This is the privacy and cookies policy for https://talentpool.com (Site). The Site is operated by or on behalf of Gradlist Limited trading as TalentPool (we, us, our and TalentPool). For the purposes of the Data Protection Act 1998 and (from 25th May 2018) the GDPR, we are the data controller and our data protection officer is Andrew Lavelle who can be contacted at by sending an email to email@example.com with ‘FAO Andrew Lavelle’ in the Subject bar.
We are committed to protecting your privacy online. We appreciate that you do not want your personal information distributed indiscriminately and here we explain how we collect information, what we do with it and what controls you have.
Information we will collect from or about you
We will typically collect and process the following information about you:
- information (such as your name, email address, postal address and telephone number) that you provide by completing forms on the Site, including if you register as a user of the Site, subscribe to any service, upload or submit any material via the Site, request any information, or enter into any competition or promotion we may sponsor;
- in connection with an account sign-in facility, your log-in and password details;
- communications you send to us, for example to report a problem or to submit queries, concerns or comments regarding the Site or its content;
- information from surveys that we may, from time to time, run on the Site for research purposes, if you choose to respond to, or participate in, them;
- career preferences, employment details,education details and any other information you choose to include if you send us a CV, resumé, cover letter or other details of your employment history (such as languages spoken and any “special category data” such as your ethnicity, health information, sexual orientation and political interests) in connection with a job vacancy or a general enquiry regarding employment opportunities with us (“Position”).
You are under no obligation to provide any such information. However, if as an Employer you should choose to withhold the above information, we will not be able to provide you with our services under our Terms of Business.
We may, from time to time, run referral programmes or similar initiatives, such as a “Tell a Friend” programme, that invite you to provide us with the contact details of someone who is known to you who may find our products or services to be of interest (“Referred Individual”). We will only use those contact details for the purpose of the relevant initiative (and not for general marketing purposes). By providing us with their details, you confirm that you have the Referred Individual’s permission to do so and must not provide us with the details of anyone from whom you do not have such permission. We reserve the right to identify you as the person who has made the referral in the message that is sent to the Referred Individual.
When you visit the Site, we may, by means of cookies and/or other similar technologies, automatically collect additional information about you – such as any website from which you have come to the Site. See Cookies and other technologies for more information.
Cookies and other technologies
When you interact with the Site, we try to make that experience simple and meaningful. When you visit the Site, a web server sends a cookie or other similar technology to your computer or mobile device (as the case may be). Cookies are small pieces of information which are issued to your computer or mobile device (as the case may be) when you visit a website and which store and sometimes track information. A number of cookies we use last only for the duration of your web session and expire when you close your browser. Other cookies are used to remember you when you return to the Site and will last indefinitely.
The cookies and/or other similar technologies we use collect information, such as the type of internet browser or mobile device you use, any website from which you have come to the Site, your IP address and/or the operating system of your computer or mobile device.
- remember that you have visited us before. This means you can access your account without having to log-in again
- customise elements of the promotional layout and/or content of the pages of the Site; and
- measure the effectiveness of digital marketing campaigns by collecting information on where you have come to site from and what pages you visit while on the site
- collect anonymous statistical information about how you use the Site (including how long you spend on the Site) and where you have come to the Site from, so that we can improve the Site and make sure the site is meeting the needs of its users and to help us make improvements
Some of the cookies used by the Site are set by us, and some are set by third parties who are delivering services on our behalf.
Most web and mobile device browsers automatically accept cookies but, if you prefer, you can change your browser to prevent that or to notify you each time a cookie is set. You can also learn more about cookies by visiting www.allaboutcookies.org which includes additional useful information on cookies and how to block cookies using different types of browser or mobile device. Please note, however, that by blocking or deleting cookies used on the Site, you may not be able to take full advantage of the Site.
On what basis can we process your information?
The legal grounds under data protection legislation for processing your personal data are as follows:
- You have given us explicit opt-in consent to the processing of your personal data for one or more specific purposes, namely to process your Special Category Personal Data where you choose to submit any as described above. You do not need to provide us with this data as we do not ask you for it, but you may choose to include such data in documents you upload, in which case we cannot hold and process those documents for you if you do not provide us with your prior consent when uploading them. This will impact on our ability to provide you with our services and will prevent us from connecting you with Employers.Where we need to comply with a legal obligation; or in rare circumstances:
- Where we need to protect your interests (or someone else’s interests); and/or
- Where it is needed in the public interest or for official purposes
Uses made of your information
We use your personal information which we collect:
- To provide our recruitment services to you and to facilitate the recruitment process;
- To assess data about you against Positions which we judge may be suitable for you;
- To send you information we think you may find useful or which you have requested from us, including information about our services, Positions, or those of carefully selected third parties, provided you have indicated that you do not object to being contacted for these purposes such as by clicking on the unsubscribe link in the email;
- To allow you to participate in interactive features of our service when you choose to do so;
- To use your information on an anonymised basis to monitor diversity within the marketplace and our candidate database;
- To send you details of reports, promotions, offers, networking and events and general information about the industry sectors which we think might be of interest to you unless you have chosen to opt out to being contacted for such purposes;
- To enable us to provide you with the services and information offered through the Site and which you request;
- To administer your account with us;
- To audit the downloading of data from the Site;
- To improve the layout and/or content of the pages of the Site and customise them for users; and
- To send your information to third parties, regulatory or law enforcement agencies if we believe in good faith that we are required by law to disclose it in connection with the detection of crime, the collection of taxes or duties, in order to comply with any applicable law or order of a court of competent jurisdiction, or in connection with legal proceedings.
From time to time we may seek your consent to process, use or disclose your personal information for any other purpose not listed above.
Should you apply to a role with which you are matched, you will most likely be asked to provide a copy of your Curriculum Vitae and answer one or more questions set by the employer. When this happens, we will share as a default your basic profile information with the Employer in question, including your name, email address, phone number, work experience and education details. And where you are requested to upload a Curriculum Vitae and/or respond to specific questions set by an Employer, we will share the Curriculum Vitae that you upload and your responses to any questions set with the Employer.
We may disclose aggregate statistics about visitors to and users of the Site in order to describe our services to prospective partners and other reputable third parties and for other lawful purposes, but these statistics will include no personally identifiable information.
We will disclose your personal information to our agents or contractors who assist us in providing the services we offer through the Site, fulfilling requests for information, receiving and sending communications, updating marketing lists, analysing data, providing IT and other support services or in other tasks, from time to time. These third parties are:
- Campaign Monitor
Our agents and contractors will only use your information to the extent necessary to perform their functions.
In the event that we undergo re-organisation or are sold to a third party, any personal information we hold about you may be transferred to that re-organised entity or third party.
We may disclose your personal information if required to do so by law or if we believe that such action is necessary to prevent fraud or cybercrime or to protect the Site or the rights, property or personal safety of any person.
The Site may, from time to time, contain links to external sites. We are not responsible for the privacy policies or the content of such sites.
We place great importance on the security of all personal information associated with our users. We have security measures in place to attempt to protect against the loss, misuse and alteration of personal information under our control. For example, our security and privacy policies are periodically reviewed and enhanced as necessary and only authorised personnel have access to personal information. Whilst we cannot ensure or guarantee that loss, misuse or alteration of information will never occur, we use all reasonable efforts to prevent it.
You should bear in mind that submission of information over the internet is never entirely secure. We cannot guarantee the security of information you submit via the Site whilst it is in transit over the internet and any such submission is at your own risk.
It is advisable to close your browser when you have finished your user session to help ensure others do not access your personal information if you use a shared computer or a computer in a public place.
Storage of your information
Your personal information which we collect is sent to and stored on secure servers located in the United Kingdom. Such storage is necessary in order to process the information.
Personal information submitted may be transferred by us to our other offices and/or to the third parties mentioned in the circumstances described above (see Information sharing), which may be situated outside the European Economic Area (EEA) and may be processed by staff operating outside the EEA. The countries concerned may not have data protection laws as strict as those in the EEA. Where we transfer your personal information we will either undertake an assessment of the level of protection in light of the circumstances surrounding the transfer or:
- Only transfer it to a non-EEA country with privacy laws that give the same protection as the EEA; or
- Ensure we have an agreement in place with the recipient under which they are under a duty to protect your data to the same standards as those in place in the EEA; or
- Transfer it to US organisations that are signed up to the EU-US Privacy Shield scheme; or
- We will make sure that any transfers are not repetitive and only limited to the minimum amount of information possible. In certain circumstances we may need to seek your consent unless there is an overriding legal need to transfer the information; and
- In all cases where your information is transferred outside the EEA, you have a right to contact us for information on the measures we have put in place. Those current measures in place are:
- Where the third party in question is an established platform (such as Google or Rackspace) we ensure through internal checks that they are GDPR compliant.
- Where the the party in question is a service provider with which we need to share data in order for them to deliver their services properly (for instance offshore contractors engaged to assist with software development), we have mandated that the relevant contractor or third party signs an agreement to comply in all respects with GDPR and not to share any data which we share with them with any third parties.
- We are required by law to hold your personal information for as long as is necessary to comply with our statutory and contractual obligations and in accordance with our legitimate interests as a data controller.
We will use reasonable endeavours to ensure that your personal information is maintained and up to date. However, you are under a duty to inform us of any and all changes to your personal information to ensure that it is up to date and we will update or delete your personal information accordingly.
How long we keep your data for
We will retain your personal data for different periods depending on the service you have chosen to use us for, which may be a longer period than that for which we need to hold your data to provide those services, i.e where we are under regulatory or statutory duties to hold your data for a longer period. Unless we are under such obligations, we will retain your information for as long as you have an account with us.
Your rights under GDPR
You have a legal right to a copy of all the personal information about you held by us. On request, we will provide you with a copy of this information free of charge. You also have a right to correct any errors in that information.
In the event that we process your data by automated means where you have either provided us with consent for us to use your information or where we used the information to perform a contract with you, you have the right to request that we send to you or to another organisation, a copy of the personal data we hold about you in electronic form, for example when you are dealing with a different service provider. If you would like us to move, copy, or transfer your information please let us know by email to firstname.lastname@example.org. We will respond to you within one month after assessing whether or not this is possible, taking into account the technical compatibility with the other organisation in question.
You can ask us to delete or remove personal data 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 data where you have successfully exercised your right to object to processing (see below), where you have withdrawn consent for us to process it (as explained below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
You can ask us to suspend the way in which we are using your information in certain scenarios, or object to our processing your data where we are relying on a legitimate interest ground (or those of a third party) and you feel it impacts on your fundamental rights and freedoms, or where we are processing your personal data for direct marketing purposes. In some cases where you object, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Please note that if you want us to restrict or stop processing your data this may impact on our ability to provide our services. Depending on the extent of your request we may be unable to continue providing you with our service.
Any queries or concerns about the way in which your data is being used can be sent to email@example.com.
You have the right at any time to withdraw any consent you have given us to process your personal data. Please note if you withdraw your consent it will not affect the lawfulness of any processing of your personal data we have carried out before you withdrew your consent. Should you wish to do so you can change your consent preferences at any time on your account settings.
As mentioned above, you also have a right to prevent the use of your personal information for direct marketing purposes.
Where we are legally permitted to do so, we may refuse your access request and will give you reasons for doing so. We will seek to act on your request in the timescale required by applicable data protection laws.
Automated decision making and Profiling
In order to provide you with our services, it is necessary for us to conduct profiling on your data as well as automated decision making which will have a legal or otherwise significant effect on you, specifically determining whether or not you are matched with a role, therefore hear about that role and therefore have an opportunity to apply for that role through TalentPool. It is our objective however to match suitable candidates for any role and therefore it is our objective that, where you are not matched with a role, you would have a very low probability of being successful in applying for that role due to not meeting the role’s requirements as set by the Employer. Specifically, the profiling and automated decision making which we conduct , consists of assessing your suitability for a role against the role profile and requirements submitted by an Employer (to illustrate with a simplified scenario, if an Employer requires a fluent French-speaker for a role and you do have not informed us that you speak fluent French, then you will not be matched with that role). It is this process, driven by a series of algorithms designed to match you with roles with which you are best suited, which enables us to deliver our service of introducing you to relevant opportunities and which differentiates us from an open job board.
We profile your data and make automated decisions in order to match you with the roles we feel are most suitable for you. But we don’t always get t right. If you feel that the roles you are matched with through TalentPool are not right for you, you can contact us to request that we review your account manually. Alternatively you may log in to your account at any time to update your preferences in your profile, which will impact the automated decision making process.
Our services are not aimed at children. Our users have to be at least 18 years of age, as set out in our terms of business and use.
Contacting us and Complaints
If you are not satisfied with our response or believe we are processing your personal data not in accordance with the law you can complain to the UK data protection regulator, the Information Commissioner’s Office. Further details can be found at www.ico.org.uk or 0303 123 1113.