salary
A log of our communications with you by email and telephone
In the case of placing you in a job or contract we may collect some or all of the following personal data
Passport; and when relevant permits and visas
National insurance number
Full details of job offer and subsequent placement
When a job offer dictates we may also hold results of security checks
Your personal data will come to us from the following source
Your application to a job through a job board, social media
We match your experience and skills through a CV database/job board or social media
Personal or professional recommendation
6. How Do You Use My Personal Data?
Under the GDPR, we must always have a lawful basis for using personal data. This may be because the data is necessary for our performance as an employment business / agency to find you suitable work whether on a contract or permanent basis, because you have consented to our use of your personal data, or because it is in our legitimate business interests to use it. Your personal data may be used for one of the following purposes:
To match your requirements, skills and experience with job vacancies so that we can assist in finding positions that most suit you
With your permission to put forward your details to our clients and prospective employers for you to be considered for vacancies
To keep you informed of the services offered by us
To place you with our clients and prospective employers
To keep you informed of available opportunities as they arise
To establish that you have the right to work
How Long Will You Keep My Personal Data?
We will not keep your personal data for any longer than 3 years, at which point we will contact you to obtain consent to continue storing your data. Except in the following circumstance;
By law, we have to keep basic information about our customers and candidates placed (including Contact, Identity, Financial and Transaction Data) for six years after they cease being a customer or candidate for tax and contractual purposes.
8. How and Where Do You Store or Transfer My Personal Data?
We store your personal data in the UK with our IT partner HiringBoss Holdings Pt Ltd. All records are encrypted using AES-256 and only accessible using the HiringBoss Holdings solution Vincere. Your personal data is self-contained within the Database so only accessible with a valid username and password which are regularly reviewed.
We may from time to time transfer some of your data for processing to our partners for our marketing or accounting or other business purposes. These partners share our respect for the protection of your data and are part of the EU-US Privacy Shield. This requires that our partners provide data protection to standards similar to those in Europe. More information is available from the European Commission.
9. Do You Share My Personal Data?
We will only share your personal data gathered from your CV and our communications with your prior consent to prospective employers and clients. We will not share your personal data with any third parties for any purposes, subject to one important exception.
In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.
If any of your personal data is required by a third party, as described above, we will take steps to ensure that your personal data is handled safely, securely, and in accordance with your rights, our obligations, and the third party’s obligations under the law, as described above in Part 8.
If any personal data is transferred outside of the EEA, we will take suitable steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the GDPR, as explained above in Part 8.
10. How Can I Access My Personal Data?
If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.
All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 11.
There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.
We will respond to your subject access request in less than one month and, in any case, not more than one month of receiving it. Normally, we aim to provide a complete response, including access online to your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.
11. How Do I Contact You?
To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the following details for the attention of Chris Yea:
Email address: email@example.com.
Telephone number: 01435 865000.
Postal Address: 8 High street, Heathfield, East Sussex, TN21 8LS.
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13. Changes to this Privacy Notice
We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection.