Purpose of our policy
Earth Talent Search (UK) Ltd (Company registered in England and Wales, number 08734744) (Earth Talent, we, us or our) provides search and recruitment services offered directly to clients who may be introduced to Earth Talent via our website www.earthtalent.co.uk, electronic mail and/or any electronically transmitted (and retained) message, (the Platform).
For the purposes of the Data Protection Act 1998 and General Data Protection (Regulation), coming into effect on the 25th of May 2018, we are the data controller.
We have adopted this policy to ensure that we have standards in place to protect the data that we collect about you that is necessary and incidental to providing the services that we offer, and the normal day-to-day operations of our business.
By publishing this policy, we aim to make it easy for our clients and the public to understand what data we collect and store, why we do so, how we receive and/or obtain that information, and the rights you have with respect to your data in our possession.
WHO AND WHAT THIS POLICY APPLIES TO
We handle data in our own right and also for and on behalf of our clients and our candidates. Our policy does not apply to information we collect about businesses or companies, however it does apply to information about the people in those businesses or companies which we store. The policy applies to all forms of information, physical and digital, whether collected or stored electronically or in hardcopy.
If, at any time, you provide data or other information about someone other than yourself, you warrant that you have that person’s consent to provide such information for the purpose specified. Earth Talent does not collect data from children (persons under the age of 18 years).
THE INFORMATION WE COLLECT
In the course of business, it is necessary for us to collect data. This information allows us to identify who you are for the purposes of our business, share data when asked of us, contact you in the ordinary course of business and transact with you. Without limitation, the type of information we may collect is:
We may collect personal details such as your name, CV, location, date of birth, photograph, passport, driver’s license and other information that allows us to identify who you are, solely in relation to our business and your suitability for a position that you may have applied for through, or been directly approached by, Earth Talent.
We may collect information such as your email address, mobile and/or landline telephone number, third-party usernames, residential and business address, and other information that allows us to contact you;
Information you send us
We may collect any personal correspondence that you send us, or that is sent to us by others (such as reference or fraud prevention agencies) about your activities, including activities with our clients.
We may collect other data about you, which we will maintain in accordance with this policy.
HOW INFORMATION IS COLLECTED
Most information will be collected in association with an individual’s use of Earth Talent’s Platform, our services, an enquiry directly to Earth Talent or generally dealing with us.
However, we may also receive data from other sources such as advertising, an individual’s own promotions, public records, mailing lists, contractors, staff, recruitment agencies and our business partners.
In particular, information is likely to be collected as follows:
When an individual registers, subscribes and or purchases a product, service, list, account, connection or other process whereby they enter data details or grant access to information in order to receive or access something;
When an individual submits their details to an open source social media platform/s that Earth Talent may have public access to and/or registers on our Platform
As there are many circumstances in which we may collect information both electronically and physically, we will endeavour to ensure that an individual is always aware of their data being collected, in particular by third parties when we need to send them your personal data and/or CV in relation to a position you may have applied for.
HOW DATA IS STORED
WHEN DATA IS USED
In general, we will only use any data for the purpose for which it was collected, except with your permission. The purpose of collection is determined by the circumstances in which the information was collected and/or submitted. Information is used to enable us to operate our business, especially as it relates to you.
This may include the provision of Earth Talent’s services to you, verifying your identity, communicating with you about your relationship with us, our services, our marketing to clients and candidates, investigating any complaints about or made by you, or if we have reason to suspect that you are in breach of any of our terms and conditions or that you are or have been otherwise engaged in any unlawful activity, preventing and detecting fraud, money laundering and other crime (such as identity theft).
If you publicly post about Earth Talent, or communicate directly with us, on a social media website, we may collect and process the data contained in such posts or in your public profile for the purpose of addressing any customers services requests you may have and to monitor and influence public opinion of Earth Talent.
WHEN DATA IS DISCLOSED
Upon your authorisation and instruction, to your advisers (such as accountants, lawyers or other professional advisers).
It may be necessary for us to disclose your data to third parties in a manner compliant with the Regulation in the course of our business, such as for processing activities like verification, due diligence, data analytics and invoice/payment processing.
We will not disclose or ever sell any of your data to unrelated third parties under any circumstances but it should be noted that we employ other companies, such as Mail Chimp, to perform tasks on our behalf and we need to share your contact information with them to provide services to you on our behalf.
There are certain circumstances in which we must disclose your information which includes where we reasonably believe that you may be engaged in fraudulent, deceptive or unlawful activity that a governmental authority should be made aware of and/or as required by any law including court orders and/or to fraud prevention agencies, in particular, we will always tell fraud prevention agencies if you give us false or fraudulent information. They will also allow other organisations (in the UK or abroad), including law enforcement agencies to access this information to prevent and detect fraud, money laundering or other crimes; and/or in order to sell our business (as we may transfer data to a new owner).
We will take all reasonable steps to ensure that any disclosure to an entity outside of the United Kingdom will not be made until that entity has agreed in writing with us to safeguard data as we do.
If the Company becomes involved in a merger, asset sale, financing, liquidation or bankruptcy, or acquisition of all or some portion of the business to another company, we may share information with that company before and after the transaction closes.
THIRD PARTY SERVICES, WEBSITES, AND ACCOUNTS
We may share your information with third-party service providers in connection with the provision of Earth Talent’s services to you, and otherwise operating our business, marketing and promoting our products and services.
For example, we may share your information as follows: all information may be processed and stored with reputable cloud service providers; information may be required to communicate with you (such as Gmail from Google, Inc); and to assist marketing and promotions to candidates on social media (such as Linked-in, Twitter and Facebook).
CONSENT TO COLLECTION OF DATA
You may opt to not have us collect your data and communicate with you at certain times.
Where relevant, you will have the right to choose to have your information collected and/or receive information from us; or
Where relevant, you will have the right to choose to be excluded from some, if not all, information collection, and/or the receiving of that information from us. You may revoke your consent at any time, and the decision to opt out should be made through the same media by which you opted in.
If you believe that you have received information from us that you did not opt in to receive, you should contact us on the details provided at the bottom of this document.
THE SAFETY & SECURITY OF DATA
We will take all reasonable precautions to protect your data from unauthorised access. This includes appropriately securing our physical facilities and electronic networks. Examples of such precautions include: Data encryption, Firewalls, Intrusion detection systems, physical protection of premises where data is stored (24/7) via the third parties that own the premises and background checks for all employees accessing our data.
The security of online transactions and the security of communications sent by electronic means or by post cannot be guaranteed. When you provide information to us via the internet or by post, you do so at your own risk. We cannot accept responsibility for misuse or loss of, or unauthorised access to, data, where the security of information is not within our control.
Privacy or security practices of any third party (including third parties that we are permitted to disclose your data to in accordance with this policy or any applicable laws) may be subject to separate privacy and security policies than that of Earth Talent’s.
If you suspect any misuse or loss of, or unauthorised access to, your data, you should let us know immediately. We are not liable for any loss, damage or claim arising out of another person’s use of the data where we were authorised to provide that person with the data.
HOW TO ACCESS AND/OR UPDATE INFORMATION
Current regulation gives you the right to request from us the data that we have about you.
If you cannot update your own information, we will correct any errors in the data we hold on you within one month of receiving written notice from you about these errors. It is your responsibility to provide us with accurate and truthful data. We cannot be liable for any information that is provided to us that is incorrect.
We may charge you a reasonable fee for our costs incurred in meeting any of your requests to disclose the data we hold on you, if such a request is manifestly unfounded or excessive.
We reserve the right to clarify the specific information your request relates to and information will be provided within one month of receipt of the request.
You also have the right to request that information held on you by Earth Talent is erased, where there are no additional legal and/or regulatory requirements for Earth Talent continuing to do so.
COMPLAINTS AND DISPUTES
You have the right to object to: processing based on legitimate interests or the performance of a task in the public interest/exercise of official authority (including profiling); direct marketing; and processing for purposes of scientific/historical research and statistics unless we hold compelling legitimate grounds for processing or the processing is for the establishment, exercise or defence of legal claims.
After 25th May 2018, you will be able to adjust your contact preferences at any time by contacting Earth Talent by electronic mail or by post. You can choose how you would like to receive any marketing and other non-business critical communications too. Any changes made to these contact preferences can take up to 72 hours to come into effect after Earth Talent have received your request.
If you have a complaint about our handling of your data, you should address this complaint in writing to the details provided at the bottom of this document. You also have the right to lodge a complaint with a supervisory authority if you consider that the processing of your data infringes the General Data Protection Regulation. If you lodge a dispute regarding your data, we both must first attempt to resolve the issue directly between us.
If we become aware of any unauthorised access to your data which is likely to result in a high risk for the rights and freedoms of the data subjects, we will inform you without undue delay after becoming aware of it, once we have established what was accessed and how it was accessed.
ADDITIONS TO THIS POLICY
We reserve the right to modify this policy at any time, so please review it frequently. Changes and clarifications will take effect immediately upon their posting on the Platform. If we make material changes to this policy, we will notify you here that it has been updated, so that you are aware of what information we collect, how we use it, and under what circumstances, if any, we use and/or disclose it.
If we decide to change this policy, we will post the changes on our Platform at www.earth talent.co.uk/privacy. It is your responsibility to refer back to this policy to review any amendments.
All correspondence relating to privacy should be addressed to (by email where possible):
The Data Controller
Earth Talent Search (UK) Ltd
The Apple Barn