GDPR & Privacy NoticeLast updated September 2022
Privacy Notice – last updated September 2022
“Controllers” are the entities that decide what and how personal data is processed. Employers and recruitment agencies are some examples of controllers.
“Processors” are applicant tracking systems or any legal bodies that process personal data on behalf of a controller.
“Processing” refers to any action that can be performed on personal data, such as collecting, recording, organising, storing, using, and erasing.
Name of organisation:
808 Talent Ltd.
Ben Swanton: firstname.lastname@example.org
Sarah Swanton: email@example.com
It is very important that the information we hold about you is accurate and up to date. Please let us know if at any time your personal information changes by contacting us.
What data do we collect about you, for what purpose and on what grounds do we process it:
Personal data means any information capable of identifying an individual. It does not include anonymised data.
We may process the following categories of personal data about you:
- Recruitment Data:
This data includes any relevant recruitment data which is used for the sole reason to connect you (candidates) to relevant job opportunities. This will be social and professional profile data, education and work experience data, and any relevant salary information. We process recruitment data for the intention of recruitment purposes only, with the intent to contact you within 30 days to assess your suitability for the desired role. If on the occasion, we do not find you suitable for the current role of interest, we may continue to keep your recruitment data on file for up to 12 months. We do this to keep you informed about other similar roles that may arise in future and to provide tailored recruitment opportunities for similar positions. You can opt-out of this anytime, or choose to exercise your other statutory rights concerning the retention of your data.
- Communication Data:
This includes any communication that you provide us whether that be through email, text, social media messaging, social media posting or any other communication that you send us. We process this data for the purposes of communicating with you, for record keeping and for the establishment, pursuance or defence of legal claims. Our lawful ground for this processing is our legitimate interests which in this case are to reply to communications sent to us, to keep records and to establish, pursue or defend legal claims.
- Customer Data:
This includes data relating to any purchases of goods and/or services such as your name, title, billing address, delivery address, email address, phone number, contact details, purchase details and card details. We process this data to supply the goods and/or services you have purchased and to keep records of such transactions. Our lawful ground for this processing is the performance of a contract between you and us and/or taking steps at your request to enter into such a contract.
- User Data:
This includes data about how you use our website and any online services together with any data that you post for publication on our website or through other online services. We process this data to operate our website and ensure relevant content is provided to you, to ensure the security of our website, to maintain back-ups of our website and/or databases and to enable publication and administration of our website, other online services and business. Our lawful ground for this processing is our legitimate interests which in this case are to enable us to properly administer our website and our business.
- Technical Data:
This includes data about your use of our website and online services such as your IP address, your login data, details about your browser, length of visit to pages on our website, page views and navigation paths, and details about the number of times you use our website, time zone settings and other technology on the devices you use to access our website. The source of this data is our analytics tracking system. We process this data to analyse your use of our website and other online services, to administer and protect our business and website, deliver relevant website content and advertisements to you and to understand the effectiveness of our advertising. Our lawful ground for this processing is our legitimate interests which in this case are to enable us to properly administer our website and our business and grow our business and decide our marketing strategy.
- Marketing Data:
This includes data about your preferences in receiving marketing from us and our third parties and your communication preferences. We process this data to enable you to partake in our promotions such as competitions, prize draws and free giveaways, to deliver relevant website content and advertisements to you and to measure or understand the effectiveness of this advertising. Our lawful ground for this processing is our legitimate interests which in this case are to study how customers use our products/services, to develop them, grow our business and decide our marketing strategy.
We may use Customer Data, User Data, Technical Data and Marketing Data to deliver relevant website content and advertisements to you (including Facebook adverts or other display advertisements) and to measure or understand the effectiveness of the advertising we serve you. Our lawful ground for this processing is legitimate interests which is to grow our business. We may also use such data to send other marketing communications to you. Our lawful ground for this processing is either consent or legitimate interests, such as to grow our business.
Data we do not collect:
- Sensitive Data:
We do not collect any Sensitive Data about you. Sensitive data refers to data that includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data. We do not collect any information about criminal convictions and offences.
Where we are required to collect personal data by law, or under the terms of the contract between us and you do not provide us with that data when requested, we may not be able to perform the contract (for example, to deliver goods or services to you). If you don’t provide us with the requested data, we may have to cancel a product or service you have ordered but if we do, we will notify you at the time.
We will only use your personal data for a purpose it was collected for or a reasonably compatible purpose if necessary. For more information on this please email us at firstname.lastname@example.org in case we need to use your details for an unrelated new purpose we will let you know and explain the legal grounds for processing.
We may process your personal data without your knowledge or consent where this is required or permitted by law.
We do not carry out automated decision-making or any type of automated profiling.
Where we source your recruitment data:
Where personal data has not been obtained from the recruitment or data subject themselves through the form of CVs submitted or interviews, through spoken word. We may obtain your data from hiring companies or LinkedIn Recruiter. You can contact our data controller Sarah Swanton at: email@example.com to learn more about this or to exercise your statutory rights.
Where our processing is based and where we store your data:
Our processing is based at our registered office address in the United Kingdom.
We store all personal data safely and securely through cloud service providers such as Hire Insight, Google Drive and Dropbox. We have chosen these providers as they safely encrypt your data, however, we would also advise that you read their privacy policies separately. If you are unhappy about how your data is being stored, contact us at firstname.lastname@example.org, and we can address your concerns or exercise your data protection rights.
Our lawful ground of processing your personal data to send you marketing communications is either your consent or our legitimate interests (namely to grow our business).
Under the Privacy and Electronic Communications Regulations, we may send you marketing communications from us if:
(i) you made a purchase or asked for information from us about our goods or services or;
(ii) you agreed to receive marketing communications and in each case, you have not opted out of receiving such communications since.
Under these regulations, if you are a limited company, we may send you marketing emails without your consent. However, you can still opt-out of receiving marketing emails from us at any time.
Before we share your personal data with any third party for their own marketing purposes we will get your express consent.
You can ask us or third parties to stop sending you marketing messages at any time by emailing us at email@example.com any time.
If you opt-out of receiving marketing communications this opt-out does not apply to personal data provided as a result of other transactions, such as purchases, warranty registrations etc.
Disclosure of your personal data:
We may have to share your personal data with the parties set out below:
- service providers who provide IT and system administration services;
- professional advisers including lawyers, bankers, auditors and insurers,
- government bodies that require us to report processing activities,
- companies who we are providing recruitment or consulting service,
- third parties to whom we sell, transfer, or merge parts of our business or our assets.
We require all third parties to whom we transfer your data to respect the security of your personal data and to treat it in accordance with the law. We only allow such third parties to process your personal data for specified purposes and in accordance with our instructions.
We are subject to the provisions of the General Data Protection Regulations that protect your personal data. Where we transfer your data to third parties outside of the EEA, we will ensure that certain safeguards are in place to ensure a similar degree of security for your personal data. As such:
- We may transfer your personal data to countries that the European Commission have approved as providing an adequate level of protection for personal data; or
- If we use US-based providers that are part of EU-US Privacy Shield, we may transfer data to them, as they have equivalent safeguards in place; or
- Where we use certain service providers who are established outside of the EEA, we may use specific contracts or codes of conduct or certification mechanisms approved by the European Commission which give personal data the same protection it has in Europe.
If none of the above safeguards is available, we may request your explicit consent to the specific transfer. You will have the right to withdraw this consent at any time.
We have put in place security measures to prevent your personal data from being accidentally lost, used, altered, disclosed, or accessed without authorisation. We also allow access to your personal data only to those employees and partners who have a business need to know such data. They will only process your personal data on our instructions and they must keep it confidential.
We have procedures in place to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach if we are legally required to. We store personal data securely with the following providers: Hire Insight; Google Drive and Dropbox. We would strongly recommend you familiarise yourself with the privacy policies of these providers before you leave our site.
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including the purposes of satisfying any legal, accounting, or reporting requirements.
When deciding what the correct time is to keep the data we look at its amount, nature and sensitivity, potential risk of harm from unauthorised use or disclosure, the processing purposes if these can be achieved by other means and legal requirements.
For tax purposes, the law requires us to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they stop being customers.
In some circumstances, we may anonymise your personal data for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
Your legal rights:
Under data protection laws you have rights in relation to your personal data that include the right to:
- request access;
- to object to processing,
- to portability of data and (where the lawful ground of processing is consent)
- to withdraw consent.
You can see more about these rights at:
You can contact the ICO at this email address: firstname.lastname@example.org.
If you wish to exercise any of the rights set out above, please email us at email@example.com
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive or refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you.
If you are not happy with any aspect of how we collect and use your data, you have the right to complain to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would be grateful if you would contact us first if you do have a complaint so that we can try to resolve it for you.
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites, however, when you leave our website, we encourage you to read the privacy notice of every third-party website you have visited.
For more information about how we handle or process your personal data, please contact our data controller, Sarah Swanton at firstname.lastname@example.org, or contact Ben Swanton at email@example.com. If you wish to learn more about your personal data rights, please visit www.ico.org.uk, where you can learn more, or email ICO at firstname.lastname@example.org.