Privacy Policy | 27 Talent

27 Talent Ltd’s Privacy Policy

Anchor 1

What is the purpose of this document?

27 Talent Ltd is a “data controller”. This means that we are responsible for deciding how we hold and use personal information about you. This privacy policy explains the purposes for which we collect your data, what data we collect, how we store it and for how long. If you are applying for work with us (whether as an employee, worker or contractor) then please refer to our Candidate Privacy Policy www.27talent.com/candidateprivacypolicy which sets out specifically how we
work with our candidates. It provides you with certain information that must be provided under the General Data Protection Regulation ((EU) 2016/679) (GDPR).

This Privacy Policy applies to the personal data of our Website Users, Candidates, Clients, Suppliers, and other people whom we may contact to find out more about our Candidates or whom they indicate is an emergency contact. It also applies to the emergency contacts of our Staff. Please note that we may amend this Privacy Policy from time to time so please check our website to stay up to date.

Data protection principles

We will comply with data protection law and principles, which means that your data will be:

Used lawfully, fairly and in a transparent way.
Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
Relevant to the purposes we have told you about and limited only to those purposes.
Accurate and kept up to date.
Kept only if necessary for the purposes we have told you about.
Kept securely.

What kind of personal information do we collect?

Set out below is a description of the type of information that we may collect, in addition to any personal data we are required by law to process in any given situation.

CANDIDATE DATA: We will collect several types of information from you to enable us to offer you employment opportunities which are tailored to your circumstances and your interests. Such information includes, but is not limited to, your name, date of birth, photograph, address, education details, employment history, referee details etc. Further details about the type of information that we will need is set out specifically in our Candidate Privacy Policy www.27talent.com/candidateprivacypolicy. The information we need to collect from you to fulfil our legal obligations to you under our terms of representation (www.27talent.com/terms-standard) is in addition to the information that will be collected from you through your use of our website, such as cookies. Please refer to our cookie policy for further information www.27talent.com/cookiepolicy.

CLIENT DATA: To comply with our obligations to our clients, 27 Talent Ltd will need to have your contact details or the details of individual contacts at your organisation (such as their names, telephone numbers and email addresses) to enable us to ensure that our relationship runs smoothly. We also hold information relating to your online engagement with Candidate profiles, which we use to ensure that our communications to you are relevant and timely. We may also hold extra information that someone in your organisation has chosen to tell us. [In certain circumstances, such as when you engage with our Finance and Debt Recovery teams, our calls with you may be recorded.]

The information we need to collect from you to fulfil our legal obligations to you under our respective legal arrangements (please contact us for further details info@27talent.com) is in addition to the information that will be collected from you
through your use of our website, such as cookies. Please refer to our cookie policy for further information www.27talent.com/cookiepolicy.

SUPPLIER DATA: To ensure our relationships with our suppliers run smoothly, we will collect the details for our contacts within your organisation, such as names, telephone numbers and email addresses. We’ll also collect bank details, so that we can pay you. We may also hold extra information that someone in your organisation has chosen to tell us.

The information we need to collect from you to fulfil our legal obligations to you under our respective relationships (please contact us for further details info@27talent.com) is in addition to the information that will be collected from you through your use of our website, such as cookies. Please refer to our cookie policy for further
information www.27talent.com/cookiepolicy.

THIRD PARTIES: This category of people includes people who have been referred to us by candidates or employees, such as referees and emergency contacts, whose personal contact details we need in specific circumstances such as ensuring a candidate or potential employee has the experience required for a position or contacting someone in the event of an emergency. To ask for a reference, we’ll obviously need the referee’s contact details (such as name, email address and telephone number). We’ll also need these details if our Candidate or an employee has put you down as their emergency contact so that we can contact you in the event of an accident or an emergency.

WEBSITE USERS: We collect a limited amount of data from our Website Users which we use to help us to improve your experience when using our website and to help us manage the services we provide. This includes information such as how you use our website, the frequency with which you access our website, your browser type, the location you view our website from, the language you choose to view it in and the times that our website is most popular. Please refer to our cookie policy for further information www.27talent.com/cookiepolicy.

How do we collect your personal data?

CANDIDATE DATA: We collect Candidate personal data in three primary ways:

Personal data that you, the Candidate, give to us;
Personal data that we receive from other sources; and
Personal data that we collect automatically.

This data is collected in various ways including, but not limited to, you providing hard copies of information at interviews with us; emailing us soft copies of information; and applications through job websites and social media websites. In addition, we will collect information on our Candidates from Third Parties and Clients. Further details of how we collect data in relation to our Candidates can be found in our Candidate Privacy Policy www.27talent.com/candidateprivacypolicy

CLIENT DATA: We collect Client personal data in three ways:

Personal data that we receive directly from you;
Personal data that we receive from other sources; and
Personal data that we collect automatically.

The data that we receive directly from you includes phone or email details. Such information may also be provided to us by your colleagues or managers or from other Third Parties and Candidates, as well as through social media websites such as Linkedin or Facebook and through use of our website.

WEBSITE USERS: When you visit our website, there is certain information that we may automatically collect, whether or not you decide to use our services. This includes your IP address, the date and the times and frequency with which you
access the website and the way you browse its content.

We collect your data automatically via cookies, in line with cookie settings in your browser. If you are also a Candidate or 27 Talent Ltd Client, we may use data from your use of our websites to enhance other aspects of our communications with or service to you. If you would like to find out more about cookies, including how we use them and what choices are available to you, please click here www.27talent.com/cookiepolicy.

How do we use your personal data?

We generally use your personal data to comply with our legal obligations to you under our relevant terms and conditions of business (please contact us further for more information info@27talent.com). Where our grounds for processing differ from this we will tell you, with further information being set out below. You have the right at any time to stop us processing your data but please note that we may not be able to comply with our obligations to you without such data.

CANDIDATE DATA: We generally use Candidate data in four ways:

Recruitment Activities;
Marketing Activities;
Payment and HMRC obligations;
Equal Opportunities Monitoring; and
To help us to establish, exercise or defend legal claims.

Further details of how we use Candidates’ data can be found in our Candidate Privacy Policy www.27talent.com/candidateprivacypolicy.

In addition to our recruitment activities, we may also send you information from time to time about roles that you may find interesting or to ask for your help with connecting other Candidates with jobs. In particular, we may wish to use your data for the purposes listed below. Please note that this list is not exhaustive. To:

enable us to develop and market other products and services;
market our full range of recruitment services (permanent, temporary, contract) to you; and
display promotional excerpts from your details on 27 Talent Ltd’s website as a success story (only where we have obtained your express consent to do so).

Where the grounds for processing data in relation to these activities is not covered by legal obligation or legitimate interests, we will contact you for your explicit consent. You have the right, even if you have opted in, to opt out of any marketing from 27 Talent Ltd.

Please note that where you have previously engaged with us (for example by submitting a job application or CV, or registering a vacancy to be filled), and we are marketing other recruitment-related services that we believe to be of relevance to you, then we will assume that you have consented to this contact and that it is in our legitimate interests to contact you further. You can choose not to receive any further information from us at any time and we will use all reasonable endeavours to remove you from any further mailing lists.

We are committed to ensuring that our recruitment processes are aligned with our approach to equal opportunities. Some of the data we may (in appropriate circumstances and in accordance with local law and requirements) collect about you comes under the umbrella of “diversity information”. This could be information about your ethnic background, gender, disability, age, sexual orientation, religion or other similar beliefs, and/or social-economic background. We may also disclose this (suitably anonymised where relevant) data to Clients where this is contractually required or the Client specifically requests such information to enable them to comply with their own employment processes.

In addition to “diversity information” that we may need to collect, there may also be a need to collect other sensitive personal data about you, such as health-related information, religious affiliation, or details of any criminal convictions. This information is what is called ‘sensitive’ personal information and therefore we need to obtain your explicit consent before we can use it. We’ll ask for your consent by offering you an opt-in. This means that you must explicitly and clearly tell us that you agree to us collecting and using this information.

Please note that in accordance with our statutory obligations we also have a legitimate interest to process your data and may share that data in connection with crime detection, tax collection or actual or anticipated litigation. Again, if you are unhappy at any time with the way we use your data, then you have the right to withdraw your consent at any time. Please contact us at the following address 7 Bell Yard, Holborn, London, WC2A 2JR.

CLIENT DATA: We use Client information for:

Recruitment Activities;
Marketing Activities; and
To help us to establish, exercise or defend legal claims.

We will principally use your data to contact you in relation to suitable Candidates for your role. As part of that work we will keep records of any conversations or meetings that we may have and we will also retain any feedback that we get from you in relation to our work and the Candidates that we propose to you.

27 Talent Ltd will also market to you where we believe such marketing is relevant to you and it is in our legitimate interests to do so. If you are not happy about this, you have the right to opt out of receiving marketing materials from us and can find out more about how to do so by contacting 27 Talent Ltd in writing either at info@27talent.com or c/o Data Controller, 27 Talent Ltd, 7 Bell Yard, Holborn, London, WC2A 2JR.

Again, if you are unhappy at any time with the way we use your data, then you have the right to withdraw your consent at any time. Please contact us at the following address; info@27talent.com.

SUPPLIER DATA: We only use your information to ensure we have the correct details with regards the services you provide to us or vice versa; to perform certain legal obligations and to help us to establish, exercise or defend legal claims. 27 Talent Ltd will also market to you where we believe such marketing is relevant to you and it is in our legitimate interests to do so. If you are not happy about this, you have the right to opt out of receiving marketing materials from us and can find out more about how to do so by contacting 27 Talent Ltd in writing either at info@27talent.com or c/o Data Controller, 27 Talent Ltd, 7 Bell Yard, Holborn, London, WC2A 2JR.

Again, if you are unhappy at any time with the way we use your data, then you have the right to withdraw your consent at any time. Please contact us at the following address; 27 Talent Ltd, 7 Bell Yard, Holborn, London, WC2A 2JR.

THIRD PARTIES: We will only use the information that our Candidate or employee gives us about you for the following purposes:

If our Candidates or employees put you down on our form as an emergency contact, we’ll contact you in the case of an accident or emergency affecting them; or
If you were put down by our Candidate or a prospective employee as a referee, we will contact you to take up a reference. This is an important part of our Candidate quality assurance process, and could be the difference between the individual getting a job or not.
If you were put down by our Candidate or a prospective employee as a referee, we may sometimes use your details to contact you in relation to recruitment activities that we think may be of interest to you, in which case we will use your data for the same purposes for which we use the data of Clients.

27 Talent Ltd will also market to you where we believe such marketing is relevant to you and it is in our legitimate interests to do so. If you are not happy about this, you have the right to opt out of receiving marketing materials from us and can find out more about how to do so here by contacting 27 Talent Ltd in writing either at info@27talent.com or c/o Data Controller, 27 Talent Ltd, 7 Bell Yard, Holborn, London, WC2A 2JR.

WEBSITE USERS: We use your data to help us to improve your experience of using our website, for example by analysing your recent job search criteria to help us to present jobs or Candidates to you that we think you’ll be interested in.
If you would like to find out more about cookies, including how we use them and what choices are available to you, please click here www.27talent.com/cookiepolicy

Who do we share your personal data with?

Where appropriate and in accordance with relevant laws and regulations, we may share your personal data, in various ways and for various reasons, with the following categories of people:

Individuals and organisations who hold information related to your reference or application to work with us, such as current, past or prospective employers, educators and examining bodies and employment and recruitment agencies;

Tax, audit, or other authorities, when we believe in good faith that the law or other regulation requires us to share this data (for example, because of a request by a tax authority or in connection with any anticipated litigation);
Third party service providers who perform functions on our behalf (including external consultants, business associates and professional advisers such as lawyers, auditors and accountants, technical support functions and IT consultants carrying out testing and development work on our business technology systems);
Third party outsourced IT and document storage providers where we have an appropriate processing agreement (or similar protections) in place;
Marketing technology platforms and suppliers;
In the case of Candidates: potential employers and other organisations to increase your chances of finding employment;
In the case of Candidates: third party partners, job boards and job aggregators where we consider this will improve the chances of finding you the right job; or
In the case of Candidates and our Candidates’ and prospective employee’s referees: third parties who we have retained to provide services such as reference, qualification and criminal convictions checks, to the extent that these checks are appropriate and in accordance with local laws.

How do we safeguard your personal data?

27 Talent Ltd takes your privacy very seriously and we are committed to taking all reasonable and appropriate steps to protect the personal information that we hold from misuse, loss, or unauthorised access. We do this by having in place a range of appropriate technical and organisational measures. These include measures to deal with any suspected data breach. If you suspect any misuse or loss of or unauthorised access to your personal information please let us know immediately by emailing info@27talent.com.

How long do we keep your personal data for?

We will delete your personal data from our systems if we have not had any meaningful contact with you (or, where appropriate, the company you are working for or with) based on the following:

If you have contracted with us, we have a contractual right to keep details for at least 6 years since the contract ended
If you have formally registered and actively looking, we believe we have a legitimate interest to keep your details for 3 years since our last recorded contact with you about possible work
If you are an unregistered candidate who has submitted personal data for roles, we believe we have a legitimate interest to keep your details for at least 1 year in the event that, for example, we are a business that can in time help you given our client base and functional expertise or if, for example, your search was put on hold. In the event that we don’t formally register you as a candidate within 12 months of receiving your CV (this could be for various reasons including either party being unavailable), but believe we still have a legitimate interest to retain your details, we will endeavour to contact you to check that you are comfortable with your details being retained.

After this period, it is possible that your data will no longer be relevant for the purposes for which it was collected. For those Candidates whose services are provided via a third-party company or other entity, “meaningful contact” with you
means meaningful contact with the company or entity which supplies your services. Where we are notified by such company or entity that it no longer has that relationship with you, we will retain your data for no longer than three years from that point or, if later, for the period of three years from the point we subsequently have meaningful contact directly with you. When we refer to “meaningful contact”, we mean, for example, communication between us (either verbal or written), or where you are actively engaging with our consultants or social media websites. If you are a Candidate we will consider there to be meaningful contact with you if you submit your updated CV onto our website. We will also consider it meaningful contact if you actively communicate with us about potential roles, either by verbal or written
communication or click through from any of our marketing communications.

How can your access, amend or restrict the processing of any personal data we hold?

You have various rights under GDPR in relation to any data of yours that we hold even after we have collected it. In order to access your data, please contact us and we will send you our data subject access request (“DSAR”) form. This form will set out what data we hold in relation to you and give you the opportunity to modify, update or delete such information. We will aim to respond to you as soon as reasonably possible and in any event within one month (subject to any extensions to which we are lawfully entitled). Furthermore, there will be no charge for accessing such information unless we deem your request to be “manifestly unfounded or excessive”. Please note that we may keep a record of your communications to help us resolve any issues which you raise and, in certain circumstances where we are legally allowed to do so, we may refuse your request with an explanation accordingly.

In addition, you have the following rights:

Right to object: this right enables you to object to us processing your personal data where we do so for one of the following four reasons: (i) our legitimate interests; (ii) to enable us to perform a task in the public interest or exercise official authority; (iii) to send you direct marketing materials; and (iv) for scientific, historical, research, or statistical purposes.If your objection relates to us processing your personal data because we deem it necessary for your legitimate interests, we must act on your objection by ceasing the activity in question unless we can show that we have compelling legitimate grounds for processing which overrides your interests; or we are processing your data for the establishment, exercise or defence of a legal claim. Similarly, if your objection relates to direct marketing, we must act on your objection by ceasing this activity.
Right to withdraw consent: Where we have obtained your consent to process your personal data for certain activities (for example, for our marketing arrangements), you may withdraw this consent at any time and we will cease to carry out the particular activity that you previously consented to unless we consider that there is an alternative reason to justify our continued processing of your data for this purpose in which case we will inform you of this condition.collected and/or processed it; the data is no longer necessary for the purpose for which we originally
Right to erasure: You have the right to request that we erase your personal data in certain circumstances. Normally, the information must meet one of the following criteria:
- the data has been processed unlawfully (i.e. in a manner which does not comply with the GDPR);
- it is necessary for the data to be erased in order for us to comply with our legal obligations as a data controller; or
- if we process the data because we believe it necessary to do so for our legitimate interests, you object to the processing and we are unable to demonstrate overriding legitimate grounds for our continued processing.
where previously given, you have withdrawn your consent to us processing your data, and there is no other valid reason for us to continue processing;
the data is no longer necessary for the purpose for which we originally collected and/or processed it;

We would only be entitled to refuse to comply with your request if it jeopardised our ability to exercise our right of freedom of expression and information; to comply with legal obligations or for the performance of a public interest task or exercise of official authority; for public health reasons in the public interest; for archival, research or statistical purposes; or to exercise or defend a legal claim.

Right to restrict processing: You have the right to request that we restrict our processing of your personal data in certain circumstances. This means that we can only continue to store your data and will not be able to carry out any further processing activities with it until either: (i) one of the circumstances listed below is resolved; (ii) you consent; or (iii) further processing is necessary for either the establishment, exercise or defence of legal claims, the protection of the rights of another individual, or reasons of important EU or Member State public interest.The circumstances in which you are entitled to request that we restrict the processing of your personal data are:
- where you dispute the accuracy of the personal data that we are processing about you. In this case, our processing of your personal data will be restricted for the period during which the accuracy of the data is verified;
- where you object to our processing of your personal data for our legitimate interests. Here, you can request that the data be restricted while we verify our grounds for processing your personal data;
- where our processing of your data is unlawful, but you would prefer us to restrict our processing of it rather than erasing it; and
- where we have no further need to process your personal data but you require the data to establish, exercise, or defend legal claims.

As we share data with third parties including Client in the case of Candidates, we will notify them about the restricted processing unless this is impossible or involves disproportionate effort. We will, of course, notify you before lifting any restriction on processing your personal data.

Right to rectification: You also have the right to request that we rectify any inaccurate or incomplete personal data that we hold about you. If we have shared this personal data with third parties, we will notify them about the rectification unless this is impossible or involves disproportionate effort. Where appropriate, we will also tell you which third parties we have disclosed the inaccurate or incomplete personal data to. Where we think that it is reasonable for us not to comply with your request, we will explain our reasons for this decision.
Right of data portability: If you wish, you have the right to transfer your personal data between data controllers. This right of data portability applies to: (i) personal data that we process automatically (i.e. without any human intervention); (ii) personal data provided by you; and (iii) personal data that we process based on your consent or to fulfil a contract.
Right to lodge a complaint with a supervisory authority: You also have the right to lodge a complaint with your local supervisory authority, which in the UK is The Information Commissioner’s Office. You can contact them in the following ways:
- Phone: 0303 123 1113
- Email: casework@ico.org.uk
- Post: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF

If you would like to exercise any of these rights, or withdraw your consent to the processing of your personal data (where consent is our legal basis for processing your personal data), you can contact us directly 27 Talent Ltd, 7 Bell Yard, Holborn, London, WC2A 2JR. Please note that we may keep a record of your communications to help us resolve any issues which you raise.

How do we store and transfer your data internationally?

Although 27 Talent Ltd is based in the UK, it is our duty to let you know that your data may be transferred:

to third parties (such as advisers or other suppliers);
to Clients within your country who may, in turn, transfer your data internationally;
to a cloud-based storage provider; and
to other third parties, as referred to here.

We want to make sure that your data are stored and transferred in a way which is secure. We will therefore only transfer data outside of the European Economic Area or EEA (i.e. the Member States of the European Union, together with Norway, Iceland and Liechtenstein) where it is compliant with data protection legislation and the means of transfer provides adequate safeguards in relation to your data, for example:

by way of data transfer agreement, incorporating the current standard contractual clauses adopted by the European Commission for the transfer of personal data by data controllers in the EEA to data controllers and processors in jurisdictions without adequate data protection laws; or
by signing up to the EU-U.S. Privacy Shield Framework for the transfer of personal data from entities in the EU to entities in the United States of America or any equivalent agreement in respect of other jurisdictions; or
transferring your data to a country where there has been a finding of adequacy by the European Commission in respect of that country’s levels of data protection via its legislation; or
where it is necessary for the conclusion or performance of a contract between ourselves and a third party and the transfer is in your interests for the purposes of that contract (for example, if we need to transfer data outside the EEA to meet our obligations under that contract if you are a Client of ours); or
where you have consented to the data transfer.

To ensure that your personal information receives an adequate level of protection, we have put in place appropriate procedures with the third parties we share your personal data with to ensure that your personal information is treated by those third parties in a way that is consistent with and which respects the law on data protection.

Contact details

Should you have any queries on the policy above or on how we process, collect or store your data, please contact us by email, post or telephone in accordance with the following:

27 Talent Ltd, 7 Bell Yard, Holborn, London, WC2A 2JR
info@27talent.com

Approved by

Brooke Cooper, Director

Date: 09/03/2022