TALON PRIVACY POLICY

This policy is designed to help you understand why and how we use personal data for the purposes of the Rehire Project (see below). By personal data we mean information that relates to a living individual and which can identify or be identified with that individual.

We are Talon Operating Ltd (“Talon”), a company registered in England and Wales with company number 09100456 and registered office at City Gates, 2-4 Southgate, Chichester, West Sussex PO19 8DJ and we provide a talent pool service offered to businesses and referred to as, the “Rehire Project”.

We have summarised how Talon uses your personal data below:

Your personal data may be used by Talon to:

  • enable you to access the Rehire Project service made available via the Talon website (rehireproject.com); and
  • contact you from time to time in connection with the Rehire Project.

Your personal data may be used by Talon to keep your details up to date.

The above is an overview of how your personal data may be processed and is by no means exhaustive – please see below for information on how specific types of personal data are collected, processed and shared.

Below, we have tried to provide you with as much information as we possibly can to explain how your personal data may be used.

PERSONAL DATA WE OBTAIN

  1. If you are company representative

A representative of any organisation wishing to sign up to the Rehire Project service will need to provide some basic details in order to register the business. The following details will be collected as part of the registration process:

  • the name of the organisation representative registering the applicable business to the Rehire Project service;
  • the company name and address; and
  • your company email address.
  1. If you are an individual entering a Rehire Project talent pool

Personal data of employees, freelancers, contractors or any other type of worker that may apply will only be collected from such individuals directly. If you are invited to join the Rehire Project, you will be asked to provide the following as part of the registration process:

  • your name;
  • email address;
  • telephone number;
  • latest job title;
  • your broad geographical location (for example your nearest city or town); and
  • leaving date.

HOW LONG IS PERSONAL DATA KEPT FOR?

All personal data is deleted when an account is closed.

WHAT IS THE PURPOSE OF USE?

If you are a company representative

Talon uses the personal data of organisation representatives to enrol the applicable business in, or remove the applicable business from the Rehire Project.

Talon’s legal basis for processing such personal data is that it is Talon’s legitimate interest to process this personal data in making the Rehire Project available to businesses. Without processing such personal data, Talon wouldn’t be able to operate, and authorise businesses to, access and use the Rehire Project service. Talon considers there is no other means by which they could operate the Rehire Project.

If you are an individual entering a talent pool

Talon uses the personal data of individual employees, freelancers, contractors or other workers as part of the service provided in storing personal details in a talent pool for the duration an organisation has a registered account with Talon.

Talon’s legal basis for processing personal data of individuals in the talent pool is consent. Consent will be obtained from individuals at the point of registration to the Rehire Project.

WHO DO WE SHARE PERSONAL DATA WITH?

Internally, Talon only grants access to personal data to those people that need access to that data to carry out their role.

Externally, Talon may share personal data with third parties for specific purposes. It may from time to time share personal data with the following categories of recipients:

  • our service providers, for instance:
    • the companies that manage our IT infrastructure; and
    • our external advisors, for instance IT consultants, accountants and lawyers.

Where we share personal data with service providers we will always ensure that the service provider is committed contractually to only use personal data in compliance with Talon’s instructions and data protection law.

TRANSFERS OF PERSONAL DATA OUTSIDE OF THE EUROPEAN ECONOMIC AREA (EEA)

The EEA is a group of countries that share the same basic data protection law, and therefore the law assumes that where your personal data is transferred between these countries it enjoys a similar level of protection.

Talon generally stores and processes personal data inside the EEA.

However, in some circumstances the third parties who assist Talon in providing the services (suppliers), may transfer personal data outside the EEA.

Where suppliers do so, Talon requires its suppliers to do so in compliance with UK data protection laws, typically requiring them to enter into standard contractual clauses approved by the European Union as providing equivalent protection to what would be in place had the personal data remained in the EEA.

We can provide more information on the non-EEA countries to which we transfer your personal data on request.

YOUR RIGHTS AND HOW TO EXERCISE THEM

European and UK privacy laws give you certain rights in respect of the data that we hold about you.  Below is a short overview of those rights.

  • With some exceptions, you have the right to have a copy of the Personal Data that we hold about you. We may make a reasonable charge for additional copies of that data beyond the first copy, based on our administrative costs.  Where the data is data that you have given to us, you have the right to receive your copy of it in a common electronic format, and to provide copies of it to other people if you wish.
  • You have the right to have the Personal Data we hold about you corrected if it is factually inaccurate.
  • In some circumstances, you have the right to have Personal Data that we hold about you erased (the “right to be forgotten”). This right is not generally available where we still have a valid legal reason to keep the data (for example, if we are obliged to do so by law).
  • You have the right to require us to stop using your Personal Data for marketing purposes.
  • You also have the right in some circumstances to request that temporary restrictions are placed on how we process your Personal Data, For example if we are processing it on the basis of our legitimate interest, and you contest our assessment that our interest is not overridden by your fundamental rights and freedoms.
  • If we are processing your Personal Data on the basis of your consent, you have the right to withdraw that consent at any time, in which case we will stop that processing unless we have another legal basis on which to continue.

In order to protect you and others, we may require you to prove your identity before you exercise these rights.

If you are unhappy with how we have handled your Personal Data, you have the right to complain to your local data protection authority, which in the UK is the Information Commissioner’s Office.  You can reach them through their website at http://ico.org.uk or you can contact them on 0303 123 1113.

CHANGES TO THIS POLICY

We may change this privacy policy at any time. Where we make significant changes, for instance where we use your personal data for materially different purposes, we will email you to let you know.